High risk buildings - verification during construction: industry guidance

9. Conclusion

This guidance demonstrates how industry users can follow the CPA, before it becomes a mandatory requirement, and it is complementary to guidance issued to local authority building standards verifiers.

Underpinning the CPA are the existing principles that

• Verifiers must only approve a building warrant if it is satisfied that the work involved will be carried out in accordance with building regulations and that nothing in any plan, specification or other information submitted with the application indicates that the building when constructed will fail to comply with building regulations.
• The Relevant Person is responsible in legislation for a completed buildings compliance with building regulations. The verifier’s role is to carry out a ‘reasonable inquiry’ into that certification.

The Relevant Person has always been encouraged to provide themselves with appropriate professional advice. The introduction of a ‘duly authorised agent’ is a step towards anticipated future legislative change, where the Relevant Person for defined building warrants will be required to employ a Compliance Plan Manager

The strengthening of the building standards system is delivered through the CPA by

• Introducing discussions on building standards compliance at an earlier stage in the development of a project, before a building warrant application is made.
• Requiring a project to introduce a role which is more focussed on compliance with building standards and building regulations, including the pre-emptive nature of the approvals system, which is considered as a substantial strength.
• Requiring compliance with building standards and regulations to be planned and recorded in a single place, the Compliance Plan, which will be open to scrutiny on the publicly accessible building standards statutory registers.

Industry is asked to follow the guidance contained in this document, and provide constructive feedback, so that the anticipated legislative change, and supporting guidance can be as effective as possible where the risk of a non-compliance with building regulations could cause harm to those in and about buildings.

Blank forms were published as appendices to the local authority verifier guidance on 5 January 2026. Links to that guidance and the appendices are found 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 - verifiers guidance - gov.scot

Appendix 2 - PreWarrant Compliance and Procedural Model Form

Appendix 3 - Compliance Plan Model Form

Feedback can be submitted to: buildingstandards@gov.scot