On 1 July 2026, two significant sets of regulations made under the Building Safety Act 2022 come into force in Wales; The Building etc. (Amendment) (No. 2) (Wales) Regulations 2025 and the Building (Higher-Risk Buildings Procedures) (Wales) Regulations 2025.
Together, they introduce a dutyholder and competence regime applying to virtually all building work in Wales, alongside a gateway approval regime governing the design and construction of higher-risk buildings (HRBs).
While much of the attention has focused on higher-risk buildings, the wider reforms are arguably the more significant change for the industry. The new dutyholder and competence requirements apply to virtually all building work covered by the Building Regulations, regardless of height or use. Importantly, these obligations attach to the work itself rather than the building control route being followed. Any organisation commissioning, designing or delivering construction projects in Wales should be considering its readiness now.
A new dutyholder and competence regime for all building work A new Part 2B of the Building Regulations, as they apply in Wales, establishes explicit building regulations duties for clients, designers and contractors on all building work, subject to limited exceptions.
The dutyholder roles are deliberately aligned with those under the Construction (Design and Management) Regulations 2015, and where a project involves more than one contractor the client must appoint a principal designer and a principal contractor for building regulations purposes. These are statutory appointments in their own right. Although the same organisations will often perform both the CDM and building regulations roles, the appointments are legally distinct and should be reflected separately in project documentation.
Competence sits at the heart of the new framework. Individuals must have the appropriate skills, knowledge, experience and behaviours for their role, organisations must have the necessary capability, and clients must take reasonable steps to satisfy themselves that those they appoint are competent.
Reliance on generic pre-qualification questionnaires alone is unlikely to be sufficient. There are also important procedural changes. The traditional deposit of plans process is replaced by applications for building control approval, a statutory definition of commencement is introduced, and approvals will lapse after three years if work has not started. Furthermore, fire safety information requirements are strengthened and, on completion, clients must submit compliance declarations from dutyholders to the building control authority. As a result, robust record-keeping throughout the project lifecycle will become increasingly important.
The higher-risk building (HRB) gateway regime
For higher-risk buildings, a staged gateway process will apply. Construction cannot lawfully commence without building control approval at Gateway 2, and the building cannot be occupied until a completion certificate has been issued. The regime applies to new HRBs, to conversions that bring a building within the HRB definition, and to building work on existing HRBs, which brings remediation projects within scope Two of these differences merit particular attention.
First, the definition of applicant expressly includes the client, meaning a director or authorised signatory will be required to sign the Gateway 2 application. This should be reflected in internal governance and approval arrangements well in advance of submission.
Secondly, the decentralised model means that application volumes at individual authorities will be low. While this reduces the risk of the processing backlogs experienced in England, it also means that institutional experience will develop slowly and practice may vary between authorities. Early engagement with the relevant authority on its intended approach is strongly advisable.
Projects already underway
Both sets of regulations contain transitional provisions. In broad terms, work commenced or approved before 1 July 2026 will continue to be governed by the existing procedures. For schemes approaching that boundary, the timing of submissions has become a strategic decision with programme and cost implications in either direction. We are advising a number of clients on this question at present; the appropriate course depends on the circumstances of each scheme, and the analysis should be undertaken now, while options remain open.
What we are hearing from the market
Gleeds recently hosted a client CPD event in Cardiff focused on the forthcoming changes. Almost 70 clients and members of their project teams joined us for a two-hour awareness session covering the new dutyholder and competence requirements, the higher-risk building gateway regime and the practical steps organisations should be taking ahead of implementation.
The level of attendance and engagement reflected a common theme across the market: organisations understand that change is coming, but many are still working through what it means for their projects, appointments, governance arrangements and internal processes.
How Gleeds can support you
Having advised on the English regime since its introduction, Gleeds has spent the past year preparing specifically for implementation in Wales, including engagement with local authorities, fire and rescue authorities and sector bodies on operational readiness.
We are supporting clients with:
Dutyholder and competence reviews
Organisation readiness
Procurement, governance and appointment audits.
Gateway readiness assessments for HRB projects.
Transitional strategy advice ahead of 1 July 2026.
Early engagement with Welsh building control authorities.
Preparing for 1 July 2026
The new regime takes effect on 1 July 2026 and the transitional window is narrowing. Organisations best placed to navigate it will be those that review their arrangements now: appointments, competence assessment, project governance and, for higher-risk schemes, gateway strategy. If you have current or planned work in Wales, we would welcome a conversation.
