The Grenfell Tower Inquiry examined, in exhaustive forensic detail, how specification and product knowledge failures propagated through AEC projects. Its Phase 2 Report, published in 2024, found repeatedly that the question was not only whether individual professionals knew enough. It was whether organisations had systems in place to ensure that competent people were making competent decisions.
The regulatory response to that finding flows directly into the practices you run. The Building Safety Act 2022. The dutyholder regime. CDM obligations. And now, published in May 2026 with the backing of more than fifty professional bodies and regulators including BSI, HSE, RIBA, CIBSE, ICE, CIOB, and the Building Safety Regulator: ITFG:01/26 — Managing Competence in the Built Environment.
Hours-based CPD is what most AEC practices had before Grenfell. Documented organisational competence management is what the post-Grenfell regulatory framework now requires.
For practices that have not yet closed this gap, the exposure is not theoretical. When a professional indemnity claim is investigated, two questions are asked. The first is whether the individual who made the decision was competent. The second — the one most practices are not prepared for — is whether the practice had systems in place to ensure that. This piece is about what that means for the senior partners and directors who hold board-level accountability.
The distinction that changes the liability picture
The ITFG guidance draws an explicit line between two things that AEC practices have long treated as the same.
Individual competence is whether a specific person has the skills, knowledge, experience, and behaviours required for their role — the SKEB framework established in BS 8670-1:2024 and referenced throughout the Building Safety Act’s dutyholder regime. Most practices are reasonably confident their staff meet this threshold. Professional body membership, CPD hours logged, relevant qualifications: these are the proxies the sector has used for decades, and they satisfy professional body renewal requirements.
Organisational management of competence is something different — and the guidance is explicit about the distinction. Section 7.2 states plainly: “The successful management of competence depends not only on competent individuals, but also on governance, supervision, and decision-making structures within organisations.”
In practical terms, this means the practice as an organisation must be able to demonstrate:
- Role-specific competence profiles exist — not generic job descriptions, but defined criteria for what each role requires given the work the practice actually delivers
- Work is assigned to individuals confirmed as competent for that work, with a documented basis for that confirmation
- CPD is evaluated for effectiveness — whether it is producing the practice changes it was intended to produce, not merely logged as attended
- Competence gaps are identified at team level and addressed — the practice knows not just who attended what, but whether the team collectively has sufficient competence capacity for the work it is taking on
- All of the above is documented and retrievable
Under the Building Safety Act 2022, the Building Regulations 2010 (as amended, Section 11Q on organisational capability), and CDM 2015, these duties fall on the organisation. A practice that employs competent architects has met the first requirement. A practice that cannot demonstrate it manages their competence organisationally has not met the second — regardless of how individually qualified its staff are.
This is the distinction most practices are not yet prepared for.
What this means in a PI context
Professional indemnity insurance is the mechanism through which design and specification liability is managed in AEC. PI claims are investigated by loss adjusters and lawyers whose function is to determine whether the practice met its duty of care. That investigation does not stop at the individual.
It examines the systems the practice had in place. How roles were defined. How work was assigned. What supervision existed. How competence was assessed and monitored. And — critically — what evidence the practice can produce that any of this was happening.
The Building Safety Act 2022 also extended the limitation period under the Defective Premises Act 1972 retrospectively, creating long-tail exposure on completed projects that is unlike anything the sector managed under previous regimes. A claim arising from work completed years ago will be investigated using the same question: what competence governance did the practice have at the time?
A practice whose CPD governance amounts to an annual email asking everyone to log their hours cannot produce meaningful evidence in response to that investigation.
A practice that has a documented CPD policy connected to role-specific competence criteria, a team-level record of CPD activity and its evaluated outcomes, and a named board-level accountability statement can produce something materially different: a documented management cycle demonstrating that competence was not assumed but actively governed.
The ITFG guidance’s PDCA framework — Plan, Do, Check, Act — described in Section 10.5, maps directly onto what loss adjusters and regulators look for when assessing whether an organisation had adequate systems in place. The Check phase requires evaluation of whether CPD “genuinely improves performance and behaviour, rather than simply recording completion” (Section 9.6.2). Most practices cannot currently satisfy that requirement. The guidance formalises the expectation that they do.
