Episode 218:

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I am your host Maria Skoutari and this week we will be talking about the ARB’s new draft guidance notes released for public consultation. Todays’ episode meets PC1 of the Part 3 Criteria. 

Back in episode 195, I ran through the three initially released guidance notes by the ARB to accompany the new Code of Conduct. Those released related to Managing Conflicts of Interest, Managing Finance Appropriately and Raising Concerns and Whistleblowing. 

Still pending at the time when I released episode 195 were guidances relating to Building Safety, Equality, Diversity and inclusion, Leadership, Mentoring and Sustainability. Well now the ARB is formally seeking consultation on those five. 

So let’s dive into what the ARB consultation is seeking and what the new guidance documents cover:

So, in April 2026 the ARB published five new draft guidance documents for public consultation. As mentioned, the purpose of these five new documents are to be supporting guidance for the new Code of Conduct. They are not mandatory in the strict sense but the ARB has been clear that if you depart from them, you should be prepared to explain why, having exercised appropriate professional judgement. In practice, that means they carry real weight. If a complaint is made about your conduct, these documents may be used to assess whether you met the expected standard.

As mentioned, the five documents relate to Building Safety, Environmental Sustainability, Leadership, Equality Diversity and Inclusion, and Mentoring. The consultation period gives architects and other interested parties the opportunity to respond with feedback before the guidance is finalised. The consulation is open until the 14th of May 2026. 

So lets look at each draft guidance document in more detail, starting with Building Safety:

The Building Safety guidance supports Standard 2 of the Architects Code, which requires architects to act in the public interest. That includes protecting the health, safety and wellbeing of those who use, construct, maintain and are otherwise affected by buildings.

The key point the ARB makes here is that building safety responsibilities cannot be avoided or ignored through contractual arrangements or informal delegation. You cannot simply pass safety responsibility to someone else by contract and consider yourself absolved. The ARB is explicit that your obligations arise throughout the full lifecycle of a project.

The key requirements under the Building Safety guidance are that:

• Architects should design with safety in mind from the very outset of a project, not treat it as a late-stage compliance exercise.
• They should place the safety of building users above commercial pressure, client preference or contractual constraints.
• Meeting legal and regulatory minimums is essential but does not, by itself, discharge architects of their professional obligations where foreseeable safety risks remain.
• They should share safety-critical information clearly, accurately and promptly with clients, consultants, contractors and others who need it.
• And consider how safety information is handed over at the end of a project, so that building users, facilities managers and future designers have what they need.

Now the gudiance makes reference relation to undertaking the role of Principal Designer under both CDM and the Building Safety Act:

Under the Construction (Design and Management) Regulations 2015, known as CDM, architects acting as designers must take reasonable steps to eliminate, reduce or control foreseeable risks arising from their designs. Where an architect is appointed as Principal Designer under CDM, they are legally responsible for planning, managing and monitoring the design work to ensure health and safety risks are addressed so far as reasonably practicable.

Where they are appointed as Building Regulations Principal Designer, they are responsible for planning, managing and monitoring the design to ensure compliance with the Building Regulations. This includes coordinating design work, monitoring competence within the design team, managing fire and structural risks, and maintaining accurate safety information as part of the statutory requirement to maintain a ‘golden thread’ of safety-critical information throughout the building’s lifecycle.

The ARB is clear on one particular point relating to these roles, accepting a Principal Designer appointment in name only, without genuine authority or resources to influence design decisions, is unlikely to be consistent with their obligations under the Code.

In addition to this, the guidance expands on fire safety related matters. The guidance highlights that fire safety must be considered early and throughout the design process. Design changes must not undermine agreed fire safety strategies. Where changes are proposed that could affect fire safety or structural integrity, their implications should be assessed and architects should formally advise whether the change maintains compliance and aligns with the original safety intent. Proceeding with design work while uncertain about fire safety implications may be inconsistent with professional obligations.

The guidance also touches on challenging unsafe practice. The guidance is clear that simply disengaging from a project may not be sufficient where there is a foreseeable risk to life or serious harm. Silence or inaction may itself be inconsistent with obligations under the Code. Any concerns should be raised clearly, escalated where necessary, and advice and decision-making should be documented fostering a culture where safety concerns can be raised without fear of reprisal.

So that’s the draft guidance for consulation relating to Building Safety.

Now let’s move onto the second guidance relating to Environmental Sustainability:

The Environmental Sustainability guidance supports Standard 2 of the Code, which requires architects to act in the public interest, including by taking responsibility for the environmental implications of their work. It also engages Standard 3, which requires architects to maintain appropriate skills and knowledge.

