BR Principal Designer Competence PAS 8671 and Reg. 11G
Building Regulations now require clear, evidenced competence from everyone who influences compliance. Nowhere is that more important than the Building Regulations Principal Designer. This guide explains BR principal designer competence, what it means under Regulation 11G, how PAS 8671 defines measurable thresholds, what clients must check before appointments, and the practical steps you can take to demonstrate and maintain competence. It is written to help you win appointments, reduce risk, and deliver compliant outcomes.
What Regulation 11G requires of a Principal Designer
Regulation 11G sits inside Part 2A of the Building Regulations and sets a higher bar for the Principal Designer than for other designers. If you are an individual, you must have the skills, knowledge, experience and behaviours to fulfil all Principal Designer duties for the project’s design work.
If you act through an organisation, that organisation must have the organisational capability to fulfil the role, and it must designate a competent individual to manage the Principal Designer functions on its behalf. The organisation must take reasonable steps to satisfy itself that the designated individual has the skills, knowledge, experience and behaviours needed to manage the function so that the organisation fulfils its Principal Designer duties.
Regulation 11F applies in parallel and sets the general competence requirement for anyone carrying out building or design work. It requires individuals to have the necessary skills, knowledge, experience and behaviours, and organisations to have the right policies, procedures, systems and resources to ensure compliance. Trainees can contribute under supervision but cannot be appointed as the Principal Designer.
The “No competence, No role” Rule
Part 2A makes competence a key test. You must not accept a Principal Designer appointment if you do not satisfy both the general competence requirement and the specific Principal Designer competence requirement at the time of appointment. Equally, clients must not appoint you unless they have taken all reasonable steps to satisfy themselves that you meet Regulations 11F and 11G.
Client checks you should expect before appointment
Expect clients to run structured checks before they permit you to start any design work. They must take all reasonable steps to confirm you meet the competence requirements. For higher-risk buildings, clients also have to ask about serious sanctions within the previous five years and consider any available misconduct information. These checks are not optional. They are mandatory in the dutyholder regime and will be scrutinised at gateways and during regulatory oversight.
The organisational capability test
Part 2A defines organisational capability as having appropriate management policies, procedures, systems and resources so that individuals under your control comply with competence requirements and trainees are adequately supervised. Your organisation must be able to evidence this capability. Treat it as a documented management system that covers competence management, supervision, information management, and quality assurance over design work.
Declarations you will sign
At completion and at early occupation for relevant buildings, each Principal Designer must provide a signed statement confirming appointment details and that they fulfilled their duties under Part 2A. Build your file with traceable evidence that supports that confirmation. You do not want to be scrambling for proof at the end.
How PAS 8671 defines Principal Designer competence
PAS 8671:2022 provides the specification for competence thresholds for individuals managing the Principal Designer dutyholder functions. It aligns to BSI Flex 8670, the overarching framework that standardises competence across the built environment. The PAS sets out four areas of competence, with minimum thresholds for all projects and additional thresholds for higher-risk buildings.
The four competence areas you must cover
- Behavioural competence. You must be able to evaluate the limits of your own competence and your organisation’s capability, refuse inappropriate work, and ask for help when needs exceed your limits. You must cooperate with dutyholders, challenge insufficient evidence of design work compliance, and use strong interpersonal skills to drive compliant outcomes.
- Legislative and regulatory framework for compliance. You must understand and apply the building control legislative environment. You need enough grasp of how designers and design work meet legal requirements to appraise, challenge and manage compliance evidence throughout design and into construction.
- Management of design work compliance. You must plan, manage and monitor design work so that the completed building will comply with all relevant requirements. You must manage interfaces between design packages and between design and construction, and you must maintain robust information management arrangements that record compliance strategies and control design change.
- Technical framework for compliance. You must understand general principles of construction, be able to appraise Principal Contractor comments, and know how to find and apply technical guidance and standards to assess evidence of compliance. For HRBs, this expands into active participation in golden thread information and mandatory occurrence reporting.
Additional thresholds for higher-risk buildings
For HRBs, PAS 8671 adds competence thresholds. You must evaluate building safety risks in connection with the mandatory safety occurrence reporting regime. You must be able to follow prescribed procedures for declaring compliance and contribute to accurate digital records in the golden thread. These are specific, testable requirements that go beyond the minimum thresholds for non-HRB projects.