What adequate organisational CPD governance actually requires
The guidance applies proportionately. A small practice working on low-risk domestic projects has lighter obligations than a large practice delivering higher-risk buildings under Building Safety Regulator oversight. The ICC 15 Principles for Competence Management — particularly Principle 6 (Develop Competence), Principle 8 (Monitor Competence), and Principle 14 (Evaluation) — provide the framework that scales with organisational complexity.
But every practice, regardless of size and risk profile, is expected to be able to demonstrate five things.
One: the practice understands what competences are required for each role it delivers. Not a generic job description, but a role-specific competence profile linked to the SKEB framework and the actual work the practice undertakes.
Two: CPD activity is connected to those competence criteria. Not selected on the basis of accreditation status, conference proximity, or catering arrangements, but evaluated against identified development needs for specific roles.
Three: CPD is being assessed for effectiveness. Whether it is producing the practice changes it was intended to produce — not merely logged as attended. Section 9.6.2 of the guidance is explicit on this. Logging hours and issuing attendance certificates does not constitute evaluation.
Four: competence gaps are identified at team level and addressed. The practice does not only know who attended what. It knows whether the team collectively has sufficient competence capacity for the work it is bidding for and delivering.
Five: all of the above is documented and can be produced on request — to a regulator, a client at prequalification, an insurer at renewal, or a court following a claim.
Most practices currently satisfy none of these requirements at an organisational level. Individual practitioners may be highly competent. The organisation’s governance of that competence is, in most cases, a spreadsheet and an annual reminder.
The question to ask before the loss adjuster does
The ITFG guidance does not create new obligations for practices that were already managing competence properly. For those practices, it provides a recognised framework and the language to demonstrate to clients, insurers, and regulators what they were already doing.
For practices that have relied on individual competence and professional body membership as proxies for organisational governance, it marks the point at which that approach is no longer sufficient — not because the guidance says so, but because the post-Grenfell regulatory framework has formally shifted what due diligence in AEC looks like.
The question for every senior partner reading this is not whether their architects are competent. It is whether, if a loss adjuster asked to see the practice’s competence management documentation tomorrow, there would be anything to show.
Not whether good work has been done. Not whether the practice has talented and experienced staff. Whether there is a documented system — connected to role requirements, linked to CPD evaluation, maintained at board level — that demonstrates the practice governed its competence, not just hired for it.
If the honest answer is no, that is the gap this piece is about.
FAQs
Q1: What is the difference between individual competence and organisational management of competence in AEC? A1: Individual competence is whether a specific architect or engineer has the skills, knowledge, experience, and behaviours required for their role — defined in the ITFG guidance (ITFG:01/26, May 2026) using the BS 8670-1:2024 SKEB framework. Organisational management of competence is whether the practice has systems and processes to define role requirements, assign work to competent individuals, evaluate whether CPD produces measurable practice change, and document all of the above. Under the Building Safety Act 2022 and Building Regulations 2010, both are required. Most AEC practices satisfy the first. Few have documented governance for the second.
Q2: How does the ITFG competence guidance affect professional indemnity liability for architectural practices? A2: The ITFG guidance formalises the expectation that AEC organisations demonstrate organisational management of competence — not just individual qualifications. In a professional indemnity investigation, a claim following a design or specification failure examines what systems the practice had in place: how competence was defined, how work was assigned, how CPD was evaluated for effectiveness, and what documentation exists. The guidance’s PDCA framework maps directly onto what loss adjusters and regulators look for. A practice that cannot produce this evidence is in a materially weaker position than one that can.
Q3: What does adequate organisational CPD governance look like for an AEC practice under the ITFG guidance? A3: Proportionate to practice size and risk profile, the ITFG guidance requires that practices can demonstrate: role-specific competence criteria are defined; CPD activity is linked to those criteria rather than selected generically; CPD is evaluated for whether it produces measurable practice change; competence gaps are identified at team level; and all of the above is documented and retrievable. Most practices currently document CPD hours per individual. Organisational governance requires documentation at practice level — who is competent for what work, whether that competence is current, and whether the CPD system is producing the development it was intended to.
