Open consultation

Plan approval requirements for new builds and fire safety order buildings: Summary of analysis

Published 2 April 2026

Applies to England

The purpose of this consultation is to seek views on proposals relating to the introduction of more stringent building control procedural requirements for new homes and in some instances work to existing dwellings where the Regulatory Reform (Fire Safety) Order 2005 (Fire Safety Order or FSO) applies below 18 metres. We also intend for these changes to address some of the current differences between the public and private sector building control routes.

We are proposing requiring the use of building notices for new dwellings using the local authority (LA) route, requiring the use of plans certificates for new dwellings and FSO buildings using the Registered Building Control Approver (RBCA) route, and assessing the proportionality of Fire and Rescue Authority (FRA) consultation points in light of these changes.

The total net present value cost^{[footnote 1]} to industry of the regulatory changes in the preferred option over 10 years is estimated at £21.5 million (£12 million to £37.9 million), with an equivalent annual net direct cost to business (EANDCB)^{[footnote 2]} of £2.5 million (£1.4 million to £4.4 million). This is broken down by policy proposal in Table 1 below. Additional Building Safety Levy generation, totalling £33.1 million, is a fiscal transfer from regulated entities to the public sector, not a regulatory cost or benefit, and is therefore excluded from the EANDCB calculation and net present social cost. The levy will be an additional cost to developers. An additional scenario where a plans certificate is required prior to an initial notice under the RBCA route is also modelled, this increases the total costs by £113 million – this is not the preferred option.

Table 1: Summary of Net Present Cost to Business and Equivalent Annual Net Direct Cost to Business, £m, 2026-2035 (2026/7 prices and 2026 base year)

(Note negative figures represent a saving)

Policy proposal	Present Value Costs (10 years, mid cost scenario) £m	Equivalent Annual Costs (£m)
Building notices: all new builds to use application with full plans route for local authority building control	-0.86	-0.10
Initial notices (preferred Option 1): all new builds to receive plans certificate prior to final certificate	21.6	2.51
FRS Consultations: all new builds to include a consultation at final certificate stage	0.72	0.08
FRS Consultations: remove the requirement for RBCA to consult with FRS at plans certificate stage	-0.31	-0.04
FRS Consultations: remove the requirement for RBCA to consult with FRS at amendment notice	-0.13	-0.01
Familiarisation costs	0.52	0.06
Total cost for preferred option	21.5	2.50
Potential additional BSL generation as a result of requiring full plans route	33.1	3.84
Additional cost for Initial notices Option 2: all new build to receive plans certificate prior to initial notice	+113	+13.1

We expect about 1,600 dwellings (under the central scenario) per annum to be subject to the building safety levy that would not be at present, because they would use a building notice. This results in an expected additional cost of c. £2,600 for each of those dwellings.

Below is an indicative average cost per dwelling change for the majority of dwellings in each scenario (excluding dwellings to which the levy will apply):

• Building notice (non-levy, no detailed plans preparation): circa £60 per dwelling saving for 2,700 dwellings per annum (outliers: 6 dwellings with an increase of c.£850 to produce plans)
• RBCA route (no need to prepare plans, or delays): circa £5 per dwelling cost increase for circa 187,000 dwellings per annum; and only circa £2 per dwelling cost increase for a further circa 36,000 dwellings per annum (outliers: 2,200 dwellings with an increase of circa £605 to produce plans)

These figures reflect the level of plans preparation that is already occurring in industry, as they are informed by good practice encouraged by regulators.

In the outlier cases in particular, we expect to see non-monetised benefits relating to increased compliance with the functional requirements of the building regulations of new dwellings. Regulators report that the increased certainty associated with inspecting work built to approved plans improves their oversight and allows for better, more targeted, intervention.

The analysis estimates the number of submissions impacted by the policy over the appraisal period (assumed to be 10 years from 2026 to 2035). The type of additional costs that could be incurred by the changes were then identified through engaging with industry and reviewing published evidence. The proportion of submissions that will incur each of the additional costs is then estimated, based on the number of submissions per annum adjusted to take account of the counterfactual. The average additional cost per submission is then estimated. Costs are calculated using an estimate of the additional time that will be incurred to meet the policy requirements and any additional fees charged to prepare additional information.

The additional time incurred is valued using a combination of: employment costs or fees to prepare, review and submit information. Where a policy option might result in a delay to the start of work, because of waiting for Building Control approval for example, the additional time is costed based on an estimate of the additional costs of financing the development for the estimated number of weeks delay. The average additional cost per submission is then multiplied by the number of submissions impacted.

The analysis indicates that there is a small financial benefit to some businesses through a cost reduction in requiring that new dwellings using the LA route apply with full plans. This is based on data collection of LA fees, comparing cost of using a building notice with the cost of using full plans. Note, this assumes fees are full cost recovery and a good proxy for value of building control resource and does not account for changes to LA fees. Reducing the number of FRA consultations for FSO buildings using the RBCA route also produces a small cost saving for relevant buildings.

We expect to see non-monetised benefits relating to increased compliance with the functional requirements of the building regulations of new dwellings and, where relevant, building work to existing buildings. Regulators report that the increased certainty associated with inspecting work built to approved plans improves their oversight and allows for better, more targeted, intervention.

1. Net present value (NPV) is a term for the sum of a stream of monetised future values (costs and benefits) that have been discounted to bring them to present value. A negative NPV is usually called a net present cost (NPC). ↩

2. The Equivalent Annual Net Direct Cost to Business (EANDCB) is used as a comparative measure of the administrative burden on business from regulation by the Regulatory Policy Committee (RPC). ↩