The client must take reasonable steps to check competence. A declaration should have an attributable supporting trail; the published aggregate decision data does not rank competence gaps as the leading cause of returns.
The regulator's focus is deliberate. The Building Safety Act is built on the premise that safe buildings are produced by competent people whose competence can be demonstrated. The competence declaration is therefore not an administrative checkbox: it is the BSR's first window into whether the delivery structure around your design is credible.
Part 2A of the Building Regulations 2010 (as amended by the Building Safety Act) creates a two-sided test:
| Duty | What it requires |
|---|---|
| Clients (regs 11F/11G context) | Must not appoint a principal designer or principal contractor unless they have taken all reasonable steps to satisfy themselves that the appointee meets the general competence requirement and the role-specific competence requirement. |
| Appointees | Must not accept a principal designer or principal contractor appointment unless they satisfy both competence requirements at the time of appointment. |
| Organisations | Must have appropriate management policies, procedures, systems and resources to ensure the individuals under their control are competent, and must nominate a designated individual to manage the dutyholder functions. |
PAS 8671:2022 (individual principal designers) and PAS 8672:2022 (individual principal contractors) — read alongside BS 8670-1:2024, which superseded BSI Flex 8670 — define the competence thresholds the industry uses to evidence Part 2A compliance. The four areas below relate to the principal designer role; PAS 8672 has its own principal contractor framework.
| Competence area | In essence |
|---|---|
| 1. Behavioural | Evaluating the limits of your own competence, refusing inappropriate work, asking for help, cooperating with and challenging other dutyholders. |
| 2. Legislative & regulatory | Understanding and applying the building-control legislative environment relevant to the work. |
| 3. Managing design-work compliance | Setting the compliance plan, controlling changes to it, coordinating designers, liaising with the principal contractor, monitoring progress to the end of the design phase. |
| 4. Technical framework | Understanding design and construction principles, technical guidance and standards well enough to assess, challenge and build consensus on compliance. |
These are standards and specifications, not legislation. PAS certification is not itself a universal statutory appointment requirement; assess the actual role and work.
For higher-risk buildings, PAS 8671 adds specific, testable requirements beyond the minimum thresholds: the individual must be able to evaluate building safety risks in connection with the mandatory occurrence reporting regime, follow the prescribed procedures for declaring compliance, and contribute to accurate digital records in the golden thread. PAS 8672 provides a separate principal contractor competence framework; do not apply the principal designer checklist unchanged.
PAS 8673 covers competence for managing safety in residential buildings in occupation — relevant to the accountable-person side of the lifecycle.
PAS 8671 is explicitly proportional: the depth of evidence should match the project's size and complexity. For an HRB scheme, "proportional" means deep. A defensible file typically contains:
| Evidence | What it demonstrates |
|---|---|
| PAS 8671-mapped competence statement | Coverage of all four competence areas plus the HRB additional thresholds, in the role-holder's own words. |
| Named individual's CV with HRB project history | That the person — not just the firm — has done this work before. |
| Training records | Regime-specific currency: Building Safety Act, fire safety, occurrence reporting, golden thread information management. |
| Organisational capability documents | Competence policy, supervision arrangements, information-management procedures, design change controls. |
| References / independent assessment | External validation — accredited PAS 8671 assessment where available, or references from comparable HRB projects. |
| Engagement records | Appointment documents, meeting attendance, design-team correspondence — proof the BRPD is actually engaged, not merely appointed. |
| The 'reasonable steps' register | The client's own audit trail: what it checked, when, and what it concluded, for each appointment. |
The competence declaration is a required component of the Gateway 2 application: the client's statement that it is satisfied its appointed principal designer and principal contractor are competent, and how it satisfied itself. Two principles determine whether it survives assessment:
Where someone other than the client submits the application, remember the declaration still belongs to the client: the portal requires the client-signed statement of application, or uploaded written proof of authorisation.
If any of these fail, the application's most query-prone document is already in the pack. Fix it before submission, not in correspondence with the regulator — the mechanics of that trade-off are worked through in our cost-of-delay analysis, and the wider failure landscape in Why Gateway 2 applications fail.
There is no legal requirement to undergo formal assessment. But accredited independent assessment aligned to PAS 8671 gives clients and insurers materially more confidence than self-declaration, and supports periodic revalidation.
Yes — but the organisation must nominate a designated individual who personally meets the PAS 8671 competence thresholds, and must demonstrate organisational capability (policies, supervision, information management, change controls).
The client must take reasonable steps to check competence. A declaration should have an attributable supporting trail; the published aggregate decision data does not rank competence gaps as the leading cause of returns.
The client's duty covers its principal designer and principal contractor appointments; those dutyholders must in turn ensure designers and contractors under their control are competent. Safety-critical specialists should be evidenced as part of the chain.
The client must review the position and, if necessary, re-appoint before works continue. Continuity planning for key role-holders belongs in the construction control plan.
Ask about a document readiness review against an agreed scope. Customer intake opens after service qualification and an accepted engagement. Gate Zero does not provide BSR approval or design certification. Please do not attach submission documents to your enquiry.
Discuss a readiness review →This article is general guidance and not legal or building-control advice. Regulatory references reflect the position at 13 September 2026.