What the law requires
On England HRBs the Principal Designer coordinates pre-construction design safety under CDM 2015 and SI 2023/911 dutyholder / competence rules, and supports Gateway packs under SI 2023/909. Competence is an appointing-party judgement — evidence can be stored in software; software does not certify the appointment. Plan continuity into BSA s.76 occupation handover for the Accountable Person.
Key clocks
Appointment
Appoint the Principal Designer in writing before design work begins.
Gateway 2 hard stop
Building work must not start without BSR Gateway 2 approval (SI 2023/909).
Into occupation
Structure information for BSA s.76 handover — not Gateway-3 completion alone.
Primary sources
Operating checklist
Share this briefing with clients, developers, and project teams at appointment stage to set clear expectations about Principal Designer duties under the Building Safety Act 2022, CDM 2015, and SI 2023/911 (Part 2A Building Regulations dutyholders / competence) on England higher-risk buildings.
Role summary
- The Principal Designer plans, manages, and monitors the pre-construction phase
- They coordinate health and safety in design, including fire and structural safety
- On HRB projects they support gateway submissions (SI 2023/909) and golden thread integrity through design and into construction
- They must be appointed in writing before design work begins
- Competence is an appointing-party judgement — software stores evidence; it does not certify the PD
Key obligations
- Ensure design decisions do not introduce unmanaged building safety risks
- Coordinate information flow between designers and the client
- Maintain competence records and declare limitations where relevant (PAS 8671 evidence commonly used)
- Support change control when safety-critical details change (SI 2023/909)
- Prepare and review information required for Gateway 2 and Gateway 3
- Plan continuity of information into BSA s.76 occupation handover for the Accountable Person
- Keep works-phase occurrence / safety reporting arrangements distinct from occupied MOR (BSA s.87 / SI 2023/907 reg.6)
What clients should provide
- Early classification of HRB vs non-HRB status under SI 2023/275 (BSR registration remains authoritative)
- Access to competent specialists (fire, structures, façades)
- A single source of truth for approvals and gateway correspondence
- Resource for information management — not ad-hoc file shares
- Clarity on who will be AP / PAP at occupation, and BAC / MOR readiness expectations after handover
- Awareness of Building Safety Levy timing for applications on/after 1 Oct 2026 (SI 2025/1236) where relevant
How Threadsovereign supports (honest ceilings)
- Gateway checklists and submission packs tracked in-platform
- Golden thread documents versioned with audit trail (works + occupied keep paths)
- Duty-holder actions assigned with due dates and evidence
- Occupied-phase handover information structured for the Accountable Person (s.76 framing)
- AP responsibility-transfer records and s.90 information-transfer checklist available where roles change (s.90 ≠ s.94)
- Accountable Person / PAP BAC duty flagged at handover — see threadsovereign.co.uk/bac-readiness-software
- Platform prepares and evidences — it does not auto-file to BSR / HSE, calculate levy liability, or replace legal advice
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Educational guides are the indexed deep-read for this topic. This checklist stays printable and out of commercial search competition.
For legal interpretation of duty-holder duties, clients should consult qualified construction and fire safety advisers. Guides: threadsovereign.co.uk/duty-holder-competence · threadsovereign.co.uk/gateways · threadsovereign.co.uk/formal-handover. Reviewed 26 July 2026.
© 2026 Threadsovereign Ltd. Provided for general guidance only — not legal advice.