A Principal Designer and Contractor beco...

A Principal Designer and Contractor become a legal requirement from October


Get ready

The changes come into force on the long expected date of 1 October 2023, however the new legislation (or amended legislation as it is now) was expected to be published months ago and not 6 weeks before the changes apply. The industry has at least got clarity that the new roles of Principal Designer (Building Regulations) and Principal Contractor (Building Regulations) will now be introduced.

(quote from bd)

This applies to ALL projects where Building Regulations apply (no one is safe from this).  The one thing that stands out for me is how this affects my PII.

The larger projects should already have most of the PD and PC information already implemented, it’s the smaller domestic projects that need to be more vigilant in what they are doing.  The client would need to be fully informed of their role and the main being a contract administrator can’t assume a principal designer role 'by accident' (get everything in writing).  

This will affect your insurance…and not for the better.

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@supernova I've just come across this which relates to your post.




Thanks Alex, RIBA had a webinar this week titled ‘In conversation with: Building Regulations Essentials: Building Safety Act - The evolving picture for Architects’, the Q&A was with Paul Bussey Senior Technical Consultant at AHMM. There isn’t a replay of this webinar but I’ll just give the basics of what was discussed.

The most important point is that CDM and Building Regulations PD role relates to ALL buildings/projects.  The PD role for CDM is to plan, manage, monitor. The PD role for BR is the same as CDM, to design and risk manage projects.

The client needs to be made aware that they have duties during this process.  Information needs to be set up for them and they need to be talked through the process. Clients will also be required to fill out a form on completion of the project and state that their duties have been fulfilled.

The PD is in charge of the design process (not a third party who comes in to do the BR that doesn't know the design) AND of coordinating H&S. There has to be an understanding of the PII about fire safety etc (make sure you are covered for the project).

Section 2A has been updated to make sure that the design work complies with BR (it is what architects are doing anyway). You need to demonstrate your competence onsite and that you have a handle on design risk management.  You will also need to demonstrate compliance by producing documents (annotated drawings, identifying critical safety issues, etc.) explaining how you dealt with any issues.

If the PD role is only up to the planning stage then the PD is to pass on enough information to the person doing the BR drawings. The level of detail has to be appropriate, including how the PD met their duties and what they have been doing to comply with BR.

The documents, both written and illustrated, need to demonstrate all the relevant information.  Make sure the drawings are clearly annotated. This will require more time and resources on your part, and will affect the fees you charge your client.

If you are PD throughout the project make sure that all changes/alterations in the project during construction have some form of a control process. All changes (even minor ones) have to be notified to and approved by BC. This will deter alteration requests to the design.

In regards to the Building Control, there will be registered, trained advisors including a wider design group for areas such as Fire, sustainability etc. The process of obtaining BC approval will take time, it was advised that getting the planning drawings with BR criteria already implemented should make this process easier. There may be extra costs depending on the time it takes for Building Control approval.  

In general you don't have to be BR experts, BC will ask the architect to be competent and if the drawings are compliant this should not be an issue. The drawings will need to have a greater level of detailing and annotation for BC. As mentioned earlier it was advised to get the drawings set out early in the planning stage to avoid complications.

It was also noted that PD needs to be independent of PC, so there is no bias in the process (the PD will need to make sure construction is in accordance with the BC approved drawings).

I hope this is useful, just a shame that they don’t have a replay of this as it was very informative.

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@supernova thanks for the great notes on PD.

This is not a problem for architects. In general while submitting planning drawings, building regs have already been taken into account. 

I think the real problem is going to be how do you go about educating contractors who have been working on small scale construction without architects involvement? 

There is a big divide in how the construction industry works, those that work on HRB’s or directly with architects on smaller scale projects and are already well versed in PC/PD roles. Then you get the smaller contractors who may not be aware of changes within H&S and building regs and that’s where the delays are going to come in.

