Status	2026 Regulatory Update
Regulator	Building Safety Regulator (BSR) / Single Construction Regulator (SCR)
Applicability	London Higher-Risk Buildings (HRBs) – Design and Pre-Construction Phase
Compliance Window	Active (Mandatory from 2026)

Introduction

By 2026, Principal Designer (PD) competence is no longer a professional aspiration, it is a regulatory condition. Under the Building Safety Act regime and the evolving Single Construction Regulator framework, London projects are now assessed not only on what is designed, but who is designing it and whether they are demonstrably competent to manage safety-critical risk.

In London, where Higher-Risk Buildings (HRBs), mixed-tenure schemes, constrained sites and complex interfaces are standard, generic competence statements are failing regulatory scrutiny. This guidance sets out exactly what the BSR expects from Principal Designers operating in the capital in 2026.

1. Why Principal Designer Competence Is a Regulatory Gate in 2026

The Building Safety Act assigns the Principal Designer a legal duty to plan, manage and monitor design work so that fire and structural risks are eliminated or controlled so far as reasonably practicable.

In 2026, the BSR’s position is clear:

If competence cannot be demonstrated, the appointment is invalid, regardless of contract or programme pressure.

For London HRBs, this is treated as a Gateway-level compliance issue, not an advisory matter.

2. What the BSR Means by Competence in 2026

Competence is not defined by job title or chartership alone. The regulator now expects three concurrent evidence layers:
 

Skills & Knowledge

Evidence that the PD understands:

• Fire and structural risk pathways
• HRB-specific regulations
• London-specific operational constraints (density, access, adjacency)

Experience

Project-relevant experience, not generic CV history:

• Prior HRB involvement
• London projects with similar risk profiles
• Demonstrable exposure to construction-stage safety decisions

Organisational Capability

Proof that the PD’s organisation can:

• Allocate sufficient time and resource
• Maintain Golden Thread information
• Interface effectively with contractors, regulators and dutyholders

All three must be present.

3. Common Competence Failures Seen on London Projects

Based on early 2026 enforcement patterns, the BSR is routinely challenging:
 

Generic CV Submissions

• Lists of unrelated projects
• No link between experience and HRB risk

 

Ambiguous Role Definitions

• Confusion between CDM Principal Designer and BSA Principal Designer
• Overlapping or unclear responsibilities

 

Competence by Association

• Relying on company reputation rather than named individual capability

 

Late Competence Confirmation

• Attempting to confirm competence later after Gateway submissions
• This is now explicitly rejected

In London, competence must be established before design freeze, not after.

4. London-Specific Expectations for Principal Designers

London projects attract heightened scrutiny due to:

• Dense occupation during construction
• TfL asset protection zones
• Party wall and adjacency risks
• Mixed-tenure liability structures
• Legacy buildings requiring intrusive investigation

 

The BSR expects the PD to demonstrate:

• Active coordination with fire engineers and structural specialists
• Awareness of site-specific logistics and emergency access constraints
• Clear documentation of how London-specific risks are being managed in design

Generic UK competence frameworks are insufficient when London constraints are ignored.

5. 2026 Principal Designer Competence Checklist (London HRBs)

Before accepting or confirming appointment, ensure the following is in place:

Appointment & Role
✔ Principal Designer formally appointed under BSA duties
✔ Scope clearly distinguishes BSA PD from CDM PD where applicable

Individual Competence
✔ Named individual responsible (not just company)
✔ HRB-relevant experience evidenced
✔ Fire and structural risk understanding demonstrated

Organisational Support
✔ Adequate resourcing confirmed
✔ Golden Thread systems defined and operational
✔ Clear interfaces with PC and Accountable Person

London Constraints
✔ Site-specific risk awareness documented
✔ TfL, adjacency and logistics risks acknowledged
✔ Emergency access and occupation interfaces considered

6. Programme and Liability Implications

An invalid PD appointment has serious consequences in 2026:

• Gateway delays or refusal
• Regulatory enforcement action
• Increased PI exposure
• Potential criminal liability for dutyholders

For London HRBs, PD competence is now a programme-critical and liability-critical control point.

 

Navigating London’s 2026 Construction Compliance Landscape: Connected Guidance Across Key Regulatory Milestones

 

As London’s construction sector moves into 2026, the regulatory framework being applied to Higher-Risk Buildings (HRBs) has become increasingly integrated, with product accountability, gateway approvals and dutyholder obligations all intersecting across the project lifecycle. 

 

Understanding how the transfer of building control to the Building Safety Regulator (BSR) affects design submissions is closely tied to the heightened evidential expectations at Gateway 2, where incomplete design packages are commonly rejected. These early stage requirements feed directly into considerations around phased occupation and partial Gateway 3 approval, which depend on coordinated safety strategy and programme sequencing. 

 

The expanding role of the Single Construction Regulator (SCR) in product liability further influences how competence and responsibility are assigned throughout design, procurement and installation processes. This aligns with the evolving competence standards for Principal Designers, whose experience and decision evidence now materially impact compliance outcomes. Meanwhile, emerging fire safety requirements, including provisions for second staircases and integrated evacuation strategy, are shaping both design and submission strategy. 

 

Finally, the increasing enforcement emphasis on remediation delivery timelines highlights how regulatory expectations apply not only to new builds but also to existing stock. Taken together, this interconnected guidance provides a comprehensive picture of how regulatory certainty, evidence readiness and delivery accountability are evolving for London projects in 2026.

 

image: constructionmagazine.uk

Expert Verification & Authorship: Mihai Chelmus Founder of London Construction Magazine | Construction Testing & Investigation Specialist | 15+ years in construction, 10+ years delivering projects in London. Writing practical guidance on regulation, compliance and real on-site delivery reality.