The word that changes what you have to check
A contractor tells you they have been fitting fire stopping for twenty years. Since 1 July 2026 in Wales, that sentence is no longer enough. The reforms to the Building Regulations turn competence from something you assume into something you must be able to evidence — and if you are the client on a project, part of that burden sits with you.
This matters to building owners, responsible persons and estates managers because the reforms do not only apply to high-rise. They apply to all building work subject to the Building Regulations, with additional requirements layered on top for Higher-Risk Buildings. If you are refurbishing a communal corridor, replacing fire doors, or having fire dampers reinstated after ductwork cleaning, you are affected.
What "competence" actually means now
Under the new framework, a company carrying out or overseeing building work must be able to demonstrate five things:
- Skills, knowledge, experience and behaviours
- Quality management systems
- Training and continuing professional development
- Relevant project experience
- Appropriate supervision and management
Read that list again as a client, not an engineer. It tells you exactly what to ask for before you appoint anyone. It is no longer acceptable to take a firm's word for it. The expectation is that competence is evidenced, on paper, before work starts — and that the evidence is kept.
Where the duty lands on you
The reforms create statutory dutyholders with defined legal responsibilities: Client, Designer, Principal Designer, Contractor and Principal Contractor. Most building owners will sit in the Client role, and being the Client is not a matter of who pays the invoice. If you commission the work, it is you.
Where more than one designer or contractor is involved, the Client must appoint a Principal Designer and a Principal Contractor. If you do not, the regulations make you responsible for their duties yourself until you do. That is not a position you want to be in.
As Client, you are not expected to inspect fire stopping yourself or read a damper drop-test result. But you are expected to take reasonable steps to satisfy yourself that the people you appoint are competent, that they will cooperate with each other, and that the arrangements for the project support compliance. If you appoint the cheapest firm without checking any of the five competence elements, and the work fails, "I didn't know" is no longer a defence the law leaves open to you.
A scenario you will recognise
An estates manager for a care home group needs fire dampers tested and any failures reinstated across three sites in South Wales. She goes to tender in autumn 2026. Two firms respond.
The first quotes low, provides a one-page method statement, and cannot produce evidence of training records or a quality management system when asked. The second provides CPD records for its engineers, a clear inspection and testing procedure, examples of comparable care-home projects, and confirms how supervision works on site.
Under the old regime, price might have won. Under the new one, the estates manager has a documented reason to choose the second firm — and, just as importantly, she has a file showing she carried out her Client duty to check competence. If a regulator ever asks how she assured herself the work was done by capable people, she can answer with paper, not a shrug.
That file is not bureaucracy for its own sake. It is the thing that protects her, and the organisation, if something goes wrong.
The evidence you should now expect to receive
The reforms place far greater weight on record keeping, and fire-safety work sits right in the middle of it. When passive fire protection work is completed, expect — and insist on — documentation that includes:
- Product information for the materials used
- Commissioning records
- Inspection and testing results, including damper drop-test data
- Fire stopping records, ideally photographic and location-referenced
- Updated O&M manuals
- Handover documentation
For Higher-Risk Buildings — broadly, those 18m or more, or seven storeys and above, containing residential accommodation, hospitals, care homes or children's homes — this feeds the Golden Thread of building safety information that must be maintained through the building's life. But even outside HRBs, this documentation is now the evidence that lets you demonstrate compliance if a local authority comes asking.
Why the enforcement change makes this urgent
Local authorities now hold stronger powers: Compliance Notices, Stop Notices and prosecution. A Stop Notice can halt work on site. The practical consequence is simple — being able to prove compliance through documented evidence is no longer an administrative nicety. It is the difference between a project that proceeds and one that gets frozen mid-way.
What to do now
Start now. Review your framework contractors and ask each one to demonstrate the five competence elements in writing. Build a standard set of questions into your tender process, including third-party certification and its scope where it applies. Decide where you will store the completion records, commissioning data and O&M updates so they are retrievable, not lost in an inbox. Specify the records you expect at handover before the work begins, not at the end. And check which of your live projects the new rules apply to. They do not apply to building work that started before 1 July 2026, or where plans were deposited or a building notice was given before that date. That protection falls away if deposited plans are rejected on or after 1 July 2026, and deposited plans can still lapse under the existing three-year rule if work has not started. Confirm with your building control body rather than assuming.
Competence has always mattered. Since 1 July 2026, in Wales, you have to be able to prove it.