Aipedia: Architects

AI design and access statements: what architects need to know

Aipedia, by the Apex broking team · Last reviewed 2026-10-27

Architects can use AI to draft design and access, heritage and planning statements, but they must check every policy reference and, at appeal, declare the AI use. Errors in these documents can cost clients consent, time and money.

Part of: AI in Architects

In short

About 32% of AI-using practices use AI for drafting reports and documentation (RIBA AI Report 2026). Planning documents are an obvious target. The Planning Inspectorate's guidance on AI in casework evidence, updated 23 September 2026, requires intentional AI use to be declared, with references to the parts affected, the checks made and confirmation of responsibility for accuracy. Improper AI use may be unreasonable behaviour leading to a costs award. A fabricated policy reference in a heritage statement can sink an application and lead to a claim.

How architects use AI for planning documents

The RIBA AI Report 2026 found 32% of AI-using practices use it for practice management such as drafting reports and documentation. Planning documents are a natural fit: design and access statements, heritage statements for listed buildings and conservation areas, planning statements, and appeal statements of case.

The appeal of AI is speed: a tool can summarise local plan policies, describe the scheme from drawings and produce a polished narrative. The weakness is that it can invent policy numbers, misquote the development plan or describe heritage significance in generic terms that a conservation officer will see through.

The rules that apply

The Planning Inspectorate's Use of artificial intelligence in casework evidence guidance was first published on 6 September 2024 and updated on 23 September 2026. It applies in England and Wales to all parties in appeals, applications and examinations. Key points:

declare intentional AI use to draft or substantially rewrite text, summarise or analyse, generate or alter images, or create content beyond formatting;
say what AI was used for, with paragraph, section or appendix references, describe the checks made and confirm responsibility for accuracy;
spellcheck, grammar and formatting tools need not be declared;
each expert should declare for their own documents, and a catch-all declaration is unlikely to suffice;
improper AI use may be unreasonable behaviour leading to an award of costs.

Architects Code Standards 1.1 (impartial judgement based on evidence), 3.2 (keep up to date) and 4.5 (accurate records) also apply. The Planning Inspectorate declaration explained goes into more detail.

What can go wrong

Illustrative scenario. An architect uses AI to draft a heritage statement for alterations to a listed building. The statement cites a local plan policy that does not exist and summarises the significance of the building using details from a different property. The council refuses consent and criticises the statement. At appeal the error is raised again, the client faces delay and extra professional fees, and blames the architect.

See Apex's listed building scenario for how such disputes develop. A costs award at appeal for unreasonable behaviour falls first on the client, who may then seek to recover it from the architect.

How PI usually responds

A claim that negligent planning documents caused refusal, delay or wasted costs is usually within the scope of an architects' PI policy, subject to the wording. Points to watch:

proving that the error, not the merits of the scheme, caused the refusal is often difficult, which affects the value of the claim;
whether a costs award passed on by the client is covered depends on the policy definition of damages;
if the practice regularly acts as planning agent, that activity should be declared to insurers.

The ARB minimum is £250,000 each and every claim under the ARB PII guidance.

Practical controls

Check every policy, guidance and case reference against the source document.
Write heritage significance from the practice's own site research, not AI summaries.
Keep the AI draft, the checked version and a note of who reviewed it.
Prepare a specific AI declaration for appeal documents, document by document.
Declare AI-generated or altered images too (see AI renders).
Explain to clients in the appointment how AI is used (see telling clients about AI).

Back to the AI in architecture overview.

How Apex helps

Apex arranges PI for architects who act as planning agents as well as designers. A broker can check that planning work is declared and how costs-related losses are treated by your wording.

Sources

Frequently asked

Do I need to declare AI use in a design and access statement?

The Planning Inspectorate declaration applies to evidence in appeals, applications and examinations it handles. For council applications, check local requirements. Declaring material AI use and checking every reference is good practice either way.

What should the declaration say?

That AI was used, what for and how, with paragraph, section or appendix references, what checks were made, and confirmation that the author takes responsibility for accuracy. Each expert should declare for their own documents.

Can AI summarise local plan policies safely?

It can help find relevant policies, but summaries can be wrong or out of date, and tools sometimes invent policy numbers. Read each policy in the adopted plan before citing it, and check whether newer plans or national policy have superseded it.

Can AI misuse lead to a costs award?

Yes. The Planning Inspectorate guidance says improper AI use may be unreasonable behaviour leading to an award of costs. The award is made against the party, who may then look to the architect if the architect prepared the evidence.

Check your PI covers how you use AI

Tell us about your firm and the work you do. A broker will review how your current PI treats AI-assisted work, or arrange new cover. No fee for a quote. Or call 0117 325 0027.

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Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales, company number 07014570. This page is general information about how AI is used in the profession and how insurance may respond. It is not legal, regulatory or insurance advice on your circumstances, and it does not guarantee that cover will be available or on what terms.