A mid-sized interior design practice in London completes the fit-out of a boutique hotel in the residential portion of an eight-storey mixed-use building. The specification covers everything inside the curtilage of the hotel: wall linings, ceiling treatments, fixed seating, decorative panelling in the corridors, soft furnishings, ironmongery, lighting, FF&E. The work signs off, the hotel opens, and eighteen months later the building is reviewed under the Building Safety Act 2022 dutyholder regime ahead of an insurance renewal. The reviewer flags two issues. A decorative timber panelling system specified for the corridor walls does not have the fire-rated certification the building's gateway approvals assumed; and a category of soft furnishings specified for the public areas does not meet the Class 1 surface-spread-of-flame requirement for the route of escape. The cost of removal, re-specification and replacement, together with the building's principal designer's investigation costs and the hotel operator's loss of trade during remediation, is £420,000. The hotel operator's solicitors write to the interior practice citing breach of contract and negligent specification.
Nothing about that scenario is theoretical in 2026. The Building Safety Act 2022 has restructured the dutyholder regime for higher-risk buildings, the Defective Premises Act limitation period has been extended retrospectively to 30 years for completed dwellings, and the practical effect for interior designers whose specification of materials, fittings and FF&E forms part of an in-scope project is that the liability tail is now longer and the regulatory backdrop denser than at any point in the profession's history. This article is the companion to our designers PI insurance UK guide and addresses the specification-risk profile UK interior designers actually face, where it diverges from the design-and-build risk profile of architects, and how Professional Indemnity Insurance responds.
The specification work that interior designers actually do
Interior designers are commissioned to deliver the look, feel, function and material performance of interior spaces, typically working within an architectural shell delivered by others. The deliverable is a combination of design intent — drawings, schedules, mood and material boards — and a set of specifications that describe in precise terms what is to be installed and how. For commercial and hospitality projects the specification typically covers wall and ceiling finishes, partitions and fixed joinery, flooring, doors and ironmongery, sanitaryware, lighting, AV and IT integration, fire-rated and non-fire-rated decorative elements, soft furnishings, and the full FF&E schedule.
The specification is also a decision-point about who carries the risk for product performance. The interior designer who simply names a category — "decorative wall panelling, fire-rated to Class 0" — leaves it to the contractor to identify a compliant product. The interior designer who names a specific product — "[manufacturer] [system reference], colour [code], to fire performance [classification]" — is taking a more active position and is, in commercial reality, more likely to be in the line of fire if that named product fails to perform.
For higher-risk buildings under the Building Safety Act, the choice of who carries the specification risk is no longer purely a contractual question. The dutyholder regime now imposes statutory design duties on those who take design decisions, and an interior designer whose specification influences the building's compliance with the relevant functional requirements may be a designer for those purposes regardless of how the contract is structured. We address this in detail below.
The procurement of FF&E is a related but distinct piece of work. Where the interior practice procures FF&E directly — placing orders with suppliers on behalf of the client, taking title to the goods, managing delivery and installation — the practice is taking on contractual obligations and warranty exposures that go beyond the design-advice envelope. Where the practice simply specifies and the client procures directly through a contractor or a procurement consultant, the position is different. The contract has to be explicit about which model applies on each project.
The regulatory and professional backdrop
There is no statutory regulator for UK interior designers in the way there is for architects or engineers. The principal voluntary body is the British Institute of Interior Design (BIID), which operates a registration scheme, a code of conduct, CPD requirements and a strong steer towards adequate PI cover. The Chartered Society of Designers (CSD) sits alongside the BIID and is more discipline-agnostic; the Design Business Association (DBA) is consultancy-focused and publishes guidance on contracts and procurement. None of these is a statutory regulator and none can impose a minimum PI limit on members in the way the architects' or accountants' regulators can, but membership of the BIID in particular is taken positively by insurers and is increasingly relied on by procurement teams.
