The Dutyholder Role defined

Ask a room full of construction project teams who the dutyholders are, and more often than not you’ll get reasonably confident answers.

Ask the same room who is responsible for compliance evidence at any particular part of the project, and the response in many cases will be much less confident.

That uncertainty is where problems can start. Dutyholder roles aren’t new. What has changed, however, is how visible and accountable they’ve become. The Regulator now expects roles to be clear, competence to be demonstrable, and responsibilities to be owned in practice, not just named in a contract.

What “dutyholder” actually means on a live project

A dutyholder isn’t just a title. It’s an ACTIVE role with LEGAL RESPONSIBILITIES attached. In the building safety context, “dutyholder” refers to those with legal duties under Building Regulations and the Building Safety Act, such as clients, principal designers and principal contractors.

Being appointed is one thing. Acting in that role, day to day, is another. Regulators are really only bothered about the second part. Who coordinated design compliance? Who checked information? Who challenged any changes that were made?

If the answer is vague or uncertain, then the risk sits with the project.

The core roles, and where things usually unravel

At a high level, most teams can list the roles needed. Client. Principal Designer. Principal Contractor. Designers. Contractors.

The problems arise appear at the interfaces, or where delivery elements overlap. For instance, design responsibility ‘assumed to sit with someone else’. Evidence expected to “come through later.” Changes made on site without structured sign-off. Or worse, two people each thinking the other has it covered.

One of the most common points of confusion is between the Building Regulations Principal Designer role and the CDM Principal Designer role. They are not the same. (The BRPD has duties focused on compliance with Building Regulations, whereas the CDM PD duties relate to managing and coordinating health and safety during the pre‑construction phase; these roles can be held by the same organisation but are legally distinct.) Assuming they are interchangeable or treating them as such creates blind spots that nobody notices until problems occur.

Familiar confusion patterns (you may have seen some of these)

• The client appoints, then steps back completely
• The Principal Designer coordinates design, but not compliance evidence
• Contractors make changes that never quite make it back into records
• Everyone assumes someone else is tracking competence declarations

None of the above comes from bad intent. It comes from general project pressure, pace of delivery, and unclear boundaries.

The cost of unclear roles

Role confusion doesn’t just create admin headaches, it creates project or programme risk, resulting in Gateway delays, requests for further information, rework, disputes about who owned what, and when, gaps in the Golden Thread that are hard to stitch back together.

It also puts individuals in exposed positions. Being named as a dutyholder without the support or authority to act properly is not a great place to be by any means.

A practical way to bring clarity back

This doesn’t need a complex framework.

A one-page responsibility matrix aligned to project stages helps more than a thick manual. Clear statements of who produces, who reviews, and who signs off key compliance information. Regular checkpoints at design freeze, pre-start, and handover.

Competence evidence should be asked for early, not chased at the end and when roles change, records should change too. It sounds obvious, but is often skipped.

How enevo supports dutyholders

Through expert BRPD and dutyholder support, Building Regulations Principal Designer services, and Building Safety Act client advisory, enevo is able to help teams understand their responsibilities and meet them confidently. ​

For projects where CDM and Building Regulations roles risk being confused, our CDM Principal Designer and advisory services can help keep duties distinct and defensible.

For higher-risk buildings, dedicated HRB support brings additional structure where scrutiny is highest, with additional obligations and oversight by the Building Safety Regulator.​

Clarity as a form of safety

Dutyholder roles are about accountability that works under pressure.

When everyone knows what they’re responsible for, decisions are faster, records are stronger, and safety conversations become more honest. It’s not bureaucracy, but rather sensible risk control.

If you want support clarifying dutyholder roles, strengthening compliance evidence, or reducing risk across your project, enevo Building Safety can help you put the right structure in place from the outset, just give us a call to see what’s possible.