The below FAQs address common questions about the Principal Designer role and the upcoming register.

Please check back here for updates as we add new queries and answers.

Will CIAT have a Register(s) for Principal Designers under the Building Safety Act?
Yes. The requirements, processes and fees for registering as a Principal Designer with CIAT will be published in spring 2024. 

The Institute's Building Safety Act Principal Designer Competency Steering Group has determined any such Registers will only be accessible to Chartered Architectural Technologists.

Will it be mandatory for Chartered Architectural Technologists to be on CIAT's Principal Designer Register?
No. It is not a legal requirement to be on a Register, however Chartered Architectural Technologists will need to be able to demonstrate their competence.

The benefit of being on a Register is that an external organisation has reviewed and assessed evidence in order to determine their competence. However, there are benefits for Chartered Architectural Technologists that apply to be on the Register as it will provide prospective clients, dutyholders, members of the public, and building users assurance that the work has been/will be carried out by a competent professional. In turn, this may provide them with a competitive advantage over other professionals that have chosen not to be on a Principal Designer Register.

Why will CIAT only allow Chartered Architectural Technologists to apply for the Principal Designer Register?
It is important for those who provide services directly to clients, such as sole traders who have not yet attained Chartered Architectural Technologist status, to qualify as soon as possible to ensure their efficacy in demonstrating their skills. Affiliate status for those providing services directly to clients is intended to be a route into the Institute to allow them to come through for Chartered Membership whilst maintaining compliance with the Code of Conduct.

Through its Professional Assessment process, the Institute can ensure that Chartered Architectural Technologists provide services to clients and users within their technical expertise and professional capabilities. CIAT works to maintain and enhance standards of professional and technical proficiency in Architectural Technology and its quality assurance procedures ensure that all Chartered Architectural Technologists achieve and maintain the required level of knowledge, skill and professionalism in Architectural Technology. 

This is why all those wishing to register with CIAT as a Principal Designer will need to qualify as a Chartered Architectural Technologist. This is achievable relatively quickly via the Professional Assessment qualifying route. Free Chartered Membership short courses are available for all Associate members and affiliates. The short course explains in detail the requirements and processes to qualify. These are held bi-monthly and are promoted via AT Weekly and on the CIAT event calendar.

I understand CIAT is considering introducing an assessment and/or interview process similar to the Chartered Membership qualifying process, evaluating members on aspects including behaviour, legislation, management, and technical knowledge. Could you please provide details regarding this as well as the envisaged timeline for implementing this?
The requirements, processes and fees for registering as a Principal Designer with CIAT will be published in spring 2024.

What is CIAT's plan for supporting its membership in navigating the new roles, and how does CIAT view this role in comparison to CDM Principal Designer?
CIAT intends to focus on registration of the Principal Designer as outlined under The Building Regulations etc. (Amendment) (England) Regulations 2023. The Construction (Design and Management) (CDM) Regulations 2015 serve a different purpose (albeit that the same competent professional may offer both services), there is no intention to include them in this initiative. There are currently no plans to implement a Health & Safety test.

Will CIAT modify its Code of Conduct to restrict Chartered or Fellow Members from offering Principal Designer services if they are not on  CIAT’s Principal Designer Register? 
No, the existing Code of Conduct already addresses this matter clearly. It explicitly states that members and affiliates must operate within their capabilities and recognise their own limitations. Therefore, if an individual lacks the capacity or experience to provide a specific Principal Designer service or role, they should refrain from offering it to the market. Our intention is not to detail every single service, especially considering the increasing specialisation within the industry. The Code is designed to encompass a wide array of services. However, it remains crucial that members and affiliates possess the necessary expertise and resources to effectively deliver any service they offer. 

Under Flex 8670 any organisation offering a Building Safety Act-related (i.e. Principal Designer or Principal Contractor) Register must determine how information about a registrant’s validation and/or revalidation is to be made accessible to members of the public, building occupants, dutyholders etc.

Although we value the Principal Designer competency framework update presented at the conference after the 2023 Annual General Meeting (AGM) in Birmingham, as Chartered Architectural Technologists, we are questioning the necessity of introducing an additional register, akin to the Institute's Accredited Conservationist Register. We hold the belief that Chartered Architectural Technologists already possess the requisite knowledge stipulated within the Institute's Code of Conduct and through the rigorous assessment process to qualify as a Chartered Member.

Could you offer insights into the rationale behind establishing this framework? Our assumption is that it might cater more towards Chartered or Fellow Members in academia, active or inactive affiliates or Associates as well as non-members rather than those actively practicing Chartered or Fellow Members.

