The consumers' organisation - which is one of the institute's consultees in its request for a Regulatory Reform Order (RRO) - has published a response to the institute's draft document that pulls no punches.
It questions the entire motivation behind the RRO, and the arguments that the RIBA deploys to support reform.
While the NCC says that the institute may have some argument for reform, it rubbishes the actual document.
The document says: 'In this instance, it is not clear to us what motivates the institute's proposals, particularly as some of them are not well argued and appear on the face of it to represent unnecessary increases in regulation, and so are quite counter to the objectives of the RRO process.
'At best it would appear to be unnecessary rhetoric, at worst it introduces confusion that might serve to hamper the board's ability to regulate the profession appropriately.
'To sum up: we would not rule out supporting changes to the regulation of architects, but we would need to see a convincing case for why and how such changes would benefit consumers.
'We are surprised and concerned by the extent to which the present consultation paper makes little or no attempt to consider the consumer interest, and instead focuses on the interests of the profession.
'This is perhaps in itself an indication of why the role of an independent body in this field remains important,' the response adds.
However the RIBA's head of public affairs, Stephen Harding, said he was 'unsurprised' by the response.
'This was expected,' he said. 'Obviously they would say this kind of thing because they are speaking from the perspective of the consumer.
'The NCC is only one of many consultees and we are expecting the other responses back.
'But we are still confident about the RRO - it is in the spirit of forthcoming legislation and the government's policies on regulation,' Harding added.