Aipedia: Principal designers and building safety

AI-drafted PD handover documents

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

A principal designer must give the client a handover document within 28 days of its appointment ending, and AI can help draft it. The danger is a document that describes ideal arrangements rather than what happened, which a successor PD or client may then rely on.

Part of: AI in principal design and building safety

In short

Part 2A reg 11M(5) requires the PD to give the client, within 28 days of the appointment ending, a document explaining the arrangements it put in place to plan, manage, monitor and coordinate design work. On HRBs, the client must pass completion and golden thread information to the accountable person under SI 2023/909 reg 38. AI tools can assemble drafts from project records but may smooth over lapses and open issues. Check every statement against evidence, state gaps plainly and reconcile the document with the golden thread.

How AI is used to draft handover documents

When a Building Regulations PD appointment ends, the PD must explain to the client how it carried out its duties. On HRBs, the client must also hand over completion information to the people who will manage the building. Both draw on years of project records, so AI tools are being used to pull together meeting notes, coordination logs, change records and correspondence into a first draft.

The risk is a document that describes the arrangements a PD should have had, rather than the ones it actually used. See the AI for principal designers overview for other PD uses of AI.

The duties that apply

Part 2A reg 11M(5): no later than 28 days after the end of the appointment, the PD must give the client a document explaining the arrangements it put in place to carry out its reg 11M duties to plan, manage, monitor and coordinate design work.
SI 2023/909 reg 38: on HRB work, the client must give the accountable person and responsible person the specified fire safety and building regulations information and golden thread information by completion, keeping its filing structure, indexes and keys. The recipient confirms it is sufficient to understand, operate and maintain the building and its fire safety systems.
CDM 2015 reg 12(8) to (10): the CDM PD passes the health and safety file to the principal contractor if its appointment ends early, or to the client at the end of the project.

The reg 38 duty sits with the client, but the PD's records usually feed it. Apex's guide to section 135 and principal designers explains how limitation affects PDs after handover.

What can go wrong

Illustrative scenario. A PD replaced part way through an HRB project uses an AI tool to draft its 28-day handover document from its project folder. The draft describes a weekly design review cycle and a formal technical query process. In fact, design reviews lapsed for several months while the client restructured the team, and that gap is not mentioned. The successor PD relies on the document, assumes coordination was current, and later finds unresolved fire stopping details. The client and successor PD look to the outgoing PD for the cost of catching up.

Other gaps found at completion:

arrangements described in general terms that could apply to any project;
open design issues summarised as closed;
references to documents that were never issued;
completion information that does not match the golden thread.

How PI usually responds

A claim that an inaccurate handover document caused loss to the client would usually be treated as professional negligence, subject to the wording. A claim by a successor dutyholder with no contract with the PD may be harder to bring, but the client can claim and pass on costs. Limitation periods under Building Safety Act section 135 can be long for Defective Premises Act claims, so keep cover in place, or arrange run-off, after the appointment ends.

Practical controls

Draft the handover document from evidence, then check every statement against records.
State gaps, lapses and open issues plainly.
List the documents relied on, with versions and dates.
Diary the 28-day deadline from the date the appointment ends.
Reconcile with golden thread content (see AI and golden thread information).
Check that minutes used as evidence are accurate (see AI minutes of design reviews).
Hand over the health and safety file in a usable form (see AI-drafted pre-construction information).

How Apex helps

Apex arranges PI for principal designers. A broker can advise on keeping cover in place after a PD appointment ends and on run-off if the practice stops trading.

Sources

Frequently asked

When is the PD handover document due?

Under Part 2A reg 11M(5), no later than 28 days after the end of the PD's appointment. It goes to the client and must explain the arrangements the PD put in place to carry out its duties.

Is the PD responsible for reg 38 completion information?

The reg 38 duty falls on the client, who must give the information to the accountable person and responsible person. The PD's records usually feed it, so inaccuracies in PD documents can carry through.

Can AI draft the handover document?

Nothing prevents it, but the document must explain the arrangements actually put in place. A PD should check every statement against records and record any gaps, rather than accept a polished summary.

What if the outgoing PD has no time to check the draft?

The 28-day deadline is short, so plan ahead. Keep a running record of arrangements during the project so the handover document can be assembled and checked quickly, rather than reconstructed from scratch by a tool.

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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.