Accountants for trades — CIS, the VAT reverse charge, vans, tools and tax WhatsApp us hello@thetradesaccountant.co.uk
Accountants for Trades

The Building Safety Levy and dutyholder duties

Two things are converging on small builders. The Building Safety Levy starts on 1 October 2026 and is charged per square metre on building control applications for dwellings — though developments of fewer than ten units are exempt, which protects most SME sites. And the dutyholder and competence duties have applied to all building work since October 2023, whether or not anyone has told you.

Guide · Updated August 2026

The Building Safety Levy — the shape of it

The levy commences on 1 October 2026 under The Building Safety Levy (England) Regulations 2025, SI 2025/1236. It is England only.

Who pays. Anyone submitting an application for building control approval relating to the provision of one or more dwellings and/or one or more purpose-built student accommodation bedspaces on or after 1 October 2026, unless exempt.

How it is charged. An "applicable area rate" per square metre of chargeable floorspace, set for each local authority area in Schedule 3 to the regulations. Developments on previously developed — brownfield — land pay half the standard rate for that authority.

We are not going to quote a rate here. The rates are set authority by authority in Schedule 3, they vary substantially, and a figure for the wrong authority is worse than no figure. Before you price a site, get the rate for that specific local authority out of Schedule 3, and establish whether the land is previously developed — because that halves it.

The exemptions, and why most small builders are outside it

Exemptions include:

  • Developments of fewer than 10 units — explicitly protective of SMEs and small sites
  • Affordable housing
  • Non-social homes built by not-for-profit registered providers
  • NHS hospitals
  • Care homes, supported housing, children's homes
  • Domestic abuse shelters
  • Armed services accommodation
  • Criminal justice accommodation

There are also exempt persons under regulation 13: non-profit registered providers of social housing and their wholly owned subsidiaries — nothing they develop incurs the levy at all.

The practical reading for a small builder

Fewer than ten units means no levy. A builder doing one-off houses, small infill sites, conversions of under ten units, extensions and refurbishment work is outside this entirely.

Where it does matter: a builder crossing from nine units to ten or eleven on a site, or a small developer stepping up in scale. At that point the levy becomes a real line in the appraisal, charged per square metre across the whole chargeable floorspace, and it needs the Schedule 3 rate for the specific authority plus the brownfield question answered before the land is bought — not after.

Note also that this is a subcontractor's problem only indirectly. The levy attaches to the person submitting the building control application, so it lands on the developer or the client, not on the trades working for them. What it will do is squeeze margins on ten-unit-plus schemes, and that pressure travels down the chain.

Dutyholder and competence duties — these already apply to you

This is the part small trade businesses most often do not know about, because it arrived quietly and applies far more widely than the levy.

The Building Regulations etc. (Amendment) (England) Regulations 2023, SI 2023/911, apply to all building work from 1 October 2023. Not just higher-risk buildings. All building work.

Dutyholders are clients, principal designers, designers, principal contractors and contractors. If you are a contractor carrying out building work, you are a dutyholder.

The core duty: those undertaking design and building work must have the competence — skills, knowledge, experience and behaviours, or organisational capability — for the work they are engaged to do. Dutyholders must also plan, manage and monitor their work, and cooperate, communicate and coordinate with the other dutyholders.

There is a specific obligation on clients. A client appointing a principal designer must take all reasonable steps to satisfy itself that they meet regulations 11F(1)–(2) (general competence) and 11G(1) (principal designer competence). For a principal contractor, it is 11F(1)–(2) and 11H(1).

What that means in practice for a small contractor: when you are appointed as principal contractor on a domestic project, the client has a legal duty to satisfy itself that you are competent — so expect to be asked, and have something to show. Conversely, when you appoint others, the coordination duty is yours.

One honest limit: we have verified the dutyholder and competence duties in regulations 11F to 11H. We have not verified any separate requirement for a formal "competence declaration" document, and you will see that term used online. Do not treat a template competence declaration you found on the internet as satisfying a legal requirement we cannot point to in the regulations. What the regulations require is competence and reasonable steps to establish it.

The Building Safety Regulator, and Gateway 2

On 27 January 2026 the Building Safety Regulator moved out of the HSE to become a standalone non-departmental public body sponsored by MHCLG, as a step towards a single construction regulator.

On timescales, the BSR's stated target is to respond to a Gateway 2 building control approval application for a new higher-risk building in non-complex cases in 18 weeks or less by the end of March 2027. MHCLG and the BSR are consulting on reforms to the higher-risk building approval regime at Gateway 2, and quarterly application data is published.

For most trade businesses this is background rather than operational — higher-risk buildings are a specific and relatively small category. It matters if you work on them, and it matters as context for why programme risk on those schemes is priced the way it is.

CDM 2015: when a project is notifiable

A project is notifiable to HSE on form F10 where construction work will either:

  • Last longer than 30 working days and have more than 20 workers working simultaneously at any point; or
  • Exceed 500 person-days

Read the first limb carefully, because it is an "and", not an "or". A twelve-week job with six operatives is not notifiable on that limb. The second limb is where medium-sized jobs get caught: 500 person-days is, for example, ten people for ten weeks.

Worked example — is this notifiable?

Job A: a 40-working-day refurbishment with a maximum of 8 workers on site at once, totalling 260 person-days. Longer than 30 days but not more than 20 simultaneous workers, and under 500 person-days. Not notifiable.

