Status	2026 Regulatory Update
Regulator	Building Safety Regulator (BSR) / Fire Safety Regime
Applicability	London Higher-Risk Buildings (HRBs) – Design, Gateway 2 & 3
Compliance Window	Active (Immediate Application)

 

Introduction 

 

By 2026, competence is no longer a background assurance for Principal Designers (PDs) working on Higher-Risk Buildings in London. 

 

It is a regulatory threshold. Under the Building Safety Act 2022, the Building Safety Regulator has moved from accepting professional titles and generic experience to requiring demonstrable, role-specific competence. 

 

In London’s high-density, high-risk environment, failure to evidence competence at Principal Designer level is now a common reason for Gateway delays, enforcement action and appointment challenges. This guidance explains what competence means in practice for Principal Designers in 2026, how it is assessed and what London project teams must do to remain compliant.

 

1. What the BSR Means by Competence in 2026

Competence is no longer defined by chartership alone.

For Principal Designers on HRBs, the BSR expects evidence that the individual and the organisation can actively manage building safety risks, not just coordinate design information.

In 2026, competence is assessed across three dimensions:

• Skills – the technical ability to identify, assess and mitigate fire and structural risks
• Knowledge – understanding of the Building Safety Act, secondary legislation and guidance
• Experience – proven delivery of comparable HRB projects, ideally within London conditions

 

Crucially, competence must be current, relevant and role-specific. Historic experience without recent HRB exposure is no longer sufficient.

2. Mandatory Competence Evidence at Gateway 2

At Gateway 2, the BSR expects the Principal Designer’s competence to be clearly evidenced within the submission package. Typical requirements include:

• A named Principal Designer individual, not just a corporate entity
• A competence statement explaining how PD duties under the BSA are fulfilled
• Evidence of experience on HRBs or complex London buildings
• Demonstrable understanding of fire and structural safety coordination
• Clear interfaces with the Principal Contractor and other dutyholders

 

Generic CVs, marketing brochures or future training intentions are routinely rejected. The regulator is assessing actual capability, not aspiration.

3. London-Specific Competence Expectations

London HRB projects are not assessed in isolation from their environment. The BSR increasingly expects Principal Designers to demonstrate experience with:

• Dense urban sites and constrained logistics
• TfL asset protection interfaces
• Mixed-tenure developments and split accountability
• Occupied buildings and phased construction strategies
• Legacy structures requiring intrusive investigation

A Principal Designer competent on a low-density regional scheme may not meet the threshold for a complex London HRB unless this context is explicitly addressed.

4. Organisational vs Individual Competence

A critical 2026 enforcement trend is the separation between company competence and individual competence. The BSR expects:

• The organisation to have systems, governance and quality controls
• The named Principal Designer to personally meet competence requirements

 

Relying solely on corporate accreditation without identifying a suitably competent individual is a recurring compliance failure. In London, the Principal Designer is treated as a personally accountable role, not a delegated function.

5. Consequences of Non-Compliance

Failure to meet competence standards is not a paperwork issue. In practice, it can result in:

• Gateway 2 rejection or extended review periods
• Requests to replace the appointed Principal Designer
• Programme delays and procurement disruption
• Increased scrutiny at Gateway 3
• Exposure to enforcement action where duties are breached

For London HRBs in 2026, competence is now a programme-critical risk, not an administrative formality.

 

How Fire Egress Strategy Intersects with London’s 2026 Regulatory Compliance Framework

 

Ensuring that fire egress provisions such as second staircases and evacuation strategy are sufficiently progressed in design submissions cannot be viewed in isolation, it is deeply connected to the wider regulatory architecture that London projects are navigating in 2026. 

 

The requirements for second staircase compliance align with expectations for the transfer of building control to the Building Safety Regulator, where robustness of safety submissions is a fundamental check. They also reflect the heightened evidential threshold at Gateway 2, where incomplete coordination frequently leads to rejectable outcomes. 

 

These design and safety criteria directly affect how phased occupation and partial Gateway 3 approval can be delivered without jeopardising occupant safety. They sit alongside the accountability frameworks introduced by the Single Construction Regulator (SCR) and the regulatory emphasis on competence standards for Principal Designers, whose decisions shape the fire engineering outcomes embedded in Gateway packages. 

 

Beyond design, the practical implications of fire safety requirements are mirrored in enforcement contexts such as remediation delivery timelines, reinforcing that safety performance and evidence readiness remain central to both new works and existing stock compliance risk. 

 

Viewed together, these interconnected guidance modules form the backbone of a regulatory environment where safety, documentation and delivery certainty are inseparable in meeting 2026 compliance expectations for London Higher-Risk Buildings.

 

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.