Aipedia: Principal designers and building safety

Part 2A, CDM and AI: PD duties explained

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

No regulator has issued AI guidance for principal designers, so AI use is governed by the existing Part 2A and CDM 2015 duties. Those duties are binding and focus on competence, coordination and records, which is exactly where AI tools are being used.

Part of: AI in principal design and building safety

In short

Neither the Building Safety Regulator, a standalone body since 27 January 2026, nor HSE has published AI guidance for principal designers. AI use therefore falls under existing law: Part 2A regs 11F and 11G on competence, reg 11I on ceasing to be competent, regs 11J and 11K on compliant design, and reg 11M on planning, managing and monitoring design work. Under CDM 2015, regs 9 and 11 govern design risk. The CROSS-UK panel in Report 1554 suggested designers consider disclosing AI-assisted outputs and that approving authorities may ask how far AI contributed.

No AI guidance from the BSR or HSE

As at October 2026, no guidance specific to AI use by principal designers had been published by the Building Safety Regulator (BSR), HSE or MHCLG. The BSR left HSE and became a standalone arm's-length body on 27 January 2026, sponsored by MHCLG, and its announcement mentions a new Innovation Unit and efficiency measures without any AI detail. HSE continues to enforce CDM 2015.

That leaves PDs applying existing law to new tools. This page maps the duties most often engaged when AI is used. For an overview of the profession, see the AI for principal designers overview.

Who regulates principal designers

Body	Role for PDs	AI publication	Status
Building Safety Regulator	Building control authority for higher-risk buildings in England	None specific to AI	Not applicable
HSE	Enforces CDM 2015	None specific to PD use of AI	Not applicable
RICS	Regulates surveyor members, some of whom act as PD	Responsible use of AI in surveying practice	Mandatory from 9 March 2026
IStructE	Professional body for structural engineers	Implementing AI in structural engineering (5 February 2026)	Guidance
Engineering Council and RAEng	Ethical principles for registered engineers	Statement of Ethical Principles (February 2026)	Statement of principles
CROSS-UK	Confidential safety reporting	Report 1554 (16 July 2026)	Expert panel commentary, not binding

There is no single professional body for PDs. Architects (ARB and RIBA), engineers and surveyors act as PDs under their own codes, so the AI rules that bind a PD depend on who the PD is.

Part 2A duties mapped to AI use

Part 2A of the Building Regulations 2010 was inserted by SI 2023/911 and has applied in England since 1 October 2023. Its duties are binding law.

Reg 11F: competence means the skills, knowledge, experience and behaviours (for individuals) or organisational capability (for organisations) needed for the work. Knowing what an AI tool cannot do is part of that.
Reg 11G: the PD must have the competence needed for the PD role, and an organisation PD must designate a suitable individual to manage its PD functions. That individual has to be able to judge AI output, not just receive it.
Reg 11I: a PD that stops meeting the competence requirements must notify the client. See whether AI use is a competence question.
Reg 11J: anyone carrying out design work must ensure it is planned, managed and monitored so that it complies with all relevant requirements.
Reg 11K: designers must ensure the design would comply, provide sufficient information, and report compliance concerns to the PD. AI-produced design information still has to meet this standard.
Reg 11M: the PD must plan, manage and monitor design work, coordinate it so the design would comply, liaise with the principal contractor, and give the client a handover document within 28 days of the appointment ending.

Reg 11M is the duty AI coordination tools most obviously touch. A dashboard can support monitoring, but the PD must still understand what it checks and what it misses. AI design coordination covers this in practice.

CDM 2015 duties mapped to AI use

Under CDM 2015, the client appoints the PD in writing (reg 5). Two duties matter most when AI is used:

Reg 9: designers must eliminate foreseeable risks so far as reasonably practicable, reduce or control those that remain, and pass information about them to the PD. An AI-generated list of hazards does not eliminate anything.
Reg 11: the PD must plan, manage and monitor the pre-construction phase, identify and eliminate or control foreseeable risks, ensure designers comply with reg 9, and assist the client with pre-construction information.

Reg 12 adds the health and safety file, which the PD prepares and keeps up to date. AI drafting can help, but generic content makes a file harder to use. See AI-drafted pre-construction information.

The CROSS 1554 panel view on disclosure

CROSS-UK Report 1554 described an AI-written calculation report for a roof plant installation on an existing mixed-use building. The panel said AI tools are not known to be capable of structural engineering judgement, cited the mandatory competence duties in Part 2A regs 11F, 11G and 11H, and made two points relevant to PDs:

designers should consider disclosure and transparency where AI-assisted outputs form part of an engineering submission;
approving authorities may wish to seek clarity on how far AI tools contributed to submissions.

This is panel commentary, not a rule. But a PD coordinating a Gateway 2 package should expect the question and know the answer. See AI in Gateway 2 applications.

Professional body AI rules that reach PDs

RICS members acting as PD must follow the RICS AI standard: written reliability decisions, an AI register, a quarterly risk register and client notice in terms of engagement.
Structural engineers should note IStructE guidance, including senior engineer review of AI designs and sharing AI policies with stakeholders such as Building Control. It also advises avoiding AI tools on security-sensitive projects.
Registered engineers are expected under the Statement of Ethical Principles to consider the risks of AI and maintain competence in novel areas.

What it means in practice and for PI

In practice, a PD using AI should be able to show who checked each AI-assisted output, against what, and why the PD was satisfied. That record supports reg 11G competence, reg 11M monitoring and any later defence. Apex's principal designer and Building Safety Act guide sets out the wider Building Safety Act position.

For PI, there is no statutory requirement for PDs; competence is the legal test, and cover follows contracts and the PD's profession. A PD error involving AI will usually be treated like any other professional negligence claim, subject to the wording, the PD role being declared and any fire safety restrictions. See PD insurance and AI.

How Apex helps

Apex arranges PI for principal designers. A broker can map your PD duties, including any AI-assisted processes, to how your policy describes your activities, so the cover reflects the work you actually do.

Sources

Frequently asked

Is there any binding rule on AI use by principal designers?

No AI-specific rule exists. The binding duties are in Part 2A of the Building Regulations 2010, CDM 2015 and SI 2023/909, and they apply whatever tools are used. RICS members acting as PD are also bound by the RICS AI standard from 9 March 2026.

Must a PD disclose AI use to building control?

There is no legal requirement. The CROSS-UK panel in Report 1554 suggested designers consider disclosing AI-assisted outputs in engineering submissions and said approving authorities may wish to ask, so being ready to explain AI involvement is sensible.

Which Part 2A regulation matters most for AI coordination tools?

Reg 11M, which requires the PD to plan, manage and monitor design work and coordinate it so the design would comply if built. Reg 11G competence sits behind it: the designated individual must be able to judge what the tool shows.

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.