Episode 229 - Reserved Activities and the Future of Built Environment Regulation

This week we are looking at an important policy development that sits at the intersection of competence, regulation, accountability, and the future structure of the built environment professions in the UK. This episode content meets PC1 - Professionalism of the Part 3 Criteria.

Resources from today's episode:

Websites:

• https://www.riba.org/work/insights-and-resources/professional-features/legislation-for-reserved-activities-and-the-built-environment-council/
• https://www.gov.uk/government/calls-for-evidence/strategy-for-the-built-environment-professions-trades-and-occupations

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Transcript

Episode 229:

Hello and Welcome to the Part3 with me podcast. 

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I am your host Maria Skoutari and this week we are looking at an important policy development that sits at the intersection of competence, regulation, accountability, and the future structure of the built environment professions in the UK. Todays episode meets PC1 of the Part 3 Criteria.

In December 2025, the government announced in the Single Construction Regulator Prospectus, which we covered back in episode 202, that it will publish a new strategy for the built environment professions, trades and occupations in 2027. That strategy is intended to support a building system where buildings are safe, high-performing and sustainable, and where companies and individuals can thrive when they act in the interests of current and future building users, so that the system is trusted.

So in today’s episode, we’re going to go through the direction of travel around the reserved activities and the government’s call for evidence on this future strategy for built environment professions, trades and occupations, and what this could mean for you if you are:

• a Part 3 candidate or recent graduate building your understanding of professional regulation,
• a practising architect or other built environment professional thinking about competence, scope of practice and accountability,
• or someone working in the wider construction and built environment sector who needs to understand how policy change may affect future work, responsibilities and routes into practice.

Let’s start with the broad context:

So as mentioned, the government has launched a call for evidence to inform its future strategy for the built environment professions, trades and occupations, with the stated aim of supporting a building system where buildings are safe, high-performing and sustainable, and where people and organisations can thrive when they operate in the interests of current and future building users. It applies to England and is deliberately broad in scope, inviting responses from across the whole building lifecycle. The call for evidence was published in May 2026 and closes on 12 August 2026, and it is intended to gather evidence that will shape policy development for 2027.

That matters because this is not being framed as a narrow technical consultation about one profession or one regulatory problem. It is part of a wider policy conversation about how the built environment sector is structured, how competence is recognised, and how accountability is defined across different stages of a project. The government has organised the call for evidence around five themes: 

• Pre-design, 
• Design and specification, 
• Construction, 
• Occupation and maintenance, 
• And cross-cutting issues, themes and challenges.

Now, alongside that, the RIBA has published a proposal for legislation on reserved activities and a Built Environment Council. The central idea is to move away from title-based regulation and toward a system where specific activities that are critical to delivering a safe and high-quality built environment are reserved to authorised people who can demonstrate competence.

That is a significant conceptual shift. Instead of regulation focusing mainly on professional title, the emphasis moves to the activities themselves. Under that model, the question is not simply whether somebody may use a protected title, but whether they are competent and authorised to carry out specific high-risk or high-responsibility tasks within the built environment. RIBA presents this as a way to improve clarity, accountability, and public protection.

For Part 3 listeners, that is worth understanding because it reflects the broader regulatory trend toward demonstrable competence, scope of practice, and accountability in real work. Even where the legislation is not yet in place, the direction of travel is clear, in that policy is increasingly focused on what people can safely and competently do, not just what their job title says they are allowed to call themselves.

Why this matters now:

The government’s call for evidence is important because it is gathering the evidence base for a future strategy, and that strategy is explicitly expected in 2027. The published material says the exercise is intended to inform future policy on those working in the building professions, trades and occupations, and it welcomes input from people across the building lifecycle, including professionals, clients, manufacturers, education providers, statutory regulators and representative organisations.

That broad invitation tells you something important in that the government is not treating this as an issue that can be solved only through one profession’s internal standards. It is looking at the whole system. That includes how people are trained, how competence is maintained, how different disciplines interact, and how the built environment workforce can better support public safety, performance and sustainability.

