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Reserved Activities, Competence & the Future of Built Environment Regulation

  • Maria Skoutari
  • 11 minutes ago
  • 8 min read

What could the future of professional regulation look like for architects and the wider built environment?

The way we regulate competence and responsibility across the built environment is changing.


In May 2026, the government launched a call for evidence to inform a new strategy for built environment professions, trades and occupations, due to be published in 2027. At the same time, the RIBA has put forward proposals for legislation around reserved activities and a new Built Environment Council.


While these proposals are still developing, they point towards an important shift in the way competence, responsibility and accountability could be understood across the profession.


For architects, Part 3 candidates and other built environment professionals, this is worth paying attention to.


The direction of travel is increasingly towards a system where it is not simply your professional title that matters, but what you are competent and authorised to do.


The wider context

In December 2025, the government announced in its Single Construction Regulator Prospectus that it would publish a new strategy for the built environment professions, trades and occupations in 2027.


The stated ambition is to support a building system where buildings are safe, high-performing and sustainable, while allowing companies and individuals to thrive when they act in the interests of current and future building users.


The government's May 2026 call for evidence is intended to help shape that strategy.

It is deliberately broad, covering the whole building lifecycle through five themes:

  • Pre-design

  • Design and specification

  • Construction

  • Occupation and maintenance

  • Cross-cutting issues, themes and challenges


The call for evidence is not therefore a narrow consultation about architects or any one profession. It is part of a much bigger conversation about how the built environment workforce is trained, regulated and held accountable.


It asks for evidence from across the sector, including built environment professionals, trades and occupations, clients, manufacturers, education providers, regulators and representative organisations.


That breadth is important.


The government is looking at the whole system, rather than treating professional regulation as something that can be addressed within individual professions in isolation.


What are reserved activities?

Alongside the government's work, the RIBA has proposed legislation around reserved activities and the creation of a Built Environment Council.


At the heart of the proposal is a move away from regulation based primarily on professional titles and towards regulation based on specific activities.


The principle is relatively straightforward:

Certain activities that are critical to delivering a safe and high-quality built environment should only be undertaken by people who are authorised and can demonstrate the required competence.


That represents a potentially significant conceptual shift.


Instead of asking only:

"What professional title does this person hold?"


the regulatory system would increasingly ask:

"What is this person competent and authorised to do?"


This links directly to the wider emphasis we are seeing across the profession on competence, scope of practice and accountability.


Which activities could be reserved?

The RIBA proposal identifies a number of activities that could become reserved, including:

  1. The current Building Regulations Principal Designer role.

  2. The submission of key statutory documents, including:

    • Outline planning applications

    • Reserved matters applications

    • Full planning applications

    • Fire safety strategies within building regulations applications

    • Structural design and certification within building regulations applications and final certificates

    • Building services design and certification within building regulations applications and final certificates

    • Building regulations applications and final certificates


The proposal anticipates that the legislation would apply beyond higher-risk buildings, potentially covering significant building work more generally, rather than only the projects currently subject to enhanced regulatory requirements.


The important point is that the proposed system would focus on the activity itself.


Rather than regulating an entire profession in a uniform way, particular activities would be identified as carrying significant implications for safety, quality or accountability, with requirements around who can undertake them.


Why does this matter for architects?

Architectural practice already involves managing responsibility across a complex network of people and disciplines.


Architects coordinate information, advise clients, develop designs, integrate consultant information and make decisions that can have significant implications for compliance, safety and building performance.


A reserved-activity model could formalise some of these responsibilities more clearly.

That could have practical implications for:

  • Scope of appointments

  • Delegation of responsibilities

  • Project team structures

  • Competence checks

  • Sign-off procedures

  • Liability

  • Internal quality assurance

  • The way firms describe and manage their services


For example, if particular submissions or responsibilities become legally reserved, practices may need to be much more explicit about who is responsible for what, whether that person has the appropriate competence, and how that competence is demonstrated.


This could potentially provide greater clarity for clients and building users as well.


However, the success of such a system would depend heavily on how the activities are ultimately defined and implemented.


They would need to be sufficiently clear to provide meaningful accountability without creating unnecessary duplication, bureaucracy or barriers to effective multidisciplinary working.


The balance between public protection and practical project delivery will therefore be critical.


The proposed Built Environment Council

The proposal for reserved activities sits alongside the RIBA's proposal for a Built Environment Council.


The proposed council would provide oversight of professional institutions across the built environment and help ensure that competency requirements are robust, consistent and aligned with public protection.


Under the proposal, members of professional bodies would be eligible to undertake the reserved activities, provided they meet the relevant competency requirements.


This could create a much closer relationship between:

professional institutions → competence standards → statutory authority → public protection.


It could also help address one of the challenges facing the built environment: projects are increasingly multidisciplinary, and problems do not always arise within one professional silo.


Failures can occur at the interfaces between roles.


A more consistent approach to competence across related professions could therefore become increasingly important.


Why is competence becoming so important?

The conversation around regulation is increasingly moving beyond qualification and title towards demonstrable competence.


That does not mean qualifications or professional titles become irrelevant.


Rather, the emphasis is increasingly on whether an individual can demonstrate that they are competent to undertake the responsibilities associated with their role.