How the PAS links to the Building Safety Act and BSI Flex 8670
PAS 8671 was sponsored by DLUHC and published by BSI to support the competence regime created by the Building Safety Act 2022. It provides enhanced competence requirements that enable independent assessment and third-party accreditation. It maps back to BSI Flex 8670’s core criteria so you can build or choose assessment schemes that are consistent, reliable and comparable.
What “design work compliance” means for your day-to-day role
The Principal Designer’s primary objective under the Building Safety Act regime is to plan, manage, monitor and coordinate design work compliance. That is different from the CDM Principal Designer, whose primary objective is pre-construction health and safety risk management. Under Part 2A you lead on ensuring the design, if built, would comply with all relevant requirements. You coordinate designers, interrogate evidence, manage design change, and keep information flowing to the Principal Contractor.
How to Evidence BR Principal Designer Competence PAS 8671
Use the actions below to build a competence file that satisfies both Regulation 11G and PAS 8671 and that makes client due diligence easy.
- Map your competence to PAS 8671 thresholds. Create a matrix against the four competence areas showing your behavioural, legal, management and technical capabilities. Reference qualifications, CPD, project examples and assessments. If you work on HRBs, map the additional thresholds, including golden thread and occurrence reporting.
- Show organisational capability. Publish your competence policy, procedures for supervision of trainees, your information management approach, and your design change control process. Link these to Part 2A’s definition of organisational capability so the client can see you meet the regulation’s language.
- Designate a named individual for organisational roles. If you act as an organisation, formally designate the individual who manages your Principal Designer functions and record the reasonable steps you took to confirm their competence at the point of designation. Keep the designation letter, CV, CPD log and assessment records together.
- Use third-party assessment aligned to PAS 8671. While not mandatory, accredited independent assessment aligned to PAS 8671 gives clients, co-workers and insurers greater confidence. It also makes revalidation and CPD planning simpler.
- Evidence your behavioural competence. Keep a log of decisions where you refused non-compliant design approaches, escalated concerns, or sought specialist input. Behavioural competence includes the integrity to say no and to report safety occurrences where required.
- Build a compliance evidence trail from day one. Define the compliance strategy, set information requirements, and establish how you will record and manage evidence. Maintain a live register of design decisions tied to the relevant technical guidance and standards you relied upon. This supports your end-of-project declaration.
- Manage interfaces actively. Show how you coordinate package boundaries and control design change. Demonstrate how you respond to Principal Contractor comments and how you resolve conflicts without compromising compliance.
- Prepare for HRB specifics. If you work on HRBs, document how you contribute to golden thread records, how you manage mandatory occurrence reporting, and how you will follow prescribed procedures for declaring compliance.
- Keep competence current. Adopt a CPD plan that aligns to BSI Flex 8670. Revisit your competence matrix at least annually and after key project learning events. Where gaps emerge, schedule targeted learning or bring in appropriately competent support.
- Align internal frameworks to PAS 8671. If you run in-house competence frameworks, update them to conform to PAS 8671 to ensure candidates are tested for the same competences to the same minimum thresholds, and consider external accreditation of the assessment system.
How to verify BR Principal Designer Competence PAS 8671
If you commission Principal Designers, implement a simple, repeatable verification process:
- Require a PAS 8671-mapped competence statement and CV for the individual who will manage the dutyholder functions. Check coverage of the four competence areas and any HRB additional thresholds.
- Assess organisational capability: ask for the competence policy, supervision arrangements for trainees, information management procedures, and design change controls. Cross-check against Part 2A’s definition.
- For HRBs, ask about serious sanctions in the last five years and review any known misconduct. Record your checks and the evidence you relied upon.
- Prefer third-party assessments aligned to PAS 8671 or equivalent. This is not a legal requirement but it materially reduces risk and improves assurance.
What “reasonable steps” look like in practice
Take a proportional approach grounded in the project’s size and complexity. For a small, low-risk scheme, a targeted competence matrix, sample project evidence and references may suffice. For complex or HRB projects, expect deeper evidence: independent assessment, role-specific training records, golden thread capability, occurrence reporting procedures and demonstration of previous HRB experience. PAS 8671 explicitly recognises that project demands modulate the acceptable level of competence while preserving a minimum threshold for all projects.
Common Pitfalls: BR Principal Designer Competence PAS 8671
- Treating competence as a CV exercise. The regulation expects live behaviours, not just qualifications. Evidence how you plan, manage and monitor design work compliance across the project lifecycle.
