Principal designer insurance: cover for the dutyholder role

Two roles, one name

The Construction (Design and Management) Regulations 2015 created a principal designer responsible for planning, managing and monitoring health and safety in the pre-construction phase of a project. That role has existed for a decade and most practices understand it.

The Building Regulations etc. (Amendment) (England) Regulations 2023 created a separate principal designer under the Building Regulations, in force from 1 October 2023, with transitional arrangements ending on 6 April 2024. This role is concerned with planning, managing and monitoring the design work so that, if built as designed, the project would be compliant with the Building Regulations. It applies to projects generally, not only to higher-risk buildings.

The same organisation or individual can hold both roles, provided it has the competence for each, and in many practices it does. But they are distinct appointments with distinct duties, and the competence required for one does not establish competence for the other.

This is worth labouring because the confusion is genuinely costly. A practice that believes its long-standing CDM appointment letter also covers it for the Building Regulations role has misunderstood what it has agreed to do, and a practice that describes its role loosely on a proposal form may find its PI underwriter has priced something different from what it is actually doing.

What the Building Regulations role commits you to

In broad terms, the Building Regulations principal designer plans, manages and monitors the design work during the design phase, coordinates matters relating to the design so far as they affect compliance, cooperates with the client and the principal contractor, and takes reasonable steps to ensure that designers under its control fulfil their duties. There is also an underlying competence requirement: the role should not be accepted without the skills, knowledge, experience and, for organisations, the organisational capability to carry it out.

That is a description of the shape of the role, not a compliance checklist — for that, take specialist advice or work from the statutory guidance. The insurance point is what it implies: the role is a coordinating and monitoring responsibility across other people’s design work. It widens the range of things a practice can be blamed for, beyond the drawings it produced itself.

That widening is what an underwriter is pricing.

What taking the role does to your PI risk profile

Three effects matter.

Scope creep into other people’s work. A designer is answerable for its own design. A principal designer under the Building Regulations has responsibilities relating to the coordination of design across the project. When something goes wrong in a specialist package, the question of what the principal designer should have picked up is now a live one.

A documented chain of responsibility. The regime is built around formal appointment and record-keeping. That cuts both ways: it evidences what you did, and it evidences what you were supposed to do. Practices that keep good records tend to benefit; practices that do not, do not.

Competence exposure. Accepting a dutyholder role you are not competent to perform is a problem in itself, quite apart from any defect. Underwriters ask how the practice assesses its own competence for the role, and a clear answer is a genuine differentiator.

Set against that, the honest counterpoint: the role also generates discipline. Formal appointments, design review, coordination records and sign-off gates are things underwriters like. A practice that takes the role seriously and can show it is often a better risk than one that avoids the role but runs loose processes.

Insurance questions worth settling before you accept the appointment

Does your professional indemnity policy respond to your activities as principal designer under the Building Regulations, and is that reflected in how your business activities are described in the policy schedule? A policy written for architectural services is not automatically written for a statutory coordination role, and the description matters.

Is your limit of indemnity appropriate for the projects on which you are taking the role, rather than for your fee income generally? Is the limit each and every claim or in the aggregate, and are defence costs inside or outside it? Does the appointment impose a specific limit and a period after completion for which cover must be maintained, and can you actually meet that for the required period given the claims-made structure of PI?

And if the project is a higher-risk building, does the policy carry restrictions — fire safety, cladding, external wall systems, or building height conditions — that bite on exactly the work you are being appointed to coordinate? That question is dealt with on our page on fire safety and cladding exclusions.

Getting the cover right

Principal designer insurance is not a separate product. It is professional indemnity insurance arranged with the role properly described, the limit set against the projects rather than the fees, the wording checked for restrictions that would undercut the role, and public liability and other covers sitting sensibly alongside it.

The practices that get this right tend to be the ones that had the conversation before signing the appointment rather than after. If you are being asked to take the role — or you have taken it and never told your insurer — that is the conversation to have now.

Frequently asked questions

Is the Building Regulations principal designer the same as the CDM principal designer?

No. The CDM 2015 principal designer is a health and safety role covering the pre-construction phase. The Building Regulations principal designer, in force from 1 October 2023 with transition ending 6 April 2024, is concerned with planning, managing and monitoring design work for Building Regulations compliance. One organisation can hold both roles if competent for each, but they are distinct appointments.

Do I need special insurance to act as principal designer?

Not a separate product, but your professional indemnity policy needs to be arranged with the role in mind: the activity properly described in the schedule, a limit set against the projects you take it on, and the wording checked for restrictions that would bite on the work. Tell your broker before you accept the appointment rather than at the next renewal.

Does the Building Regulations principal designer role apply only to higher-risk buildings?

No. The dutyholder roles introduced by the Building Regulations etc. (Amendment) (England) Regulations 2023 apply to projects generally, not only to higher-risk buildings. Higher-risk buildings sit within an additional and more onerous building control regime on top of that.

What limit of indemnity should a principal designer carry?

There is no single figure. The sensible approach is to set it against the value and risk of the projects on which you take the role and the requirements written into your appointments, rather than against your fee income. Check too whether the limit is each and every claim or aggregate, and whether defence costs sit inside or outside it.

This page is insurance information for UK businesses, not legal or regulatory advice. It describes how the Building Safety Act landscape is affecting professional indemnity cover and what underwriters are asking; it does not tell you how to comply with the legislation. For advice on your duties under the Act, take specialist legal advice. Position stated as at August 2026.

Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority (FRN 724952). This page is general information, not advice on a specific policy.