However, we understand that all Chartered Architectural Technologists involved in project management are being advised to consider joining the Institute's register to act as Principal Designers during the construction phase under the Building Safety Act. 
The register is a method to demonstrate competence to those making the appointments and will be open to Chartered Architectural Technologists who run projects from conception to completion, as you have outlined, this is their sphere of practice. We are currently in the process of: 

  • establishing competence performance criteria
  • determining performance evidence requirements to demonstrate competence
  • determining proportionality for registration under all building types
  • developing methods to assess competence
  • establishing CPD criteria to maintain registration

I'm using both RIBA and CIAT Building Safety Act resources and there appears to be some discrepancies with respect to the Principal Designer role – is one of these inaccurate?
It is not necessarily an inaccuracy, just a different approach. The RIBA is combining its training with that of CDM Principal Designer. Whilst the same individual may be competent to offer both services, they are distinct and have different outcomes.

You are invited to review our recently published position statement in relation to registration of Principal Designers here.

Will additional safety qualifications be necessary, or will experience be considered?
The necessity of additional safety qualifications will depend on whether an individual meets the Institute's requirements for registration as a Principal Designer in the respective strand of the register. Therefore, for certain individuals, having prior experience may or may not suffice without additional experience and/or qualifications.

Do Chartered Architectural Technologists already have the necessary skills, or will they need to engage in additional continuing professional development (CPD)?
This will vary because some of our Chartered Architectural Technologists already possess substantial design experience in ensuring regulatory compliance and dealing with Building Control. Our goal is to ensure that individuals acting as Principal Designers on all buildings including HRBs are suitably accommodated within registration options. We envisage re-accreditation will be required every 3-5 years, as there is a requirement to reassess these individuals on a cyclical basis to ensure their ongoing competence and suitability to remain on our register.

Is it permissible for the client to appoint different organisations, taking into account specialist CDM practitioners, for the two Principal Designer roles, or is it necessary for the CDM PD and Building Regulations PD to be fulfilled by the same individual or organisation?
Yes – there is nothing in the legislation to prevent this. In fact, it even states that the CDM PD and BSA PD may be the same. The client is obliged to appoint a "competent" person for the role. It is therefore imperative that the client understands their obligations to avoid any misunderstanding.

With regards to liability, will the individual in the Principal Designer role, overseeing the project (approved and designated on the CIAT BSA register) be primarily held accountable through their company's professional indemnity insurance, whether owned by them personally or not?

Alternatively, will the individual also bear responsibility according to the CIAT Code of Conduct, assuming some personal liability? Additionally, we assume that, for a company to act as a Principal Designer under the BSA, only a qualified and registered individual within that practice will have the authority to certify and oversee the project.
The legislation is clear in that the Principal Designer function may be undertaken by either an individual or a company. It is the responsibility of the individual or the firm to liaise with their insurance provider to ensure that all services that they offer are covered.

In respect of the Code of Conduct – all members and affiliates are individually responsible for ensuring their continuing compliance with all clauses. 

The legislation requires an individual or firm to be competent to provide this service and that is why CIAT is exploring proportionate methods to assist Chartered Architectural Technologists in demonstrating their competence to potential clients, such as a Principal Designer Register.

Members have previously enlisted external Principal Designers in adherence with the CDM 2015 regulations. Will Chartered Architectural Technologists be required to fulfil the Principal Designer duties outlined in the BSA as designers, while external consultants are ineligible for this role?
There is no intention to include the Construction (Design and Management) Regulations 2015 (CDM) in this initiative, as they serve a different purpose (albeit that the same professional may be competent to offer both services). The relationship and differences between the two Principal Designer roles are covered under PAS 8671 as below:

This PAS does not cover the duties of Principal Designers under the Construction (Design and Management) Regulations 2015 (CDM). Whereas the primary objective of the Principal Designer under CDM is to plan, manage, monitor and coordinate health and safety in the pre-construction phase by identifying, eliminating or controlling forseeable risks, the primary objective of the Principal Designer under the BSA is to plan, manage, monitor and coordinate design work compliance.

In respect of the fulfilment of the function on different projects, it would be for the firm to consider whether or not to appoint sub consultants to undertake this on their behalf if they are offering the services as with CDM PD and any other specialist functions. It is important for members and affiliates to understand, however, when the role is triggered and how the client intends for the requirements to be fulfilled. As with CDM PD, in some instances, notably domestic, if the client has not appointed a competent Principal Designer under the BSA, the default may be the first designer.

Would an individual require separate professional indemnity insurance in addition to the coverage provided by their employment?
If an individual is employed by a firm, it is typically expected that the firm covers any work under their professional indemnity insurance (PII). With CIAT Chartered Practices, many of them are insured under through the CIAT Insurance Services PII scheme, and it's crucial for a firm to declare which services they offer to ensure appropriate coverage is secured under their PII.

If you are an employee, it's advisable to ask your employers to confirm that their PII extends to cover your work.