The Building Safety Act 2022 is the legislation that has reshaped the interior designer's risk profile. The Act came into force in stages from 2022 to 2024 and introduced a comprehensive dutyholder regime for higher-risk buildings (HRBs). HRBs are, broadly, buildings at least 18 metres in height or with at least seven storeys that contain at least two residential units, plus care homes and hospitals meeting the same threshold during design and construction. The Building Safety Regulator (operated under the Health and Safety Executive) administers the regime.
The dutyholder regime is modelled closely on the Construction (Design and Management) Regulations 2015 and identifies a client, a principal designer, designers, a principal contractor and contractors. Each has statutory duties to plan, manage and monitor the design and construction so that the building, when completed, complies with the relevant requirements of the Building Regulations. "Designer" is defined functionally — anyone who in the course of a business prepares or modifies designs for construction work, including specification — and an interior designer whose specification of fire-rated materials, wall and ceiling linings, fittings or finishes affects compliance with the functional requirements of the Building Regulations is a designer for these purposes.
The Defective Premises Act 1972 was amended by the Building Safety Act to extend the limitation period under section 1 (dwellings only) to 30 years for works completed before 28 June 2022 and to 15 years for works completed on or after that date. For an interior designer whose specification forms part of a defective premises claim on a dwelling, that is a very different time horizon from the standard six-year contractual limitation period. The extension is retrospective: works completed many years before 2022 can now be the subject of fresh claims within the 30-year window.
The Office for Product Safety and Standards (OPSS) oversees consumer-product safety and the UKCA marking regime. Fire-performance classification for interior building products is governed by Approved Document B of the Building Regulations and by the relevant British Standards (BS 476 series, BS EN 13501-1), each of which an interior designer specifying for in-scope work needs to understand in working detail. The Health and Safety Executive retains oversight of the broader construction-safety framework and the CDM Regulations 2015, which continue to apply to interior fit-out projects that meet the threshold.
How interior designer PI responds to specification claims
Most modern design PI wordings include negligent specification as a core insured peril alongside the unintentional-IP cover discussed in our graphic designer IP infringement claims cluster. Cover responds to defence costs and damages where a client or third party alleges that the practice's specification was defective, did not match the brief, did not perform as specified, or did not meet a regulatory or compliance standard the project required.
Several wording points specifically matter for interior designers.
The first is whether the policy responds to specification of fire-related products and to advice on higher-risk buildings under the Building Safety Act. Some PI wordings written for the wider design sector exclude or sub-limit cover for cladding-adjacent specification, for fire-related product advice, or for work on HRBs generally. The exclusions emerged after the post-Grenfell tightening of cladding cover in the architects' PI market and have spread to some interior wordings. A practice that takes on hospitality, healthcare, education or mixed-use residential work on in-scope buildings needs to read the schedule and the exclusions carefully — and, where the standard wording is restrictive, to ask the broker to source a market that responds at the full limit.
The second is the position on FF&E procurement. Where the practice procures FF&E directly, the PI policy may not respond to claims that are properly product-liability claims against the manufacturer or supplier. The line between design-advice liability (which PI covers) and procurement liability (which often needs a separate cover or contractual indemnity from the supplier) is the practical question. Where the practice's contract is structured so that the practice takes title to the FF&E, the practice may need a separate products-liability cover or specific endorsement on the PI to pick up the procurement exposure.
The third is the principal-designer endorsement. Where the practice takes on a "principal designer" role under the Building Safety Act dutyholder regime, the PI policy needs to reflect that — most standard design wordings will respond to the role provided the schedule lists it and the limit is sufficient, but some require a specific endorsement. The practical position is to flag the role at renewal and have the schedule updated.
PI does not cover deliberate breach, the practice's own bad debts, claims arising from work outside the policy retroactive date, or — in most cases — physical injury to a visitor or occupier (which sits under public liability). It does not pay regulatory fines imposed on the practice or its individual members, including any penalty imposed under the Building Safety Act regime.