The guidance makes clear that passive compliance is not enough. Active engagement with climate and environmental responsibility is now a basic expectation of professional practice.

The key behaviours the ARB expects are:

• Staying informed, architetcs should understand the sources of carbon emissions from the built environment, keep up to date with climate policies, building regulations and recognised standards such as the RIBA 2030 Climate Challenge, the Low Energy Transformation Initiative, and PAS 2080.
• Give clear, honest advice by explaining the environmental implications of design choices to clients, and being frank about limitations and how a design could be strengthened.
• Advocating for better outcomes by championing environmentally responsible design principles from the earliest stages, even when others are not prioritising sustainability.
• Collaborating and influencing by working constructively with clients, engineers and contractors to raise standards.

Now when it comes to the design strategies the ARB expects architects to understand and apply, the guidance sets out a number of established sustainable design strategies. These include:

• Retrofit first by prioritise retaining and improving existing buildings over demolition and new build.
• Fabric first by improve the performance of the building envelope before relying on technology.
• Passive design and daylighting using orientation, form, materials and natural systems to reduce energy demand.
• Using efficient systems and renewables to minimise energy demand and propose low-carbon systems and renewable technologies where practical.
• Consider whole-life carbon by evaluating and reporting on carbon emissions across construction, operation, maintenance and end of life.
• Assessing land use and nature-based solutions and designing with sensitivity to ecosystems and promote solutions such as swales and rain gardens that provide co-benefits including flood control and biodiversity.
• Considering water and biodiversity by reducing water use and enhancing ecological value.
• Factoring pollution and waste by minimising construction and operational pollution as far as possible and eliminating avoidable waste.
• Adopting circular economy principles by designing for disassembly or future reuse from the earliest stages of a project.

In summary, the Code does not expect perfection, but it does require action. Passive compliance is not enough. Architects are expected to use their knowledge, influence and judgement to pursue sustainable outcomes at every stage. That is a very clear signal about the direction of professional expectations in relation to Environmental Sustainability.

So that’s the draft guidance for consulation relating to Environmental Sustainability.

Now let’s move onto the third guidance relating to Leadership:

The Leadership guidance supports Standard 3 (Competence), Standard 4 (Professional Practice) and Standard 6 (Respect) of the Code.

One of the most important points in this guidance is that leadership is not only for those in senior roles. The ARB is explicit in that leadership in professional practice does not depend on job title. Architects may demonstrate leadership at different stages of their career by influencing decisions, supporting colleagues, and raising concerns where professional standards may be at risk.

The key leadership behaviours the ARB highlights are:

• Leading with integrity and values, setting an example for your team.
• Be visible and approachable, and promote open communication so that concerns can be raised without fear.
• Create an inclusive and respectful workplace. Discrimination, harassment and bullying have no place in architectural practice.
• Mentor and train others, including by giving junior staff constructive feedback and guiding them through new challenges.
• Delegating effectively. Those carrying out tasks must have the appropriate supervision, support and resources to do so safely and effectively.
• Managing workloads responsibly. Excessive workloads increase the risk of errors and compromised professional judgement.
• Set clear expectations with clients in writing, including scope, timeline and change procedures.
• Ensure accountability rather than blame. Junior staff should not be left carrying responsibility for issues beyond their control.

So that’s the draft guidance for consulation relating to Leadership.

Let’s move onto the fourth guidance relating to Equality, Diversity and Inclusion:

The Equality, Diversity and Inclusion guidance supports Standard 6 (Respect) of the Architects Code. Respect, the ARB says, is a core professional value and it applies not only to how architects treat colleagues and clients, but also to how they design the built environment.

The guidance requires architects to meet their legal duties under the Equality Act 2010, which means avoiding discrimination based on the nine protected characteristics: age, disability, gender reassignment, marriage or civil partnership, pregnancy or maternity, race, religion or belief, sex, and sexual orientation.

The guidance also refers to inclusive design, in that inclusive design is a core part of an architect’s responsibility. It goes beyond meeting minimum access standards, it is about designing for dignity, usability and equity. Examples of inclusive features include step-free access and wide doorways, clear wayfinding and braille signage, sensory-friendly spaces with adjustable lighting, and gender-neutral toilets or multi-faith rooms. Where appropriate, architects should engage with building users, local communities and groups representing access needs, particularly in the early stages of design.

