You are the Client. That is now a legal role with legal duties.
Appoint a contractor, sign off a quote, ask for the work to start — and from 1 July 2026 in Wales, you have just stepped into a statutory role. The Client is one of five named dutyholders under the reformed Building Regulations, and being the Client is no longer a matter of who pays the invoice. It is a defined legal position with obligations you can be held to account for.
This catches a lot of building owners and estates managers off guard. They assume the responsibility for compliance sits with the people doing the work. It sits with you as well. And the reforms make that explicit.
The five dutyholders, and where you fit
The Welsh reforms mirror the structure already in place in England. Every project subject to Building Regulations now has statutory dutyholders: the Client, the Designer, the Principal Designer, the Contractor and the Principal Contractor. Each has defined responsibilities. Each must cooperate with the others. Each must ensure the work complies.
If you commission the work, you are the Client. Your core duty is to make suitable arrangements for the project to comply with Building Regulations — and that includes appointing people who are actually competent to do it. Where there is more than one designer or more than one contractor, you must appoint a Principal Designer and a Principal Contractor to coordinate the work. If you do not make that appointment, the law treats you as holding those roles yourself. That is not a position you want to be in.
Competence now has to be evidenced, not assumed
Here is the change that matters most in practice. Before, a firm turned up with the right van, the right accreditation logos on the website, and a confident manner, and that was broadly taken as competence. After 1 July 2026, competence has to be demonstrable.
A company you appoint must be able to show its skills, knowledge, experience and behaviours; its quality management systems; its training and CPD records; its relevant project experience; and its supervision and management arrangements. If they cannot produce that evidence, the reforms expect you — as the Client — to have checked before you appointed them.
For fire-safety work specifically, this bites hard. Fire stopping, fire door installation, fire damper testing and ductwork hygiene are exactly the disciplines where poor competence stays invisible until there is a fire. A penetration seal that looks tidy but uses the wrong product for the substrate will pass a glance and fail a fire. Asking for evidence of competence is now how you protect yourself, not just the building.
A scenario worth recognising
Consider a housing association carrying out a compartmentation upgrade across a block of flats — sealing service penetrations, replacing flat entrance doors, servicing the fire dampers in the communal risers. Straightforward passive fire protection work.
Under the old regime, the association would engage a contractor, the work would happen, and the paperwork would be whatever the contractor chose to hand over. Under the reformed regulations, the association is the Client. It must satisfy itself that the contractor is competent before appointment. It must ensure a Principal Contractor is named if more than one firm is on site. And it must ensure the Golden Thread information — product data sheets, installation records, commissioning results, fire stopping records, inspection and test results — is captured and handed over as the work proceeds, not scrambled together at the end.
If a Compliance Notice or Stop Notice later lands, the association's defence is that documented evidence. If it does not exist, there is no defence.
What to do before the deadline
Start with a simple audit of how you appoint people. Write down what you ask a contractor to prove before you engage them for fire-safety work, and be honest about whether "they've done our buildings for years" is the whole of your assurance. It will not be enough after July 2026.
Build competence checks into your procurement. Ask for the evidence — quality systems, relevant project experience, training records, third-party certification where it applies — and keep it on file. Decide, at the outset of any project, who your Principal Designer and Principal Contractor are, and appoint them in writing.
And specify the records you expect at handover before the work begins. Product information, commissioning records, inspection and testing results, fire stopping records and O&M manuals are not optional extras; they are part of the Golden Thread and, increasingly, part of your legal audit trail.
The reforms are not asking you to become an engineer. They are asking you to prove you appointed competent people and kept the evidence. That is a habit worth forming now, well before the deadline arrives.