The line between interior design specification risk and architectural design-and-build risk
This distinction matters because the underwriting markets, the loss profile and the regulatory framework all diverge. An architect taking on a design-and-build commission for a building has design responsibility for the structure, the envelope, the services strategy and the regulatory compliance of the whole building. An interior designer taking on a fit-out commission within that building has design responsibility for the interior package, but is working within a shell whose structural, envelope and services design were decided by others.
For most pre-Building Safety Act risk profiles, that distinction kept interior designers materially below the architect's PI exposure. The interior practice was unlikely to be a primary defendant in a claim arising from envelope failure, structural defect or services design.
The Building Safety Act has shifted this picture for in-scope work. The Act's functional definition of "designer" picks up anyone whose design decisions affect compliance with the Building Regulations, and an interior designer specifying wall and ceiling linings, fire doors, partitions and decorative elements is making decisions that affect the building's fire performance. The interior practice is not the principal designer (that is normally an architect or a specialist engineer), but it is a designer with statutory duties.
Two practical consequences follow. The first is that interior practices working on in-scope projects need to think of themselves as part of the dutyholder chain and engage with the principal designer's coordination process — providing the information the principal designer needs to discharge their statutory duties, recording the basis for fire-related specification decisions, and retaining the evidence within the project file. The second is that the practice's PI policy needs to respond to that statutory designer role. Most do, but some do not, and the schedule and exclusions are what answer the question.
The architects' PI market hardened materially after the Grenfell Tower fire in 2017, and the cladding cover position remains restrictive. Interior practices have, so far, generally not seen the same scale of hardening, but the underwriting questions have tightened: insurers now ask about HRB exposure, fire-related specification, the practice's CPD on fire safety, and the practice's process for product certification verification.
Supplier-default exposure
A specific exposure that arises on direct-procurement projects is supplier default. The interior practice specifies a product, the manufacturer warrants its performance, the product is installed, and after some time the product fails to perform as warranted. In an ideal scenario the manufacturer's warranty responds and the manufacturer remediates at its own cost. In a less ideal scenario the manufacturer has become insolvent, has withdrawn from the UK market, or contests the warranty claim — and the client looks back along the chain to the next party with the deepest pocket and the most direct contractual link, which is often the interior practice.
The PI policy will respond to allegations of negligent specification where the practice should have known about the supplier's financial position or product reliability, or where the specification itself was defective on the facts known at the time. It does not generally respond to a "pure" product-performance failure where the practice's specification was sound and the product warranty was honoured by a now-insolvent supplier. The gap between those two positions is what creates the practical exposure.
Two protective steps reduce the exposure. The first is a documented product-selection process: a record of why each product was chosen, what alternatives were considered, what certification was reviewed, and (for products with known reliability questions) what additional verification was done. The second is a clear contractual position on who carries supplier-default risk. Where the client procures directly, the supplier-default exposure sits with the client. Where the practice procures, the supplier-default exposure sits with the practice and needs to be priced into the fee or insured separately.
Fire-rating compliance specifications
Fire-performance classification is the single most-scrutinised area of interior specification in 2026 and the area where the underwriting questions have tightened most sharply.
The current UK framework distinguishes Class A1, A2, B, C, D, E and F under BS EN 13501-1 for reaction to fire, with corresponding smoke development and droplet/particle classifications. The legacy Class 0 standard under BS 476 part 6 and part 7 remains referenced in some specifications but is being progressively replaced by the EN classifications. Approved Document B of the Building Regulations sets out the specific classifications required for specific applications — internal linings on means of escape, decorative elements in common areas, ceiling treatments — and the classifications differ depending on the building's height, use and occupancy.
For an interior designer specifying these elements, the practical position is that the specification document needs to state the required classification, the manufacturer's product needs to carry certification supporting that classification, and the project file needs to retain the certification evidence. Where the specification is for an in-scope building, that file is also the evidence that supports the principal designer's coordination of the design under the Building Safety Act dutyholder regime.