The ARB also identifies specific risks to inclusion in the workplace itself. Rigid long-hours cultures, unclear promotion processes and informal cliques can all contribute to exclusion. Practices should regularly review whether these dynamics exist and take action to address them. The guidance makes clear that underrepresented colleagues should not be expected to shoulder the burden of culture change.

So that’s the draft guidance for consulation relating to Equality, Diversity and Inclusion.

And finally, looking at the fifth and final guidance which focuses on Mentoring:

The Mentoring guidance applies to architects acting in a mentoring role, and the Code applies whether that relationship is formal or informal. This is particularly relevant for Part 3 candidates and newly qualified architects as you are either being mentored right now or will soon be in a position to mentor others.

The ARB defines mentoring as a professional relationship in which a more experienced practitioner supports the development, confidence and professional judgement of a less experienced person. It involves sharing experience, offering constructive challenge, and encouraging reflection. The purpose is not to direct or control decisions, but to support the development of independent professional judgement. Mentoring is distinct from supervision, management or formal assessment roles, although these may overlap in practice.

The key obligations on architects acting as mentors are:

• Managing the inherent imbalance of experience and influence responsibly.
• Being clear about your role and the limits of your experience distinguishing between opinion and instruction, and avoiding presenting your preferred approach as the only acceptable one.
• Mentor only in areas where you have appropriate knowledge and experience, and direct the mentee to others where matters fall outside your competence.
• Provide honest and constructive feedback, and avoid placing mentees in situations beyond their capability without appropriate support.
• Where mentoring forms part of a structured arrangement, such as a Part 3 candidate’s period of professional practical experience, mentors should commit appropriate time and attention to it and engage constructively with the processes linked to the trainee’s education and training.
• Another key theme is accountability. ARB says mentors remain personally accountable for the guidance they provide, particularly where mentoring relates to learning, training or readiness for practice. If a mentor becomes aware of behaviours, environments or practices that risk harm, exploitation or unsafe learning, they should take appropriate action, including stepping back, seeking advice, or raising concerns through proper channels.

So that’s the draft guidance for consulation relating to Mentoring.

So what does all of this mean for architects in practice:

• These five guidance documents together signal a clear shift in the ARB’s expectations. Building safety, sustainability, leadership, Equality, Diversity and Inclusion, and mentoring are no longer soft professional values but areas where your conduct can be measured against a published standard.
• Although compliance is not mandatory, departing from these documents without good reason and without exercising professional judgement could be used as evidence in fitness to practise proceedings.
• If you hold or aspire to a Principal Designer role, the Building Safety guidance is especially important reading in light of your duties under the Building Safety Act 2022 and CDM 2015.
• The Sustainability guidance makes clear that you cannot remain passive on climate as it expects proactive advice, documentation of sustainability risks, and active advocacy even when clients do not prioritise it.
• Leadership, EDI and Mentoring together reframe professional responsibility as something that extends beyond your own project delivery, it encompasses how you treat and develop the people around you.
• The consultation is still open, so if you have views on these documents, now is the time to respond via the ARB’s CitizenSpace consultation page.

Let’s sum up what we ran through today:

• The ARB published five new draft guidance documents for consultation in April 2026, covering Building Safety, Environmental Sustainability, Leadership, Equality Diversity and Inclusion, and Mentoring, all supporting the Architects Code of Conduct and Practice.
• The Building Safety guidance makes clear that safety responsibilities cannot be delegated away by contract, that meeting regulatory minimums alone is not enough, and that accepting a Principal Designer appointment in name only is inconsistent with your obligations under the Code.
• The Environmental Sustainability guidance requires active, not passive, engagement with climate responsibility, including giving honest advice to clients, advocating for sustainable design strategies, and documenting sustainability-related risks in writing.
• The Leadership guidance confirms that leadership is not only a senior responsibility. Architects at all levels are expected to influence decisions, support colleagues, manage workloads responsibly and foster inclusive and respectful working environments.
• The Equality, Diversity and Inclusion guidance requires architects to meet their legal duties under the Equality Act 2010 and to design inclusively not to a minimum standard, but for dignity, usability and equity.
• The Mentoring guidance establishes that acting as a mentor is a professional activity governed by the Code, and that mentors must manage the power imbalance responsibly, mentor only within their competence, and support the development of independent professional judgement.

These documents, taken together, represent the ARB’s most comprehensive articulation to date of what professional responsibility looks like across the full breadth of an architect’s practice. I would strongly encourage every architect whether at Part 3 stage or further along in their career to read all five and consider responding to the consultation.