The new regulations also depend on the client being aware of their duties in the building process, who is going to educate them before they even start.  There is an underlying emphasis on client, PD and PC to show competency of the process as they will all have to fill out forms at completion before the Building regs certificates are issued.


Has anyone else seen this?



Posted by: @jane

Has anyone else seen this?



Hi Jane, 

Thanks for the link, there is a lot to say about this.

The regulations do not require the Principal Designer under Building Regulations to be on an accredited register, but a key purpose of the regulations is to ensure that all statutory dutyholders on construction projects have the necessary competence to undertake their work and should be able to demonstrate this competence.

As stated, there is no need for the PD to be on an accredited register only to be competent, so there is no reason for the RIBA setting up a register for this role. The point of an architect is to be competent in all things related to design and construction. This includes building regulations, H&S, construction details, contracts, on-site inspections etc. This is why the profession takes a min. of 7 years to complete.  

The RIBA PD accreditation is in 3 parts and takes a year to complete, costs £420 + VAT and then an annual register fee tbc (up to £420 + VAT)...not only do you have to waste time and money on things you should already know but then you have the annual fee as well. This is more about the RIBA fleecing the members out of more money on top of the membership fee!

RIBA’s position has always been that the architect as Lead Designer is best placed to take on both the CDM and the new Building Regulations Principal Designer role. The new Principal Designer role is an opportunity for architects to bring leadership in an industry-wide culture change to deliver the highest standards of building safety.

This should have been the job of RIBA, to make sure that the profession stays at the forefront to ensure that design, quality, budget and construction are maintained. 

The role of PD doesn’t need to be defined, it is what architects are supposed to be doing on every project. All this is revealing about the RIBA is how to grow more revenue off their members.

A ScottJetsetJB
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RIBA has a new book out, called ‘Principal Designer's Guide’. It costs £29 and has all the information needed for the role, as well as some letter templates.

This is a companion guide to  RIBA Health and Safety Guide 2023. It also complements the new PD accreditation course set out by the RIBA.


Companion guide that provides practitioners with the required knowledge regarding the Principal Designer role as it relates to the Building Safety Act.


Link to the book: https://www.ribabooks.com/RIBA-Principal-Designers-Guide_9781915722201


Thanks @archiZen, from the blurb the book provides ‘practitioners the required knowledge for the PD role’, but on the overview tab

To ensure chartered architects are reaching a high standard of knowledge, the RIBA has introduced an online test based on a comprehensive curriculum to test for competency.

Competency is part of the CPD that is required for all architects and as a body RIBA is aware of this and should already be monitoring. Is there really a need for an accredited course when CDM and H&S have been part of the architects role for quite a few years now, so my question is:


What would you choose?

  1. Principal Designer accreditation (1 year to complete and in 3 parts): £500 plus a yearly renewal fee
  2. RIBA Principal Designer's Guide book: £29
  3. Neither of the above, read new legislation and use common sense: £0

PD accreditation is only for RIBA chartered members. Why?

You'd think an institution like RIBA, supposedly the gold standard of architecture, would appreciate that this is already part of an architect’s role. 

It feels like RIBA is unintentionally encouraging a two-tier industry. Bigger firms like FCBStudios and Fosters can pay these fees without batting an eyelid but this is just another burdensome charge for the smaller practices


I posted about this in November

Posted by: @jbarch

You'd think an institution like RIBA, supposedly the gold standard of architecture, would appreciate that this is already part of an architect’s role. 

Basically as a professional body you are expected to provide value to your members, be expected to represent your interests, are a place for genuine advice and support, but they now have a register for PD accreditation.


From an architect point of view, there is an interesting article in Architects Journal https://www.architectsjournal.co.uk/news/opinion/how-can-the-riba-view-the-new-principal-designer-role-as-a-money-spinner   explaining some of the pitfalls of RIBA’s new PD register.