My Local Authority Building Control Department is interpreting Chapter 4 - 11K - Additional duties of designers, "carrying out design work" including carrying out a feasibility/sketch proposal even if the agent was not contracted or engaged to provide planning or technical documentation submission.

In the case where a client submits a building notice for domestic works along with a sketch or feasibility study, this implies responsibility for the designer, irrespective of their engagement? If so, how might this affect my Professional Indemnity Insurance premiums?
Within this legislation, the following clause stands out in respect of your query and is quite clear:

(2) Any person carrying out any design work must take all reasonable steps to ensure the design work carried out by them (and by any workers under their control) is planned, managed and monitored so that the design is such that if the building work to which the design relates were built in accordance with that design the building work would be in compliance with all relevant requirements.

The crucial element here is the requirement to take "reasonable steps". Additionally, it is essential to note that this legislation is applicable to ALL buildings, emphasising the need for proportionality.

With respect to Professional Indemnity Insurance (PII) premiums, we would recommend discussing this with your PII provider who is best placed to assess your exposure to risk, given the specific nature of the project you will be taking on.

The importance of having a clear contract with the client with a scope of works detailing what is included in the service offered is paramount to avoid any unintended consequences. It is also crucial that the client understands their duties under the Act. If this is not clearly defined and, in a domestic setting, it is likely that the PD role will default to the first designer. Other than this, all "designers" have responsibilities under the legislation.

Seeking advice from both your insurer and a legal expert, preferably experienced in consultant service contracts in the construction industry, is highly advisable to make an informed decision.

Case 1

I have been asked to provide a service proposal to a client for a project involving x blocks of y flats with an approximate construction cost of z million. My role will be to advance the already approved RIBA Plan of Work (POW) stage 3 design to RIBA POW stage 4, and I will charge based on time spent. The client is a contractor/property developer who will handle the construction themselves and engage other consultants. These consultants include a fire safety engineer who will prepare the fire safety risk assessment and check the designs against it. Additionally, there will be an engineer responsible for civil work, structural engineering, and drainage, as well as an M&E consultant.

I can informally demonstrate my competence working on flats up to RIBA POW stage 4, as I have previously worked as a lead technologist on flats up to RIBA POW stage 4 for other practices.

Q1. Can I act as a Principal Designer under the new Building Safety Act?
Role as Building Safety Act Principal Designer:

Ensuring your competence and understanding the scope of liability under The Building Regulations etc. (Amendment) (England) Regulations 2023 is crucial. It is important to consider the appropriateness of taking on the role of PD under the Building Regulations etc. (Amendment) (England) Regulations 2023, since you will not be involved throughout the entire project. This is especially relevant if other designers will be engaged for the remainder of the project. Ensuring that you have the necessary autonomy to carry out your duties is essential. It is advisable to maintain open communication with your insurer regarding this role to ensure that your coverage remains comprehensive throughout the stages in which you are involved in the project.

Client and Principal Contractor duties:
Given that your client is a contractor/property developer undertaking both client and principal contractor duties, it is essential to formalise your arrangement in writing. Clearly outline your role up to RIBA POW stage 4, ensuring your position as the Principal Designer is relinquished in a manner that aligns with the regulatory requirements. Should this not be clear on the contract, the risk could potentially extend further than the requirements of the Principal Designer should any issues stem throughout the life of the project.

Seeking advice from both your insurer and a legal expert, preferably experienced in consultant services contracts in the construction industry, is highly advisable to make an informed decision.

Demonstrating competence:
Your experience as a lead technologist on flats at RIBA POW stage 4 is valuable; however, it is crucial to determine whether you have the relevant skills, knowledge, and experience to undertake the work of this project. Please see our Code of Conduct and refer to Clause A5 Offering and/or Providing Services Directly to a Client, clause v) and vi). You may also wish to visit the Building Safety Regulator website for guidance to further understand the competence required to demonstrate under the new Building Safety Act. 

Q2. How much should my Professional Indemnity Insurance (PII) cover be?
Determining the appropriate level of PII is crucial and highly dependent on the scope and complexity of your project. We recommend discussing this directly with your insurance provider, as they can assess your risk exposure and help you determine the adequate level of cover required.

Q3. Do CIAT terms of engagement /offer of services letters allow Chartered Architectural Technologists to offer services whilst setting out the maximum level of PII we wish to be liable for?
While CIAT's standard terms of engagement are tailored for domestic projects, we recommend exploring the RIBA's Professional Services Contracts which are endorsed by CIAT, which might offer more suitable options. We are expecting a draft of the BSA PD version which RIBA is intending to finalise and make available in Spring 2024. However, it is important to note that in considering the new PD role, it is imperative to scrutinise the terms and ensure they are comprehensive and appropriate for your project, including all the services that you will be offering.  

Seeking advice from both your insurer and a legal expert, preferably experienced in consultant services contracts in the construction industry, is highly advisable to make an informed decision.