The most common claim pattern is a specification that references the correct classification, but where the product as installed turns out either to lack the certification (because a substitution was made on site and not recorded, or because the supplier's certificate covers a slightly different product variant) or to fail testing under the relevant standard. The PI policy responds to negligent specification or specification advice; what it will not do is reach across the chain to recover from the contractor who made the substitution, the supplier who issued a misleading certificate or the testing house. Those recoveries are pursued separately, and the practice's PI policy may fund the practice's own contribution claim against those parties as part of the defence.
What underwriters look at for interior designers
Underwriters pricing an interior design renewal in 2026 look at the standard PI underwriting variables discussed in the pillar guide, plus several that specifically matter for the specification-risk profile.
The proportion of the practice's fees that comes from work on higher-risk buildings under the Building Safety Act, and the role the practice typically takes on those projects. A practice that is 10% HRB-adjacent is a different risk from a practice that is 60%.
The practice's process for fire-rated specification, including how the required classification is identified, how the product is selected against the classification, how certification is verified, and how substitution requests during construction are handled.
The practice's FF&E procurement model — direct procurement versus specify-and-client-procure — and the contractual position on supplier-default risk.
CPD on fire safety, building safety and the Building Safety Act dutyholder regime. Insurers are increasingly asking for evidence that the practice's senior designers have completed structured CPD on the regulatory framework.
BIID registration. Membership is taken positively. Where the practice carries out specification work on residential or mixed-use HRBs, the absence of BIID registration is sometimes flagged.
The practice's claim history specifically on specification, FF&E and supplier-default matters. A track record of resolved specification notifications is more concerning than a clean PI history overall, because specification claims tend to cluster — practices that had one usually face similar exposures on adjacent projects.
Run-off and the long liability tail
The run-off question is sharper for interior designers than for the wider design sector because of the Defective Premises Act 1972 extension under the Building Safety Act. For dwellings, the limitation period is now 30 years for completed works retrospectively and 15 years prospectively. For an interior designer whose specification on an in-scope project forms part of a defective premises claim, the practical liability tail is therefore not the standard six years but potentially fifteen or thirty.
No insurer at present writes 30-year run-off as a single product. The practical reality is that interior practices working on residential or mixed-use HRB projects need to make a conscious decision about how long they will hold run-off on closure or sale, what the contractual indemnity position is on novation if the practice is sold rather than wound down, and what the surviving principals' personal exposure looks like after the run-off period expires. Six years remains the working minimum for non-HRB work and is the floor for HRB work; longer is sometimes prudent and is the conversation we have with practices at the point of closure or sale.
Run-off is normally bought as a single up-front premium calculated as a multiple of the last working premium across the run-off period. For an interior practice with HRB exposure, the cost of run-off on closure is a real number that needs to be priced into any decision about the practice's future. We work with practices and their solicitors on the run-off question at the point of sale, merger or wind-down.
What to do next
Three immediate steps are worth taking ahead of an interior practice's next PI renewal.
First, audit the practice's project portfolio against the HRB threshold. Identify the projects where the building meets, or arguably meets, the higher-risk threshold; identify the practice's role on each; and retain evidence of the specification decisions, the certification reviewed and the coordination with the principal designer. The audit feeds into the renewal submission and into the long-term run-off decision.
Second, check the current PI policy for cladding-adjacent specification exclusions, fire-related-advice exclusions, HRB exclusions and the principal-designer endorsement (if relevant). Where the wording is restrictive, ask the broker to source a market that responds at the full limit on the work the practice actually does.
Third, look at the practice's standard contract on FF&E procurement and supplier-default risk. Where the practice takes title to FF&E, the contractual position should reflect that and the insurance should cover the procurement exposure or transfer it back to the supplier.
To talk through your practice's specification-risk position with an Apex broker, see the designers sector page or contact us. The first conversation costs nothing and does not commit you to anything.
Frequently asked questions
Does my interior design PI policy cover work on higher-risk buildings under the Building Safety Act?