The RIBA response to this will tell you all you need to know (bolded the relevant bits) 


Jack Pringle, chair of the RIBA board of trustees

Our members are the natural qualified design professionals to act as principal designers and we are fully committed to positioning architects in this role. The initial qualification and subsequent Continuous Professional Development (CPD) requirements which RIBA members currently undertake do not reflect the very detailed and specific competence requirements for the Principal Designer (Building Regulations) role (as set out by the framework for competence of individual Principal Designers, PAS 8761:2022).

However, not all architects will choose to take on this role or demonstrate these specific competences.

So, the RIBA principal designer register addresses the need for architects who wish to take on the responsibility of this defined dutyholder role to demonstrate their competence, and for clients to meet their duty to appoint a competent Principal Designer. While registrants may have an advantage when it comes to securing work, there is no obligation to join the register, and professionals may choose to demonstrate their competence to clients in their own way instead, including through suitable CPD programmes.


The fact we have a professional qualification for this is actually non helpful to RIBA as they want you to be on the register,  just for the prestige or that it turns into another money making scheme…


This is a great piece about how the RIBA are getting it wrong. They are all about making more money, not actually helping architects to thrive. @jbarch as you mentioned above, the larger practices will jump onto the RIBA PD accreditation because they can afford it and make it acceptable, instead of taking a stand and saying that it is not necessary to have.

There is no consistency in what RIBA does, they recently had an article about the Building Safety Act and a small practice adapting, Keri Barr (architect KBA) gives an assessment on how she has modified her work to the new legislation. It all boils down to understanding what is required and updating how you work to accommodate this, making sure that you are covered with what you are designing. The drawings are fully annotated, conform to the building regs and that the materials you specify fit all the requirements and certifications. This is what we were educated to do so you don’t need to be on a register. 

I understand the larger practices wanting to register certain employees on this register because most of the architects end up not going on site, whereas those who work in smaller practices, normally go on site with the projects they are in charge of, understanding that their drawings are up to building regs standards. 

Maybe instead of having a dedicated register they should have just had CPD courses to update architects.

This post was edited 4 mo ago by Supernova

Sorry, a bit late to the party on this one. I fully understand the worry and see where you're coming from jbarch.... it's just one of those things that RIBA got wrong. I was a member of RIBA when at uni and newly qualified then with financial issues decided that I'd had enough. I should have realised that earlier when I was thinking it through and what I was giving up was just the recognised brand. RIBA is just a business and the new register shows how little the members are valued.

There is an old article here about the PD role, I'd suggest you give it a read:


The Building Regulations principal designer (PD) must plan, manage monitor design work, and cooperate, coordinate and communicate to ensure the design work, if built, complies with building regulations.

It is important that the principal designer is part of the design team and not a third-party without any influence over design decisions.

The principal designer should be able to co-ordinate the design team. It may help the principal designer to keep a record of designers and their responsibilities across a project.

A principal designer is not expected to be an expert in every design specialism, but they are expected to know enough about the building regulations to assess whether a building design will comply with all relevant regulations.

principal designers should support others, for example, in being able to pass on necessary information to contractors and explain to them how to demonstrate that elements are built properly.

The issue of RIBA not having the ability to acknowledge the role of the architect makes it hard to prove their worth.

I have to add that as much as it frustrates me, I am not saying i have an answer nor do I expect people to be working for a pittance. I just think these sweeping adjustments make great headlines, but can have a devastating impact on the small business owner, particularly in architecture. The "self-fulfilling spiral of doom" is an appropriate description IMO!


Why architects must embrace the Principal Designer role

This article has really hit a nerve with me, when I became an architect I knew what was required of me and making sure that a project was managed from conception to final certificates was what I had to do. I didn’t study all those years for me to give away my responsibilities. 

There is something quite wrong when an institution is pushing something that is not required. As stated above by @jbarch and @jetset those that can will gladly pay the overpriced yearly registration. What makes this even more bizarre is that this ‘qualification’ is not required.

The more likely scenario of this article is to push this insanity as they may not have had a lot of architects partaking in this ‘new’ (very expensive and not required) scheme.