- Ignoring designation obligations. If you are an organisation, a named individual must manage your functions and you must evidence the reasonableness of your designation decision.
- Weak change control. Most compliance failures arise at interfaces and during late changes. You need documented strategies and controls for change that preserve compliance.
- HRB blind spots. If you work on HRBs, you must show capability in golden thread and mandatory occurrence reporting. Do not leave these to general information management processes.
- Signing end-of-project statements without auditable evidence. Build the file as you go. You will need it for your completion declaration.
FAQs: BR Principal Designer Competence PAS 8671
What is the difference between a BR Principal Designer and a CDM Principal Designer
Under the Building Regulations regime, the Principal Designer’s primary objective is to plan, manage, monitor and coordinate design work compliance so the completed building will comply with relevant requirements. Under CDM 2015, the Principal Designer’s primary objective is managing health and safety in the pre-construction phase. The two roles can be performed by the same party, but the duties and competence tests are distinct.
Who decides if a Principal Designer is competent
Clients decide whether to appoint you, but the decision must be informed by reasonable steps to satisfy themselves that you meet Regulations 11F and 11G. You must also self-police: you must not accept an appointment unless you meet the competence requirements at the time of appointment.
What counts as organisational capability
Policies, procedures, systems and resources that ensure individuals under your control comply with competence requirements, along with appropriate supervision of trainees. Show how your system embeds compliance in practice.
Do I need a certificate to prove principal designer competence PAS 8671
There is no legal requirement to undergo formal assessment. However, accredited independent assessment aligned to PAS 8671 inspires greater confidence among clients and insurers and supports periodic revalidation of competence.
What extra competence do I need for higher-risk buildings
You need additional capability in building safety risk evaluation, mandatory occurrence reporting, golden thread information, and following prescribed procedures for declaring compliance. These are in addition to the four core competence areas.
What evidence should I retain to support my completion statement
Keep appointment records, competence matrices, designation evidence (for organisations), compliance strategies, design coordination records, design change logs, key correspondence with dutyholders, and references to the technical standards used. These support the signed statement you must provide at completion or early occupation.
How does PAS 8671 interact with BSI Flex 8670
PAS 8671 is aligned to BSI Flex 8670 and maps to its core competence criteria. Using a PAS 8671-conforming framework improves consistency and comparability across domains and supports trustworthy third-party assessment.
A simple, defensible pathway to demonstrate BR Principal Designer Competence PAS 8671
- Document your role-holder’s competence using a PAS 8671 matrix that covers the four areas plus HRB additions where relevant.
- Evidence organisational capability with policies, procedures and resources aligned to Part 2A.
- Designate a named manager of the Principal Designer functions and retain the due diligence trail behind the designation.
- Establish your information management and design change control processes from day one and tie them to compliance outcomes.
- If you work on HRBs, integrate golden thread and mandatory occurrence reporting into your plan.
- Consider accredited independent assessment and maintain your competence through planned CPD and periodic revalidation.
Conclusion: BR Principal Designer Competence PAS 8671
Clients and regulators expect you to evidence principal designer competence PAS 8671 and Regulation 11G from the moment of appointment. When you align your people, processes and records to the PAS, you reduce risk, speed up client due diligence, and deliver more predictable compliance. Treat competence as a management system, not a badge. Build your file as you go. Lead coordination with confidence. That is how you win work and stay compliant.
Soft call to action
If you want a quick diagnostic of your principal designer competence PAS 8671 position, ask for a 30-minute review. You will receive a gap analysis against the four competence areas, a shortlist of high-impact actions, and a client-ready statement you can include with bids.
Contact
For more information on evidencing BR Principal Designer Competence under PAS 8671 and Reg. 11G get in touch.
If you need a Principal Designer for Building Regulations who combines deep regulatory know-how with practical design coordination, get in touch. We’ll review your project, confirm competence transparently, and set up a clear plan to deliver compliance from day one.
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For more information on all aspects of the BR Principal Designer role see the collection of articles in our blog.
To discuss the Building Regulations Principal Designer role for your project please call 020 4534 3130.
For further information, please contact :
Sean Robinson
BSc (Hons) MCIOB MIFSM
Director, Head of Dept.
Building Safety
London
Nikki Barrow
BA (Hons) CIHM aFa
Building Safety Coordinator
Building Safety