For practising professionals, that means this is a policy area to watch closely because it could influence future expectations around competence frameworks, professional responsibilities, routes to practice and potentially the division of responsibilities between different disciplines in a project team. It is also relevant from a practice perspective because the way a regulatory system is designed affects how projects are managed in real life. If reserved activities are introduced or expanded, firms may need to reassess who signs off what, who leads what work stages, how competence is evidenced, and where risk sits within the delivery team. That is why this is not just policy for policy’s sake. It has practical consequences for appointment structures, scope descriptions, liability management and internal assurance processes.

So let’s look at the RIBA’s Reserved Activities proposal:

The reserved activities proposal is the most conceptually important part of the discussion. The RIBA says the proposed legislation would define specific activities within the built environment that only authorised persons can perform, on the basis that those activities are crucial to delivering a safe and high-quality environment.

The RIBA has identified the reserved activities to include: 

1. The current Building Regulations Principal Designer role 

2. And the submission of key statutory documents, such as:

• Outline planning applications
• Reserved matters applications
• Full planning applications
• Fire safety strategies, within building regulations applications
• Structural design and certification, within building regulations applications and final certificates
• Building services design and certification, within building regulations applications and final certificates
• Building regulations applications and final certificates

The RIBA anticipates that not only higher risk buildings, as defined now or in the future, would be included in this legislation, but all significant building work beyond very small scale domestic projects, such as those that would be carried out under a building notice.

That language is significant because it suggests a more targeted regulatory model. Rather than regulating the whole profession in one uniform way, the system would identify the activities that carry the greatest importance for safety, quality and accountability, and then restrict those activities to people who meet the required competence standard.

For architects, this distinction matters because it shifts attention toward actual competence, verified responsibility, and the ability to demonstrate fitness to deliver key parts of the project process. In practical terms, it would create clearer boundaries around responsibility and reduce ambiguity about who is authorised to take responsibility for particular decisions or submissions. That could strengthen consumer protection, because clients and building users would have more certainty about who is accountable for important parts of the work.

This is especially relevant because much of architectural practice already depends on managing responsibility across overlapping roles. We coordinate information, advise clients, integrate consultant input, and make design decisions that affect compliance, safety, and performance. A reserved-activity model could formalise some of those boundaries more clearly, which would matter for scope definition, appointments, internal delegation, and team competence checks.

At the same time, it would need careful drafting and implementation. Reserved activities would need to be defined clearly enough to be workable, but not so rigidly that they create unnecessary friction or duplication in project delivery. The policy direction is therefore about balance in protecting the public while maintaining a system that still allows efficient multidisciplinary working.

This is where the Built Environment Council would come in:

The Built Environment Council will sit alongside that idea as a proposed oversight body. Its role would be to regulate or oversee the professional institutions in the built environment and ensure competence requirements are robust, consistent, and aligned with public protection objectives. Under the proposal, members of those professional bodies would be the professionals eligible to carry out the reserved activities set out in the new legislation. That would create a closer link between institutional regulation, competence standards, and statutory authority. The professional charter bodies would ensure their chartered members met the appropriate competency standard required by the Built Environment Council. 

If professional bodies are brought under a common oversight structure, then competence expectations across related professions may become more consistent. That would matter in a sector where projects are increasingly multidisciplinary and where failures often arise from gaps between roles rather than from one role alone.

This kind of model also reflects the government’s broader interest in improving building safety and trust in the system. The call for evidence explicitly asks for real-world examples and quantitative data, which suggests the strategy is intended to be evidence-led rather than purely theoretical. For architects, that creates an opportunity to contribute practical insight about where current regulation works, where it breaks down, and which activities most need legal definition.

The government’s call for evidence is structured to inform that wider strategy, and it specifically asks for real-world examples and quantitative data where possible: 

It is open for responses from across the sector, including built environment professions, trades and occupations, and also adjacent sectors such as legal, financial and insurance services.