That means understanding:

  • What you are competent to do

  • What sits outside your competence

  • When you need supervision

  • When you need specialist advice

  • How responsibilities are delegated

  • How competence is maintained

  • How decisions and sign-offs are evidenced


This is particularly relevant to the changing expectations around professional practice and accountability.


It also reinforces something that is already fundamental to good architectural practice: knowing the limits of your own competence and acting appropriately when those limits are reached.


What could this mean for architectural practice?

If the proposals progress, practices may need to look more closely at how responsibility is allocated and documented.


For example, firms may need to consider whether they have sufficiently clear systems for:

  • Identifying who is competent to undertake particular activities

  • Recording training and CPD

  • Managing supervision and delegation

  • Defining individual scopes of responsibility

  • Checking competence before assigning particular tasks

  • Managing consultant interfaces

  • Evidencing decision-making and sign-off

  • Understanding where liability sits


This does not mean practices need to immediately overhaul their procedures.


The proposals are still developing, and the government strategy is not expected until 2027.


But it is worth considering whether your existing systems would stand up to a regulatory environment where competence and authorisation become more explicit.


The government's call for evidence

The government's call for evidence is particularly interesting because it is asking for real-world examples and quantitative evidence wherever possible.


That suggests an intention to develop policy based on how the system actually operates, rather than relying solely on theoretical assumptions.


And that matters.


Regulation does not exist separately from practice.


If there are recurring problems around competence, supervision, coordination, handover, accountability or training, those experiences can help demonstrate where the current system works and where it doesn't.


The call for evidence is therefore looking across the entire building lifecycle, from pre-design through to occupation and maintenance.


This whole-lifecycle approach is important because responsibility for building safety and performance does not sit with one individual or one profession.


It is shared across a much wider network of people and organisations.


What should architects be thinking about now?

There is no need to make immediate changes to your practice based solely on proposals or a call for evidence.


But there are some useful questions to start asking.


1. Can you demonstrate competence?

If someone asked you to demonstrate why you were competent to undertake a particular responsibility, what evidence would you provide?


That might include qualifications, experience, CPD, supervision, project experience or records of previous work.


2. Are your responsibilities clearly defined?

Do your appointment documents, internal procedures and project structures clearly establish who is responsible for what?


Ambiguity around responsibility can become particularly problematic when things go wrong.


3. Do you understand your scope of practice?

It is important to recognise not only what you can do, but also where you need additional expertise, supervision or specialist input.


4. How is competence maintained?

Competence is not simply something you demonstrate once when you qualify.


It needs to be maintained and developed throughout your career.


That makes CPD, experience and ongoing professional development increasingly important.


5. How does your practice manage accountability?

Consider how your practice records decisions, approvals, delegation, design changes and sign-offs.


If regulation becomes more explicit about who is authorised to undertake particular activities, having clear internal processes could become increasingly important.


What does this mean for Part 3 candidates?

For Part 3 candidates, this is a useful example of how professional regulation is evolving.


PC1 is not simply about memorising legislation or knowing the names of regulations.


It is about understanding the professional environment in which architects operate, including how competence, responsibility, regulation and public protection are developing.


This topic could also be useful in a Part 3 interview.


If you are asked about:

  • Current issues affecting the profession

  • The future of architectural regulation

  • Competence

  • Building safety

  • Professional responsibility

  • The role of professional bodies

  • Changes you expect to see in architectural practice

the discussion around reserved activities and the government's future built environment strategy provides a current example.


The important thing is not simply to repeat the headline.

Instead, consider why the change is being proposed and what its practical consequences could be.


The bigger picture

Although the RIBA's proposal and the government's call for evidence are separate initiatives, they sit within a broader shift in the built environment.


The focus is increasingly on:

Safety.Competence.Accountability.Public protection.Sustainability.Trust.


And these principles are increasingly being considered across the whole building lifecycle, rather than being attributed to one profession or one stage of a project.


For architects, that means understanding not only how to design and deliver buildings, but also how responsibility is allocated within the wider system.


The profession is likely to continue moving towards more explicit conversations around who is competent to do what, who is accountable for particular decisions, and how that competence can be demonstrated.


What should we keep an eye on?

There are two developments worth following closely.


The government's 2027 strategy

The current call for evidence is the beginning of a wider policy development process. Its findings are intended to inform a new strategy for built environment professions, trades and occupations, expected in 2027.


The future of reserved activities

If legislation progresses, the detail will be crucial.


The practical impact will depend on:

  • Which activities are ultimately reserved

  • Who is authorised to undertake them

  • What competency requirements are applied

  • How competence is assessed

  • How competence is maintained

  • How the system interacts with existing professional regulation


It is this detail that will determine what the proposals actually mean for architects and other built environment professionals in day-to-day practice.


Final thoughts

The biggest takeaway is perhaps not the specific list of proposed reserved activities.


It is the direction of travel.


The built environment is moving towards a more explicit competence-based approach to professional responsibility, with increasing emphasis on safety, accountability and public protection.


For architects, that means being able to demonstrate not just that we are qualified, but that we are competent, appropriately experienced and operating within our scope of practice.


For Part 3 candidates, it is another reminder that professional qualification is only the beginning.


The responsibility that comes with being an architect is not simply about having the right title. It is about understanding what you are responsible for, knowing the limits of your competence, working effectively with others and acting in the public interest.


And as the regulatory landscape continues to evolve, those principles are likely to become even more important.

 
 
 

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