Building Standards
The Building Standards Compliance Plan Approach – Grenfell Inquiry Phase 2 Recommendations
July 30, 2025 by Simon Moore 1 Comment | Category Building Standards, Compliance
We have been working to scope and develop a strengthened building standards compliance regime with the development of the Compliance Plan Approach (CPA). This work follows recommendations made by Professor John Cole, and the Building Standards (Compliance and Enforcement) Review Panel.
In 2024 we moved from a single pilot project to an Early Adopters phase, taking the theory developed through research, public consultation, a live project and industry working groups into practice.
The CPA is about delivering compliant buildings. We aim to make compliance with building standards and the responsibilities for it, more transparent and documented, and hold those who would seek to avoid the legislation to account.
The tools to do this will be provided through the introduction of the Compliance Plan (CP), a new role of Compliance Plan Manager (CPM), and making changes to enforcement and sanctions for offences under the Building (Scotland) Act 2003. Particularly for buildings considered as high risk this means supporting the building owner, or relevant person as it is described in legislation, to fulfil their duty to evidence and deliver a building compliant with the building regulations.
The CP will be created and managed by the CPM and then approved by the local authority building standards verifier as part of the building warrant application before work starts on site. The CP will detail the approach to compliance for a project, including where the work is staged.
The CPM is a new role, and to fully implement it a change in legislation will be required. But that shouldn’t stop us implementing changes such as the CP process through guidance, and that is what we are intending to do from next year.
We will issue revised guidance on verification during construction, applying the CPA principles and documentation to any new qualifying building project which requires a building warrant. This includes any prebuilding warrant discussions, and the issue of a version of the CP with building warrant which will set out clearly the responsibilities and compliance evidencing particular to the project. The CP when completed will allow the verifier to consider if a completion certificate, and its compliance statement, have been lawfully made. This includes when the verifier should be notified, what their inspection and evidencing requirements are, it will record if notifications happened, and how well the verifier responded.
Our next step will then be to publish CPA guidance for industry to voluntarily adopt, prior to legislative change. This will include the steps expected of a CPM, before it becomes a statutory requirement to work with all parties to propose and then monitor the CP.
The publication of revised national guidance in advance of a legislative change is part of the Scottish Government’s response to the Grenfell Inquiry Phase 2 recommendations. This will allow us to follow a recognised change curve and move from early adopters to an early majority before legislative change requires it.
This change process will allow us to continue to receive feedback, review and refine the CPA, so that it is an established practice, and fine-tuned for legislation.
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a positive way forward. Keeping things clear and transparent.