That breadth is crucial as the strategy is not being shaped only by professional bodies. It is being informed by the wider ecosystem in which projects are funded, designed, insured, regulated and delivered. That means evidence about competence, safety, coordination failures, training gaps, accountability issues and workplace realities is likely to be important.

For practitioners, there is a straightforward message here that policy is being built from evidence, and the more concrete that evidence is, the more useful it is likely to be. The call for evidence is not limited to abstract views. It explicitly welcomes information about how the system works in practice across the lifecycle of a building.

From a Part 3 standpoint, that is a useful reminder that regulation is not separate from practice. The best regulatory systems are shaped by the realities of delivery. If there are recurring problems around handover, competence gaps, poor coordination, weak supervision or unclear accountability, those are the issues likely to influence future policy responses.

So what should you take from this in practical terms:

First, the discussion is reinforcing the central importance of competence. Whether the policy is framed as reserved activities, a new strategy, or a broader built environment reform agenda, the underlying principle is the same. The sector needs people who are demonstrably competent to do the work they are undertaking.

It reinforces the importance of understanding scope of practice. As soon as regulation begins to distinguish between general professional work and reserved activities, firms will need to be more precise about role definitions, supervision arrangements and sign-off responsibilities. That affects how teams are structured and how projects are managed.

It also places more weight on evidence and accountability. If the future system places greater emphasis on who is authorised to do what, then records of competence, training, CPD, supervision and delegation become even more important. That is true whether you are a candidate building towards qualification or a senior practitioner overseeing delivery.

Finally, it highlights the role of professional bodies and regulators in shaping the future built environment system. RIBA’s proposal and the government’s call for evidence are not the same thing, but they are clearly aligned around the broader question of how to improve safety, quality and accountability across the sector.

For those of you in practice, the immediate action is not to change your procedures overnight based on a consultation document. The sensible response is to stay alert to how these ideas develop, to review how your current practice already evidences competence and sign-off, and to think carefully about where your own organisation may be exposed if the policy direction becomes more formalised.

From a Part 3 perspective:

This is a useful topic because it sits directly within the themes of PC1 and professional awareness. You are expected not only to know how buildings are designed and delivered, but also to understand the regulatory environment in which architects operate. That includes how competence is assessed, how responsibility is allocated, and how public protection is maintained.

It is also helpful in interview preparation because it gives you a current example of how the profession is changing. If you are asked about future issues facing architects, this is one of the clearest examples you could use in mentioning a move toward more explicit definition of reserved activities, and a government strategy that is looking across the entire built environment workforce rather than at isolated professional silos.

The key point is the principle, not just the headline. Regulation is increasingly focused on safety, competence, and accountability across the whole project lifecycle. That affects how architects collaborate, how responsibilities are shared, and how the profession demonstrates value in the public interest.

So key things to keep an eye on:

The first is the government’s strategy process. The call for evidence is the beginning of a wider policy development exercise, and the published material says the outcome will inform a new strategy for the built environment professions, trades and occupations in 2027.

The second is how reserved activities are defined, if legislation progresses. The practical significance will depend entirely on how specific activities are drafted, who is authorised to undertake them, and how competence is evidenced and maintained. That detail will determine whether the change is clearer or whether it has deeper consequences for day-to-day practice.

For now, the most useful position is to recognise the direction of travel. The sector is moving toward a more explicit competence-based conversation, and that conversation is increasingly being linked to public safety, sustainability and trust in the building system.

Let’s sum up what we ran through today:

• The proposal is for legislation that would define reserved activities in the built environment and limit them to suitably competent professionals.
• The RIBA argues that title-based regulation is not enough and that competence should be the main regulatory test.
• A Built Environment Council would provide oversight of professional bodies and help align competence standards with public protection objectives.
• The government is already developing a broader strategy for built environment professions, trades, and occupations, with publication expected in 2027.
• The call for evidence takes a whole-lifecycle view of the building process, from pre-design through to occupation and maintenance.
• For architects, the biggest practical issues are accountability, scope definition, competence evidence, and how reserved activities would affect project delivery.