The UK Building Safety Act: What Roofing Contractors Need to Know for 2026

The Building Safety Act 2022 is the most significant piece of construction legislation passed in England in a generation. Introduced in the wake of the Grenfell Tower tragedy, its purpose is to raise safety standards, establish clear accountability across the construction supply chain, and ensure that everyone involved in building work — from the client to the subcontractor — is demonstrably competent to do what they are being paid to do.

Many UK roofing contractors are still operating on the assumption that the Act only affects those working on high-rise residential buildings. This is a dangerous misconception. The dutyholder and competency regime introduced by the Building Regulations etc. (Amendment) (England) Regulations 2023 applies to all regulated building work in England — including standard residential roof repairs and replacements. And 2026 brings further significant changes that make compliance more urgent, not less.

This guide explains what the Act requires of roofing contractors in plain terms, what the consequences of non-compliance are, and what practical steps you should be taking now.

What Is the Building Safety Act and Why Does It Matter for Roofers?

The Building Safety Act 2022 was passed following the Grenfell Tower fire of 2017, which killed 72 people and exposed fundamental failures in the UK's building safety system — failures that went far beyond cladding to include how accountability was allocated across the construction supply chain, how building work was overseen, and how competence was defined and demonstrated.

The Act's secondary legislation — particularly the Building Regulations etc. (Amendment) (England) Regulations 2023 — created a new Part 2A in the Building Regulations 2010. This Part introduces what is known as the dutyholder and competency regime. It came into force on 1 October 2023 and became fully operational, with transitional arrangements ended, on 6 April 2024.

For roofing contractors, the regime matters for three reasons. First, it establishes for the first time that you are legally a dutyholder on any project involving notifiable building work — with specific duties that are separate from and additional to those you already hold under the CDM Regulations 2015. Second, it requires you to be able to demonstrate competence in a structured way — not just assert that you do good work. Third, failure to comply can now result in criminal liability, unlimited fines, and up to two years' imprisonment for individuals.

Key Changes and Dates for 2026

The Act has been rolling out progressively since 2022. These are the most significant developments arriving or taking effect in 2026 that directly affect UK roofing contractors.

The Dutyholder Regime — What It Means for You Specifically

The core of the Building Safety Act's relevance to roofing contractors is the dutyholder regime. Part 2A of the Building Regulations creates five dutyholder roles. Understanding which one you occupy on any given project determines what your legal obligations are.

What "Competence" Means Under the Act — and How to Demonstrate It

The word "competence" appears throughout the Building Safety Act, but for a long time it was not clearly defined. The Act's secondary legislation and supporting publicly available standards (PAS) have since clarified what competence means in practice for contractors.

Competence under the BSA has two dimensions:

• Individual competence — the skills, knowledge, experience, and behaviours of the people actually carrying out the work. This means qualifications (NVQs or equivalent), relevant trade experience, and familiarity with the specific requirements of the job type. For roofing specifically, membership of the NFRC's Competent Person Scheme or the Competent Roofer Scheme are well-established routes to demonstrating individual competence.
• Organisational capability — the management policies, procedures, systems, and resources your business has in place to ensure Building Regulations compliance. This is not just about what you personally know — it includes how your business plans work, monitors quality, keeps records, and coordinates with other parties on projects.

The key practical implication is that competence cannot simply be asserted — it must be capable of being demonstrated on a project-by-project basis if required. This means keeping records of qualifications, accreditations, relevant experience, and the policies and procedures your business follows to ensure compliant work.

The four behavioural pillars

PAS 8672 (the publicly available standard for Principal Contractors) and PAS 8670 (core principles of competence) identify four behavioural pillars that underpin competence under the Act. While these documents are primarily aimed at principal contractors, the behavioural framework applies to all dutyholders:

1. Respect for life — actively prioritising the safety of building users and the public above commercial considerations
2. Respect for the law — knowing and complying with all relevant regulatory requirements, not just the minimum
3. Respect for the environment — considering the broader environmental impact of construction work and the materials used
4. Respect for the public good — cooperating openly with other dutyholders, sharing relevant information, and supporting the overall objective of building safety

Which Approved Documents Apply to Roofing Work

The Building Regulations Approved Documents are the guidance documents that explain how to comply with specific parts of the Building Regulations. Several are directly relevant to roofing work and must be understood and applied on notifiable projects.

The Building Regulations Compliance Certificate — and Why It Matters

A Building Regulations Compliance Certificate (BRCC) is an official document confirming that roofing work is compliant with UK Building Regulations. It is issued when a thermal element — such as the roof covering — is being renovated and must be upgraded to current energy efficiency standards.

BRCCs matter for three reasons that roofing contractors are often unaware of:

• Property sales can be blocked without them. A homeowner whose roof was replaced without the relevant BRCC may be unable to sell their property, or may face delays while remedial documentation is produced. This creates liability exposure for the contractor who completed the work without notification.
• Home insurance can be invalidated. Work completed without compliance certificates can invalidate a homeowner's building insurance policy, particularly for the roof — the most critical weather protection element of any property.
• Non-notification is already a criminal offence. Carrying out notifiable roofing work without informing building control or self-certifying through a competent person scheme is a breach of the Building Regulations. The Building Safety Act has significantly strengthened enforcement powers in this area.

