Since 1 July 2026, Part 2B of the Building Regulations 2010 has introduced dutyholder and competence requirements in Wales. They apply to building work requiring building regulations approval — not only higher-risk buildings. Clients, designers, principal designers, contractors and principal contractors all hold duties.

 

G Squared Surveying advises clients across South Wales on whether their arrangements meet the requirements.

What changed on 1 July 2026

Part 2B of the Building Regulations 2010 introduced a dutyholder and competence regime in Wales, broadly mirroring the regime that has applied in England since October 2023.

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The regime places statutory duties on clients, designers, principal designers, contractors and principal contractors involved in building work and design work. It applies to building work that requires building regulations approval, whatever route that approval takes.

 

It is not limited to higher-risk buildings. Separate and additional requirements apply to higher-risk building work, but the dutyholder duties themselves are far broader.

Does it apply to my project?

If your project requires building regulations approval, the dutyholder duties apply.

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For housing providers that reaches well beyond new build and major refurbishment. Depending on the scope of works, it can apply to:

• Void property works

• Adaptations and accessibility works

• Planned maintenance and component replacement programmes

• Refurbishment and remodelling

• Extensions and structural alterations

 

Whether any individual scheme is caught depends on whether the work itself requires building regulations approval. The practical consequence for a housing provider is that duties can arise across a programme of small works, not just on a handful of large projects.

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Projects already underway on 1 July 2026 are not automatically caught. Where an application was correctly deposited with building control before that date, the work generally falls outside the new dutyholder requirements. The position turns on whether a valid application was made before the cut-off, so if you have schemes straddling the date it is worth checking them individually rather than assuming a programme-wide answer.

Who the dutyholders are

​Client

The organisation or individual for whom the building work is carried out. The client holds overall responsibility for making suitable arrangements so that the work complies.

 

Principal Designer (Building Regulations)
Responsible for planning, managing and monitoring the design work and coordinating designers so the design complies with the Building Regulations.

 

Principal Contractor
Responsible for planning, managing and monitoring the building work and coordinating contractors so the work complies with the Building Regulations.

 

Designers and contractors
Each hold their own duties, including a duty not to begin work unless satisfied the client is aware of their duties.

Where more than one contractor is working on a project, or it is reasonably foreseeable that more than one will, the client must appoint a Principal Designer and a Principal Contractor in writing.

If the project has only one designer, they are the principal designer. If the project has only one contractor, they are the principal contractor.

Client duties in summary

As client, you are responsible for making suitable arrangements for planning, managing and monitoring the project so that the design work and building work can be carried out in compliance with the relevant Building Regulations requirements. In practice that means:

• Providing relevant information about the building, site, existing construction, previous works, surveys, risks and constraints

• Appointing competent designers and contractors

• Ensuring project roles and responsibilities are clear

• Allowing sufficient time for design, review, approval and construction

• Cooperating with designers, contractors and other dutyholders

• Keeping project arrangements under review as the project progresses

• Considering whether the works may involve higher-risk building work

 

Your CDM Principal Designer is not automatically your Building Regulations Principal Designer.

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This is the single most common misunderstanding we encounter.

 

The Principal Designer role under the Building Regulations is a separate appointment from the Principal Designer role under the Construction (Design and Management) Regulations. They have different statutory sources, different scopes and different duties. One is concerned with health and safety in construction. The other is concerned with compliance with the Building Regulations.

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An existing appointment for surveying, design, schedules of work, contract administration, clerk of works or quality inspections, CDM Principal Designer duties, or general advisory services does not automatically make that consultant your Principal Designer under the Building Regulations.

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If a firm is to act as Principal Designer under the Building Regulations, it must be expressly agreed in writing.

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If you cannot point to a written appointment naming a Building Regulations Principal Designer, the role may not be allocated on your project at all — and the duty to make suitable arrangements sits with you as client.

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Not sure whether your appointments cover this? Contact us. 

Information the client should provide

To allow designers and contractors to comply with their duties, the client should provide relevant project information as soon as reasonably practicable. This may include:

• Existing drawings

• Asbestos information

• Fire safety information

• Structural information

• Previous approvals

• Surveys

• Access restrictions

• Client standards

• Any known defects, risks or compliance issues

 

For housing providers, the practical question is usually not whether this information exists but whether it can be retrieved reliably and issued at the right point in a programme running to hundreds of properties.

How we help

We act as Client Adviser and Principal Designer Adviser, helping clients and dutyholders navigate their responsibilities under the Building Regulations. Where appropriate, and where we are undertaking design work, we can also fulfil the role of Principal Designer. This allows us to provide either independent advice or direct dutyholder services, depending on the needs of the project.

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We also deliver CPD to boards, asset teams and development teams on client duties under the regime.

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Contact us about your arrangements

Common questions

Does this only apply to higher-risk buildings?
No. The dutyholder and competence requirements apply to building work that requires building regulations approval. Higher-risk building work carries additional, separate requirements on top.

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Does it apply to small works?
It can. The test is whether the work requires building regulations approval, not the value or size of the scheme.

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We already have a CDM Principal Designer. Is that enough?
No. The Building Regulations Principal Designer is a separate appointment and must be agreed in writing. A CDM appointment does not automatically carry the Building Regulations role.

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What if there is only one contractor on the project?

If the project has only one designer, they are the principal designer. If the project has only one contractor, they are the principal contractor.

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What about projects that started before 1 July 2026?

Where an application was correctly deposited with building control before 1 July 2026, the work generally falls outside the new requirements. Schemes straddling the date should be checked individually.

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Who is the building control authority for higher-risk buildings in Wales?
The relevant local authority, rather than the Building Safety Regulator as in England.

This page is a general summary only. It is not legal advice and does not replace your own statutory, legal, procurement, building control or project-specific professional advice. It reflects our understanding of the position as at September 2026. Requirements may change.