Scotland is carving out its own pathway to improving the post-Grenfell building safety space, with a new approach and new role, explains APS chief executive Andrew Leslie
The compliance plan manager (CPM) role in Scotland is a newly proposed position designed to strengthen building standards for high-risk buildings (HRBs) initially, with voluntary adoption of the approach starting from March 2026.
In response to critical safety failures such as the Grenfell Tower fire and structural issues in Edinburgh schools, the Scottish government initiated a new approach to compliance – one that can be scaled up or down and is appropriate for all types of work that need a building warrant.
This led to the creation of the compliance plan approach (CPA), a quality assurance system aimed at improving transparency and accountability in projects and delivering compliant buildings – initially focused on HRBs. (In Scotland these are residential buildings with any storey over 11 metres, and include public, community, health and residential care buildings, regardless of storey height.) Over time, this approach is expected to be applied to all building warrants.
Central to this is the new role of compliance plan manager (CPM), alongside two existing roles – the relevant person and local authority building control (BC) verifier.
The CPM, which is yet to be enshrined in primary legislation, will be responsible for developing and managing compliance plans (CPs) for HRBs, ensuring the work delivered aligns with approved building warrant plans and complies with the Scottish building standards established under the Building (Scotland) Act 2003.
The CPM will record the planned measures taken to assure compliance then record whether these have been carried out, oversee the collection of evidence, ensure inspections are properly conducted and recorded, and liaise with relevant professionals to maintain compliance. They will be responsible for making sure the CP is completed. The role is not limited to a single profession but intended to coordinate across disciplines, promoting safety through good design and rigorous documentation.
Questions remain
Some questions about the role remain. Who does the CPM report to? What are the criteria to become a CPM? Will it be a role protected by statute as an independent function?
APS anticipates the role to translate in practice as a combination of PD and PC as known in England and Wales (and possibly a bit of clerk of works) – focusing on compliance and continuity between the design and construction phase, orientating around coordination, oversight, verification and information management.
In terms of competence, despite it being a managerial role, this would start to translate towards requiring a demonstration of breadth and depth of knowledge in potentially quite specialist areas of design and construction, including knowledge and application of the building regulations, contractual and technical competences, as well as an extensive suite of pre-requisite requirements spanning essential and desirable experience. Membership of a relevant professional body is currently seen as an important pre-requisite.
APS believes the CPM role should be focused across key elements of building safety and health and not necessarily across all elements of compliance with the building standards, with the wider role being the responsibility of the BC verifiers. Close liaison between the CPM and BC verifiers will be required as far as signing off key elements is concerned.
What is certain is that anyone doing the CPM role will want to make sure they feel confident about signing the compliance declaration on the completion certificate submission, confirming that the building complies with the building regulations.
Supporting tools
The CPM role is supported by tools such as the Construction Compliance and Notification Plan (CCNP – issued by the local authority with a building warrant) and the proposed Compliance Handbook, which will provide guidance for implementation of the role.
By the end of December 2025, CPA guidance will be published for industry to voluntarily adopt – including the steps expected of a CPM – before it becomes a statutory requirement to work with all parties to propose, then monitor, the CP. Verifiers’ guidance will also be published to support the implementation of phase 1 of the CPA.
The publication of revised national guidance in advance of a legislative change, anticipated in the next legislative term, is part of the Scottish government’s response to the Grenfell Inquiry Phase 2 recommendations. The Scottish government hopes this allows it to follow a recognised change curve and move from early adopters to an early majority before legislative change requires it.
