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

1. Introduction

This national guidance has been developed by Scottish Government Building Standards Division (BSD) in collaboration with a Local Authority Building Standards Verifier Working Group and the Scottish Building Standards Hub (SBSH).

This document outlines steps that verifiers must follow when processing building warrant applications and completion certificates for defined High Risk Buildings (HRBs) to support implementation of phase 1 of the Compliance Plan Approach (CPA). This guidance is being introduced in anticipation of the CPA becoming a legal requirement which has not been confirmed by Scottish Ministers. Legislative change is not anticipated until after the 2026 Scottish Parliament elections and will be subject to parliamentary scrutiny.

Introduction of guidance at this stage serves several purposes:

• Introduction of measured change through guidance before legislative change, including opportunities for revisions based on feedback from stakeholders.
• Delivering on the Scottish Governments response to the Grenfell Tower Inquiry Phase 2 Report^[1]
• Delivering on the findings of the Review Panel on Building Standards Compliance and Enforcement chaired by Professor John Cole^[2]

This guidance replaces the Verification During Construction (VDC)^[3] guidance for major work to defined HRBs. For all other work requiring a building warrant, the existing VDC guidance remains applicable.

KPO2, to ‘increase quality of compliance assessment during the construction processes’ was removed from the national data collection from 1 April 2026 to allow a full scale review following the publication of the Scottish Government’s response to the Grenfell Phase 2 report and commitment to introduce legislative change for the Compliance Plan approach.

Verifiers are still required to issue Construction Compliance and Notification Plans (CCNP) in accordance with the nationally agreed VDC guidance with all building warrants issued. A Compliance Plan is considered as a CCNP in this requirement.

In terms of managing compliance assessment, the risk being managed is that of non-compliance with building regulations, and the potential consequences, including injury or loss of life.

Verifiers are required to follow this new guidance, as an amendment to the existing VDC guidance as a requirement of the Verification Performance Framework.

The background and overview of the CPA is described in the Compliance Plan Approach – Background and Implementation document.

The stages of implementation of the CPA are anticipated as follows: -

• Introduction of Local Authority Verifier guidance to implement the principles of the Compliance Plan Approach to building warrant projects - December 2025.Verifiers are expected to use this guidance from 1 April 2026.
• Full Compliance Plan Approach for High risk Buildings developed for voluntary adoption by industry and to inform future legislative change - March 2026. An implementation date for the full CPA guidance is under consideration and subject to wider sector conversations.
• Legislative change to mandate the CPA for defined building types – anticipated during the parliamentary term 2026 – 2031.
• Introduction of guidance to implement the CPA for all projects in a risk based scheme following legislative change.

As with the previously published VDC guidance, this guidance does not seek to define 'reasonable inquiry' in terms of the Building (Scotland)Act 2003. However, it would be expected that the Compliance Plan (CP) issued with a building warrant approval for a HRB, would be considered as an expression of the Verifiers plan to carry out ‘reasonable inquiry’.