---
date: '2024-11-27'
description: and what it meant to be an engineer
id: occupational licensure
modified: 2026-10-12 09:14:55 GMT-04:00
tags:
  - engineer4a03
  - fruit
title: On occupational licensure
created: '2024-11-27'
published: '2024-11-27'
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slug: posts/occupational-licensure
permalink: https://aarnphm.xyz/posts/occupational-licensure.md
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---
> \[!question\]- Question
>
> The Professional Engineers Act gives provincial regulators such as Professional Engineers Ontario (PEO) the responsibility to
> regulate the registration of professional engineers within their mandated jurisdictions. On May 15 2023, PEO implemented
> new changes in the process for one to become licensed as a Professional Engineer in Ontario. [^links]
>
> After your review of the Professional Engineers Act, and the licensing procedure, do you think this new procedure
> strengthens the engineering profession? Does it support what the Professional Engineers Act stands
> for? Is it equitable for engineers whose educational background is not considered ‘traditional’?
> For example one who’s undergraduate degree is not in engineering but have a graduate degree in engineering,
> or are internationally educated engineers?

[^links]: See also [Professional Engineers Act](https://www.ontario.ca/laws/statute/90p28) and [PEO Procedure](https://www.peo.on.ca/apply/licensing-changes#:~:text=applicants%20%E2%80%93%20PEO%20has%20launched%20an,Limited%20Licence%20in%20the%20future)

<blockquote class="quotes"><p>The overthrow of the medieval guild system was an indispensable early step in the rise of freedom in the Western world.</p><p>Milton Friedman</p></blockquote>

According to \[@friedman1962capitalism\{chap. IX\}\], while justified as protecting consumers from fraudulent practitioners, occupational licensure “almost inevitably becomes a tool in the hands of a special producer group to obtain a monopoly position at the expense of the rest of the public.” The Act’s stated object is the opposite: PEO regulates the practice of professional engineering “in order that the public interest may be served and protected” (s. 2(2)). Read against Friedman, the May 15 update mostly moves in the right direction. It removes the barrier that fell hardest on internationally educated engineers and judges experience by competency rather than by where it was gained. The changes strengthen the profession’s assessment of experience. Their narrower academic entry rule also excludes some applicants who could previously seek an equivalence assessment.

### What changed

The May 15 changes removed the Canadian experience requirement, moved every applicant to a competency-based assessment of the 48 months of experience, closed the Engineering Intern program to new applicants, and required applicants to meet the academic and experience requirements before applying.[^peo] PEO also committed to a registration decision within six months for 90% of complete applications.

The first two changes are the ones that matter for equity. A rule that some of your experience must be Canadian is a rule about geography, not about competence, and it fell almost entirely on internationally educated engineers. A competency-based assessment asks what an applicant can do, which is the question a public-interest regulator should be asking. On these points the update is what Friedman’s critique would recommend, and it strengthens the profession by tying the licence more closely to the skill it is supposed to certify.

The other two changes are smaller. Closing the EIT program removes a paid interim status rather than a requirement, since experience still counts toward the 48 months whether or not the applicant was registered as an intern. Requiring applicants to meet the criteria before applying delays their formal entry into the process. The separate change to academic eligibility affects who can enter at all.

### Where it is still inequitable

The academic entry rule narrowed. Before May 15, 2023, applicants with a relevant science bachelor’s, a three-year technology diploma, or qualifications accepted as equivalent could enter an individual academic assessment. PEO could assign exams to address gaps; admission to assessment did not guarantee a licence.[^academic]

For the new process, PEO requires a CEAB-accredited engineering bachelor’s or a recognised engineering bachelor’s plus its technical examination requirements. An engineering master’s or PhD does not replace that undergraduate requirement. PEO’s current guidance also lets holders of unlisted engineering bachelor’s degrees request program verification.[^academic] A physics bachelor’s followed by an engineering master’s therefore needs a more careful argument than counting degrees. The master’s may establish depth in a specialty; it does not by itself establish the breadth of an accredited engineering undergraduate program. An open equivalence assessment would let the applicant demonstrate the missing knowledge.

By defining “qualified” through one kind of degree, PEO risks excluding individuals who may bring valuable perspectives and skills to the profession. This is the part of the system that Friedman’s argument still applies to. Requiring permission from a governing body to work in one’s chosen occupation restricts [[thoughts/Camus#absurd freedom|individual freedom]], and when the requirement tests a credential rather than a competence, the restriction protects incumbents more than it protects the public \[@friedman1962capitalism\]. An academic gate that is stricter than the competence it stands for can create an artificial scarcity of engineers, raise the cost of engineering projects, and push capable people toward jurisdictions where they can more easily practise.

### What would serve the Act better

Maintaining high professional standards is essential, but licensing procedures should not exclude capable engineers. Friedman advocated certification systems that would allow consumers to identify qualified practitioners while not preventing others from practising. PEO has already taken the first step he would recommend for experience. The consistent next step is to apply the same principle to academics: assess what an applicant knows, through exams or a competency review open to any degree path, rather than which program granted the degree, and recognise different levels of expertise through tiered certification. That would keep the standard the Act asks for while opening the profession to the engineers the question asks about.

[^peo]: PEO, [Licensing changes](https://www.peo.on.ca/apply/licensing-changes), effective May 15, 2023. The Canadian experience change followed Ontario’s _Working for Workers Act, 2021_, which bars Canadian experience requirements in regulated professions.

[^academic]: PEO, [pre-May 15 application process](https://www.peo.on.ca/apply/pre-may-15-applicants/application-process), academic requirements, and [application-process FAQ](https://www.peo.on.ca/knowledge-centre/frequently-asked-questions/application-process), academic requirements. Checked October 12, 2026. This essay evaluates the 2023 changes; its 48-month experience requirement belongs to that period.