Job B: a 12-week new build with an average of 9 workers over 60 working days = 540 person-days. Over 500 person-days. Notifiable, on the second limb, even though it never had 20 people on site.

Person-days is the limb that catches the ordinary medium-sized job, and it is the one people forget to count.

Companies House identity verification — a live compliance trap

Not a building safety matter, but it sits in the same category of obligation that stops a business functioning if ignored, and it caught a lot of small construction companies in 2026.

Identity verification became a legal requirement on 18 November 2025 under the Economic Crime and Corporate Transparency Act 2023, having been voluntary from 8 April 2025.

Who must verify: directors; director equivalents such as members, general partners and managing officers; directors of overseas companies registered in the UK; persons with significant control; and Authorised Corporate Service Providers.

Each verified individual gets a personal code, which directors must provide in the company's next confirmation statement filing. The operative consequence: the company cannot file its confirmation statement unless all its directors are verified. PSCs have a 14-day window to provide their personal code.

Not verifying can bring prosecution, court fines or financial penalties, and bars a person from becoming a new director, registering new companies, or registering as an ACSP. If you have a co-director who is a family member not involved day to day, that is the one to check — because their unverified status blocks your filing, not just theirs. See the structure guide for the other company obligations.

What to do, in order

  1. If you build fewer than ten units at a time, the levy does not apply to you. Note the threshold and move on.
  2. If a scheme reaches ten units or more, get the Schedule 3 rate for that specific local authority and establish whether the land is previously developed — brownfield is half rate — before the appraisal is signed off.
  3. Accept that you are a dutyholder on all building work and be able to evidence competence for what you are engaged to do.
  4. Count person-days on every job over about six weeks and notify on F10 where the project exceeds 500, even if you never have 20 people on site.
  5. Verify every director and PSC at Companies House and get the personal codes onto the file before the confirmation statement is due.

None of this is accounting, and we do not pretend the levy or the competence regime is our speciality. What we do is make sure the numbers in your appraisals and your cash plan reflect the obligations that have dates attached — see accounts and tax and, for the tax side of scaling up, the first employee guide.

The trades money email, once a month

What has changed on CIS and the reverse charge, the dates coming up, and one number worth checking on your own jobs. No spam, unsubscribe any time.

Quick answers

Frequently asked

Does the Building Safety Levy apply to a small builder?

Usually not. The levy commences on 1 October 2026 in England under SI 2025/1236 and is charged on applications for building control approval relating to dwellings or purpose-built student accommodation bedspaces — but developments of fewer than 10 units are exempt, an exemption written explicitly to protect SMEs and small sites. Affordable housing, care homes, supported housing, NHS hospitals and several other categories are also exempt, and non-profit registered providers of social housing are exempt persons whose developments never incur it. A builder doing one-off houses, small infill sites, extensions and refurbishment is outside the levy entirely.

How much is the Building Safety Levy per square metre?

It depends on the local authority, and you should not work from a national figure because there is not one. The regulations set an applicable area rate per square metre of chargeable floorspace separately for each local authority area, listed in Schedule 3 to SI 2025/1236, and the rates vary substantially between authorities. Developments on previously developed brownfield land pay half the standard rate for that authority. Before pricing a scheme of ten units or more, get the rate for that specific authority out of Schedule 3 and establish whether the site is previously developed, because the brownfield discount halves the charge.

What are dutyholder duties and do they apply to a small contractor?

Yes, they apply to all building work from 1 October 2023 under The Building Regulations etc. (Amendment) (England) Regulations 2023, SI 2023/911 — not just to higher-risk buildings. Dutyholders are clients, principal designers, designers, principal contractors and contractors, so a contractor carrying out building work is a dutyholder. The core duty is competence: the skills, knowledge, experience and behaviours, or organisational capability, for the work you are engaged to do. Dutyholders must also plan, manage and monitor their work and cooperate, communicate and coordinate with the others. Clients appointing a principal contractor must take all reasonable steps to satisfy themselves of competence under regulations 11F and 11H.

When do I have to notify HSE about a construction project?

A project is notifiable on form F10 where the construction work will either last longer than 30 working days and have more than 20 workers working simultaneously at any point, or exceed 500 person-days. The first limb is an 'and', not an 'or', so a twelve-week job with six operatives is not caught by it. The second limb is the one people forget: 500 person-days is ten people for ten weeks, so an ordinary medium-sized job can be notifiable without ever having twenty people on site. A 12-week new build averaging nine workers over 60 working days reaches 540 person-days and is notifiable.

Why can my construction company not file its confirmation statement?

Most likely because a director has not completed Companies House identity verification, which became a legal requirement on 18 November 2025 under the Economic Crime and Corporate Transparency Act 2023. Directors, director equivalents, directors of overseas companies registered in the UK, persons with significant control and Authorised Corporate Service Providers must all verify, and each verified individual receives a personal code that directors have to provide in the next confirmation statement filing. The company cannot file that statement until all its directors are verified, and PSCs have 14 days to supply their code. The usual culprit is a family co-director who is not involved day to day.

Ready when you are

Talk to accountants who only act for trades.

A free, no-obligation call about your CIS position, your VAT treatment and what is actually locked up. If we cannot save you anything, we will say so.

The trades money email, once a month

One short email: what has changed in CIS and construction VAT, the dates coming up, and one number worth checking on your own invoices. No spam, unsubscribe any time.