High risk buildings - verification during construction: industry guidance

3. Executive Summary

3.1 Introduction

The Compliance Plan Approach (CPA) is being introduced in Scotland for High Risk Buildings as a guidance only approach, to inform future legislative change. Detailed guidance has been delivered and can be found through the links below.

High risk buildings - verification during construction: compliance plan approach - background and implementation - gov.scot

High risk buildings - verification during construction: phase 1 of compliance plan approach - industry guidance - gov.scot (this document)

High risk buildings - verification during construction: phase 1 of compliance plan approach - verifiers guidance - gov.scot

Appendix 2 - PreWarrant Compliance and Procedural Model Form

Appendix 3 - Compliance Plan Model Form

3.2 Purpose

The Compliance Plan Approach (CPA) sets out how compliance with building regulations should be planned, managed, monitored and evidenced for High Risk Buildings (HRBs). It applies across the full lifecycle of a project, from early design and building warrant application through construction to completion.

The CPA is not yet a statutory requirement but is being implemented through national guidance to allow industry and local authority verifiers to adopt the approach ahead of planned legislative change. Its purpose is to reduce the risk of serious non-compliance and improve confidence that completed buildings are safe, compliant and legally occupiable.

3.3 Why the Compliance Plan Approach is being introduced

The approach responds to lessons learned from significant building failures, including defects identified in Scottish school buildings and the findings of the Grenfell Tower Inquiry. Independent reviews concluded that while Scotland’s building standards system is robust, compliance during construction has not always been sufficiently planned, monitored or evidenced.

The Compliance Plan Approach aims to:

• reduce the risk of non-compliant buildings
• clarify roles and legal responsibilities
• ensure compliance activity is planned in advance
• provide a transparent evidence trail to support completion certification

3.4 The Compliance Plan Process – Overview

• Stage 1: Pre‑warrant engagement

For projects within scope of the guidance, early engagement with the local authority building standards verifier (the verifier) should begin at least 12 weeks before the first building warrant application is submitted.

The Relevant Person (normally the owner or developer) appoints a ‘duly authorised agent’^[6] to lead the compliance process. A pre‑warrant meeting is held to discuss the project, identify areas of higher compliance risk and agree how compliance will be demonstrated and recorded.

• Stage 2: Building warrant application

Pre‑warrant information is submitted with the building warrant application. The verifier assesses the proposals and prepares a Compliance Plan, which replaces the Construction Compliance Notification Plan for High Risk Buildings.

• Stage 3: Compliance Plan issued

The Compliance Plan is issued with the building warrant approval. It must be shared with the Relevant Person, design team and contractors and becomes a live project document, updated by the verifier.^[7]

• Stage 4: Construction

During construction, the verifier must be notified at all stages identified in the Compliance Plan. Inspections and evidence are recorded. Failure to notify or provide evidence may result in delays or additional inspection requirements.

• Stage 5: Completion

At completion, the Compliance Plan must be fully completed. The Relevant Person submits the completion certificate, which the verifier must accept or reject within 14 days.

3.5 Key roles

• Relevant Person – legally responsible for compliance and for submitting the completion certificate.
• Duly authorised agent/ future Compliance Plan Manager^[8] – manages and coordinates the Compliance Plan process.
• Design and construction teams – responsible for delivering compliant design and construction and providing evidence.
• Verifier – assesses warrant applications, undertakes inspections and carries out reasonable inquiry.

3.6 Key timescales

• Pre‑warrant engagement: at least 12 weeks before first building warrant submission
• Completion certificate decision: acceptance or rejection within 14 days of submission

3.7 Phased introduction of the Compliance Plan Approach

• From 1 April 2026 – new‑build High Risk Buildings and major cladding remediation works (will need revised when we have an industry guidance publishing date)
• From 1 January 2027 – all other major works to High Risk Buildings
• 2026–2031 – anticipated legislative change to mandate the approach and introduce the Compliance Plan Manager role.

3.8 Conclusion

The Compliance Plan Approach promotes earlier engagement, clearer accountability and transparent recording of compliance activity. Adopting the approach now will support smoother delivery, reduce delays at completion and prepare projects for future legislative requirements.