The competence regime: PAS 8671, 8672, 8673 and the declarations that bite

Why does the Act care about competence?

Because Hackitt found an industry where responsibility was diffuse and capability was assumed rather than demonstrated. The answer, in force since 1 October 2023 through Part 2A of the Building Regulations, makes competence a legal duty attached to every dutyholder role: no person should appoint anyone to design or build work unless satisfied they are competent, and no one should accept an appointment they are not competent to hold.

The test is deliberately plain: skills, knowledge, experience and behaviours for individuals, organisational capability for companies. The behaviours limb deserves the attention it rarely gets, because it is where the regime encodes culture: an engineer with impeccable qualifications who signs what the programme needs rather than what the evidence supports fails the behaviours test.

What do the PAS specifications actually do?

The Act sets the duty; the PAS documents describe the benchmark. PAS 8671 specifies competence for principal designers discharging the Part 2A design duty, PAS 8672 does the same for principal contractors, and PAS 8673 covers building safety management in occupation. They translate "competent" into assessable terms: what a principal designer for a higher-risk building should know about fire safety in design, regulatory process and information management, and what behaviours evidence it.

Two practical notes. The specifications are BSI publications, so we describe them and link to the source rather than reproduce them. And they are benchmarks, not certificates: a PAS-aligned assessment is strong evidence of competence, but the legal duty stays with the appointer to be satisfied and the appointee to be honest, project by project.

Where does competence bite in the gateway process?

At Gateway 2, in writing. The application includes competence declarations, and the client signs a statement confirming its arrangements. The BSR's validation process checks that the declarations exist and cover the dutyholders actually appointed, and gaps here are among the recurring validation failures that bounce applications before assessment even starts.

It bites again at the end: the compliance declarations the principal designer and principal contractor sign at Gateway 3 are competence's final exam, a personal statement that the building complies, resting on the evidence the project kept. Organisations that treat competence as a procurement questionnaire discover at completion that it was always a delivery discipline.

What should organisations do about it?

Map appointments against the PAS benchmarks honestly, including your own; keep competence records per role and per project, because "satisfied of competence" is a judgement you may need to evidence; match the assessment to the building, since HRB competence is a higher bar; and fund the behaviours: reporting lines that let engineers say no, time for the checking the declarations assume, and records discipline that makes signatures safe to give. Competence in this regime is not who you hired; it is what your project can prove.