Every AEC professional indemnity policy written in the UK today is priced on assumptions about competence governance that cannot be verified at underwriting. Practices declare their staff are qualified. They submit professional body membership lists. They confirm CPD requirements are met. What none of this answers — and what the post-Grenfell regulatory framework now makes explicit — is whether the practice has systems to ensure competent people are assigned to competent decisions, and whether their CPD is evaluated for effectiveness. The Building Safety Act 2022 and the ITFG guidance (May 2026) draw a formal distinction between individual competence and organisational management of competence. The latter is where liability exposure concentrates. Until there is infrastructure to evidence it, it cannot be priced.
The liability gap the post-Grenfell framework creates.
The Grenfell Tower Inquiry’s Phase 2 findings established that specification and product knowledge failures in AEC are not only individual failures — they are systemic failures, rooted in organisations that lacked processes for ensuring competent assignment, adequate supervision, and evaluated professional development. The Building Safety Act 2022 responded by placing organisational competence obligations on dutyholders: principal designers, principal contractors, and building owners. The ITFG guidance (May 2026) extends this framework to every AEC practice through a competence management cycle requiring documented, evaluated, systematic CPD governance. The exposure this creates for PI underwriters is specific: a practice that cannot demonstrate organisational competence management is in a weaker position in any subsequent claim, regardless of how individually qualified its practitioners are. Individual qualifications are a necessary but not sufficient defence. Organisational governance documentation is what demonstrates the practice met its duty of care at a systems level — and most practices currently cannot produce it. Their CPD evidence is individual hours logs: no team-level competence mapping, no documented evaluation of whether CPD produced practice change, no board-level accountability statement. From a PI risk perspective, this is not a minor gap. It is the absence of the documentation that demonstrates systematic competence management.
What robust CPD governance evidence looks like.
The ITFG guidance’s Plan–Do–Check–Act framework maps directly onto the kind of documented management cycle that loss adjusters and regulators look for. A practice with adequate CPD governance can produce, on request: a documented CPD policy linked to role-specific competence criteria; a team-level record of CPD activity and its evaluated outcomes — aggregated evidence of what the team attended and what changed as a result, not individual hours per person; a Realisation Rate, the percentage of CPD sessions for which the team has confirmed application to practice at 30 and 90 days; and a named board-level accountability statement confirming the above governance is in place and maintained. The difference between a practice that can produce these four items and one that cannot is not cosmetic in a PI investigation. It is the difference between demonstrating a governed system and asserting that one existed.
The question to add to PI renewal conversations.
The Grenfell Inquiry and the regulatory framework that followed have made it possible, for the first time, to ask a specific question of AEC practices at renewal: not “are your staff qualified?” but “can you demonstrate that your CPD system evaluates whether training produces measurable practice change?” The first question has always been answerable. The second, until recently, had no answer, because no infrastructure existed to capture it. That infrastructure now exists. A practice using structured CPD outcome tracking can export a team-level evidence report showing hours, disciplines, intent signals, and application rates — the documented CPD governance evidence the ITFG framework asks for, and that PI investigations examine. Underwriters and brokers who begin asking for this documentation are not creating additional burden. They are incentivising practices to close a governance gap the post-Grenfell regulatory framework has already identified.
The pricing gap this leaves open, for now.
The pricing of AEC PI policies has not yet caught up with the governance framework the Building Safety Act created. When it does, practices with documented CPD governance will be in a materially stronger position than those that cannot produce it. The infrastructure to generate that documentation exists now. The question is whether underwriters begin asking for it before or after the next major claim.
FAQs
Under the ITFG guidance on Managing Competence in the Built Environment (May 2026) and the Building Safety Act 2022, practices are expected to demonstrate organisational management of competence, not just individual qualifications. At renewal, the most meaningful question is not whether practitioners are RIBA or CIBSE members, but whether the practice has a documented CPD policy linked to role-specific competence criteria, a team-level record of CPD outcomes, and evidence that CPD is evaluated for practice change rather than attendance alone.
The Grenfell Tower Inquiry Phase 2 findings established that specification and product knowledge failures are systemic, rooted in organisational processes rather than only individual competence. The regulatory response — the Building Safety Act 2022 and the ITFG guidance — places formal organisational competence management obligations on AEC practices. In a PI context, this means demonstrating individual qualifications is necessary but not sufficient. A claim following a specification failure will examine whether the practice had governance systems in place, and whether those systems were documented.
An individual CPD record shows what sessions a practitioner attended and how many hours they logged. Organisational CPD governance evidence shows that the practice had a system: role-specific competence requirements defined, CPD activity connected to those requirements, evaluation of whether CPD produced measurable practice change, competence gaps identified at team level, and a named accountability statement. The first satisfies professional body membership conditions. The second satisfies the Building Safety Act’s organisational capability requirement and is what a PI investigation examines.
“The documentation that protects a practice in a PI investigation is the same documentation the ITFG guidance asks for. CPD Impact’s Practice Plan generates it — session by session, with a team-level evidence export your practice can produce on request.”
