A Practical Guide to the PDBR Role

The introduction of the Building Safety Act has brought significant changes to the construction industry, placing greater emphasis on accountability, competence and compliance throughout the design and construction process.

While many clients are aware of the new Principal Designer for Building Regulations (PDBR) role, there is often less clarity around what the role involves in practice, when appointments should be made, and what responsibilities clients themselves retain under the regulations.

As the regulatory landscape continues to evolve, understanding these duties has become increasingly important. Early and informed decisions around dutyholder appointments can help clients manage risk, support project delivery and ensure that compliance is considered from the outset rather than addressed retrospectively.

Our aim is to provide a straightforward overview of the role and its implications, helping clients navigate an increasingly complex regulatory environment with confidence.

The Principal Designer (Building Regulations) is a dutyholder role introduced under the Building Safety Act and associated amendments to the Building Regulations. The PDBR is responsible for planning, managing and monitoring the design work so that, if built in accordance with the design, the building will comply with the Building Regulations.

The role is intended to create greater oversight and coordination during the design phase, helping to ensure that compliance is embedded throughout the project rather than addressed retrospectively.

This position is distinct from the Principal Designer (CDM) role under the Construction (Design and Management) Regulations 2015, although the two may be carried out by the same organisation where appropriate.

The role emerged in response to recommendations following the Grenfell Tower Inquiry, which highlighted shortcomings in accountability, coordination and compliance within the construction process.

The new regulatory framework seeks to:

• Improve building safety outcomes.
• Strengthen accountability across the project team.
• Ensure competent oversight of design work.
• Improve coordination between dutyholders.
• Create clearer records and evidence of compliance.

For clients, this means that appointing the right dutyholders and establishing clear responsibilities from the outset is now a fundamental part of project governance.

Clients must appoint a PDBR where more than one contractor is involved in a project, or where this is reasonably foreseeable. If no appointment is made, the legal duties of the Principal Designer default to the client. This is an important point, as many clients may unintentionally assume responsibilities they are not prepared to discharge.

Because the PDBR is responsible for planning, managing and monitoring the design work, the appointment should be made as early as possible in the design phase. Early appointment allows the Principal Designer to influence compliance strategy, identify compliance risks, and establish appropriate processes from the outset.

The Principal Designer’s role is primarily to make sure all design work is coordinated so the final building, when built in accordance with the design, will meet the requirements of the building regulations.

Key responsibilities include:

• Planning, managing, and monitoring design work during the design phase;
• Coordinating design work with the designers;
• Ensuring designers cooperate with one another and comply with their duties under the regulations;
• Assisting the client in providing information to the designers and contractors;
• Sharing any information relevant to the planning, management, and monitoring of the building work.

The PDBR does not personally check every single drawing for compliance. Instead, they establish a robust management system to ensure that the designers, including the structural engineers, architects, and services engineers, are talking to each other, resolving compliance issues and providing sufficient evidence to demonstrate compliance before construction starts.

The PDBR are an integral member of the design team, attending all design meetings, establishing the route to compliance and ensuring that a clear trail of design decisions are recorded.

These responsibilities apply across all projects where these dutyholder roles are required. For Higher-Risk Buildings, the Building Regulations introduce additional requirements, oversight and evidence to demonstrate that compliance has been properly considered throughout the design and construction process.

Higher-Risk Buildings (HRBs) are subject to additional regulatory duties under the Building Safety Act framework. These include requirements relating to:

• Gateway approvals with the Building Safety Regulator (BSR).
• The Golden Thread of information.
• Change Control Management.
• Mandatory Occurrence Reporting.

The Principal Designer plays a key role in supporting compliance with these requirements and in assisting the client with submissions and coordination.

The introduction of Higher-Risk Building legislation has also brought a new building control approval regime through the Building Safety Regulator (BSR)*. The gateway system introduces formal approval stages that must be satisfied before a project can progress.

The Principal Designer plays an important role in supporting these applications by coordinating information from the wider design team and helping demonstrate how the project will comply with the Building Regulations. Depending on the project and scope of appointment, the Principal Designer can also assist the client in preparing and administering submissions to the BSR.

*Note: The Building Safety Regulator (BSR) has now transitioned from the Health and Safety Executive (HSE) to an executive non-departmental public body sponsored by the Ministry of Housing, Communities and Local Government. This forms part of the wider move towards a Single Construction Regulator (SCR), which is expected to be fully implemented by 2027 following recommendations arising from the Grenfell Tower Inquiry.