Most modern design PI wordings respond to work on higher-risk buildings, but the position varies between wordings and several markets have introduced specific exclusions or sub-limits for cladding-adjacent specification, fire-related product advice and HRB work generally. The schedule and exclusions are what answer the question, not the headline wording label. Practices working on residential or mixed-use HRBs should ask the broker to confirm in writing how the policy responds to that work, and where the response is restrictive, to source a market that responds at the full limit.
Am I a "designer" under the Building Safety Act dutyholder regime if I only specify finishes?
The Act defines "designer" functionally — anyone who in the course of a business prepares or modifies designs for construction work, including specification, where those designs affect compliance with the Building Regulations. An interior designer specifying wall and ceiling linings, fire doors, partitions, decorative elements or finishes that affect the building's fire performance or other functional requirements is a designer for these purposes. The practice is not the principal designer (that is normally an architect or specialist engineer), but it is a designer with statutory duties to plan, manage and monitor its own design work and to provide the principal designer with the information needed for coordination.
How does specification risk differ between interior designers and architects?
Architects taking on design-and-build commissions have design responsibility for the structure, envelope, services strategy and overall regulatory compliance of the building. Interior designers taking on fit-out commissions have design responsibility for the interior package within a shell delivered by others. For most pre-Building Safety Act work, that distinction kept interior designers materially below the architect's PI exposure. The Act has narrowed the gap for in-scope projects because the functional definition of "designer" picks up specification decisions that affect fire performance, but interior designers remain a different underwriting profile from architects and the markets that respond differ.
Does PI cover the cost of replacing FF&E that has failed in use?
PI responds to allegations of negligent specification — the design advice that led to the product selection. It does not generally respond to "pure" product-performance failures where the specification was sound and the product warranty has been honoured by the supplier. The position becomes more complicated where the supplier has become insolvent or contests the warranty, leaving the client looking back along the chain. Practices that procure FF&E directly may need a separate products-liability cover or specific endorsement to address the procurement exposure.
How long should an interior practice hold run-off cover after closure?
Six years is the working minimum for most interior work, in line with the standard contractual limitation period under English law. Practices that have done work on dwellings within higher-risk buildings should think significantly longer because of the extended Defective Premises Act limitation period — fifteen years for new works, thirty years retrospectively for completed dwellings — and should make a deliberate decision about how long they will hold run-off and what the contractual indemnity position will be on sale or merger. No insurer at present writes 30-year run-off as a single product.
What about cladding-adjacent specification — is it covered?
Cover for cladding-adjacent specification varies sharply between wordings and has been the subject of the post-Grenfell hardening that began in the architects' PI market and has spread to some interior wordings. Some policies respond at the full limit, others apply specific exclusions or sub-limits. Practices whose specification work touches external wall systems, fire-rated linings adjacent to escape routes or other cladding-related elements should ask the broker to confirm in writing how the policy responds, and where the response is restrictive, to source an alternative market.
Do I need separate cover if my practice procures FF&E directly for clients?
It depends on the policy wording and the contractual structure. Where the practice procures FF&E directly — placing orders, taking title, managing delivery and installation — the PI policy may not respond to claims that are properly product-liability claims against the manufacturer or supplier. Some practices address this with a separate products-liability cover; others with a specific endorsement on the PI; others by restructuring the contract so the client procures directly and the practice's role stays advisory. The choice depends on the practice's commercial model and is one we work through with practices at renewal.
Related guides
- Designers PI insurance UK guide 2026
- Graphic designer IP infringement claims
- Designers sector page — speak to a broker
About Apex Insurance Brokers — Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority, FCA firm reference 724952. Registered in England and Wales, Companies House 07014570. Last reviewed: May 2026.
This guide is general information about Professional Indemnity Insurance for UK interior designers and is not advice tailored to any individual firm's circumstances. For advice on your own renewal please speak to a broker — contact@apexinsurancebrokers.co.uk or 0117 325 0027.
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