The Penalties for Non-Compliance

The Building Safety Act significantly strengthened the enforcement regime that previously applied under the Building Regulations. Non-compliance is no longer a matter of civil liability only.

What Roofing Contractors Should Be Doing Right Now

Based on the requirements now in force, here is the practical compliance checklist for every UK roofing contractor operating in England.

• Join or renew your NFRC Competent Person Scheme registration. The CPS is the most straightforward way to demonstrate competence as a roofing contractor, self-certify eligible works, and issue BRCCs to clients. It directly evidences your compliance with Part 2A's competency requirements. Registration details: nfrccps.com.
• Document your individual and organisational competence. Keep records of all qualifications (NVQs, trade cards), relevant accreditations (CHAS, Safe Contractor, NFRC), and evidence of experience relevant to the specific types of work you carry out. Create or update a simple written policy document explaining how your business plans, monitors, and records building work compliance.
• Understand your dutyholder role on every project. Before starting any notifiable job, establish: who is the client, who is the principal designer (if applicable), and whether you are acting as Contractor or Principal Contractor. Your duties differ depending on the answer.
• Notify building control or self-certify before starting notifiable work. Any roof replacement covering more than 25% of the roof area, or any roofing work involving structural elements, triggers building control notification requirements. Notify your local authority building control or self-certify through the NFRC CPS before work begins — not after.
• Verify material compliance before specifying. All materials used on notifiable projects should comply with the relevant British Standards and, for fire-sensitive applications, carry appropriate BBA certification and fire classification data. Keep supplier compliance documentation in your project records.
• Issue BRCCs to every client who is entitled to one. Most homeowners whose roof is being replaced under Part L do not know they are entitled to a BRCC and may not realise they need one for a future property sale. Make issuing the BRCC a standard part of your job completion process — the same as invoicing.
• Keep project records for every notifiable job. Records should include: scope of work, materials used (with compliance data), photos of key stages, date of notification or self-certification, and the BRCC reference. The NFRC CPS portal provides a records management system for registered members.
• Ensure your workers are also competent. The Contractor's duty under Part 2A requires that all workers under your control are given appropriate supervision and instruction. You cannot simply self-certify your own competence and then direct unqualified labourers. Each person on site should be able to demonstrate relevant competence for the work they are carrying out.

How This Affects Your Commercial Positioning

There is a business case for proactive compliance that goes beyond simply avoiding prosecution. Commercial clients — property management companies, facilities managers, housing associations, and main contractors — are increasingly required to verify the competence of their supply chain as part of their own dutyholder obligations. A roofing contractor who cannot demonstrate NFRC CPS membership, organised project records, and a clear compliance process is increasingly likely to be excluded from approved contractor lists, particularly for public sector and housing association work.

Conversely, contractors who can present clear compliance documentation — a membership certificate, a sample BRCC, an explanation of their project record-keeping process — are differentiating themselves from the majority of the market. In a sector where most competitors have little awareness of the BSA's application to their work, demonstrated compliance is becoming a meaningful competitive advantage, particularly in the commercial and FM market.

"Anyone who thinks the Building Safety Act only applies to high-rise buildings needs to read the regulations and urgently reconsider their view." — CIBSE, on the dutyholder and competence regime

Scotland, Wales, and Northern Ireland

The Building Safety Act 2022 and the Building Regulations etc. (Amendment) (England) Regulations 2023 apply in England only. Scotland, Wales, and Northern Ireland each have their own building regulations frameworks:

• Scotland — building regulations are managed by the Scottish Government under the Building (Scotland) Regulations 2004. Scotland has its own competency and verification requirements separate from the BSA regime.
• Wales — Wales is implementing the Grenfell recommendations through its own framework. While some Building Safety Act provisions apply in Wales, the specific dutyholder and competency regime under Part 2A currently applies in England only. Welsh contractors should monitor Welsh Government guidance.
• Northern Ireland — operates under the Building Regulations (Northern Ireland) 2012 and is not subject to the BSA dutyholder regime.

Frequently Asked Questions

Where to Get Further Guidance

The following official and industry sources provide reliable, up-to-date guidance on Building Safety Act compliance for roofing contractors:

• NFRC Competent Person Scheme — nfrccps.com — the primary accreditation route for UK roofers, including self-certification, BRCC issuance, and record-keeping support
• Building Safety Regulator — hse.gov.uk/building-safety — official regulator guidance on the Act and HRB regime
• DLUHC Building Safety guidance — gov.uk/guidance/building-safety-act-2022 — government guidance on the dutyholder and competency regime
• CIBSE guidance on dutyholder and competence regulations — detailed technical explanation of Part 2A requirements
• PAS 8670 and PAS 8672 — available via BSI — core principles of competence and competency requirements for principal contractors

For contractors working on commercial or higher-risk projects, independent legal advice from a solicitor with construction law experience is strongly recommended before taking on principal contractor duties on any complex project.

For advice on how compliance and accreditation can strengthen your commercial positioning — particularly for commercial roofing contracts — read our guide to getting commercial roofing contracts by targeting property managers and FM companies.