The Golden Thread refers to the digital information that must be created, maintained and stored so that a Higher-Risk Building can be approved through these gateway stages, and be safely occupied, managed and operated once built.

While the Principal Designer can assist with the process, the client retains responsibility for ensuring that the information is held electronically in a facility that complies with the regulations.

In practice, this is usually achieved through a cloud-based Common Data Environment (CDE), which allows the project team to securely share files, track revisions and manage workflows.

Clients should think carefully about ownership and long-term access to this information. If a third-party dutyholder establishes and pays for the CDE, access to critical information could become problematic if the relationship ends or the provider ceases trading.

For Higher-Risk Buildings, the documents approved as part of the Building Control application are known as the “Agreed Documents”. Any deviation from these documents is treated as a “Controlled Change”.

A Change Control Plan and Change Control Log must therefore be established to manage and record design changes. Changes are typically categorised as:

• Notifiable changes: changes that may affect compliance with Building Regulations and must be notified to the BSR before the work proceeds.
• Major changes: changes that undermine the basis on which the project was approved and require approval from the BSR before related work can begin.

Clients should be aware that Major change applications can attract additional fees and may take several weeks for the BSR to assess.

The Change Control Log should record:

• What changed.
• When the change arose.
• Who initiated or approved it.
• Its compliance implications.
• Any related approvals or notifications.

The Principal Designer, Client and Principal Contractor are all required to review the effectiveness of these change control arrangements periodically.

Before construction begins on a Higher-Risk Building, the Principal Designer and Principal Contractor must establish a Mandatory Occurrence Reporting (MOR) system.

This system is designed to ensure that building safety incidents and risks are promptly identified, assessed and reported to the Building Safety Regulator where required.

The MOR system should:

• Define project responsibilities.
• Identify the individuals responsible for oversight.
• Explain how incidents and risks should be reported.
• Provide a standard process for assessing whether an occurrence is reportable.
• Set out procedures for notifying the BSR and recording reference numbers.
• Support decisions on remedial action, investigations and further compliance measures.

The system should also be reviewed regularly and updated where necessary, with relevant changes recorded in the Change Control Log and the Golden Thread of Information.

When appointing a Principal Designer, clients must ensure that the organisation and individuals involved have the appropriate skills, knowledge, experience and behaviours for the scale, type and complexity of the project, as well as the applicable regulatory framework.

In practice, this means considering:

• Relevant project experience.
• Technical competence in Building Regulations compliance.
• Ability to coordinate multidisciplinary design teams.
• Understanding of Higher-Risk Building requirements where applicable.
• Robust management and reporting processes.

Formal appointment arrangements are typically documented through appropriate contracts and scopes of service, which should clearly define the duties and responsibilities associated with the role.

While certain duties always remain with the client, an experienced Principal Designer can help navigate what is often a complex regulatory landscape.

Beyond their statutory responsibilities, the Principal Designer acts as a key coordinator throughout the project lifecycle, helping to establish robust compliance processes, coordinate design work across the design team, and identify potential risks before they become issues. This support can be particularly valuable on Higher-Risk Building projects, where new and enhanced requirements introduce additional layers of complexity.

By engaging early and working closely with the wider project team, the Principal Designer can help clients manage compliance risks, reduce uncertainty and ensure that compliance is considered proactively rather than retrospectively. Ultimately, the role is not simply about meeting regulatory requirements; it is about providing clients with confidence that compliance is being managed in a structured, coordinated and effective manner from the projects inception and then throughout the design phase.

The Principal Designer role represents a significant shift in how responsibility is managed during the design phase of a project. With the regulations placing greater scrutiny on compliance and accountability, the role of the Principal Designer has become central to achieving successful project delivery, and for many clients, the value of the role lies not only in meeting statutory requirements, but in having an experienced professional guide the project through an increasingly complex regulatory environment.

The key takeaway is that the PDBR is not simply an administrative appointment. The role has real legal duties and serious practical implications, particularly on complex or Higher-Risk projects. Early appointment, clear scope definition and collaboration between dutyholders are essential to achieving compliance and delivering safer buildings.

The Principal Designer for Building Regulations plays a central role in ensuring that design work is properly coordinated and compliant with Building Regulations. The role becomes particularly significant on Higher-Risk Building projects, where additional duties such as the Golden Thread, Change Control Management and Mandatory Occurrence Reporting apply.

By understanding the role early and making informed appointments, clients can better manage risk, support efficient project delivery and contribute to the broader industry goal of creating safer buildings for everyone.