Coulter BIM Information Management

The Building Safety Regulator’s Industry Competence Committee (ICC) has just launched a six-week consultation on its draft guidance, Setting Expectations for Competence Management. Responses are invited until 6 November 2025.

While “competence” might sound like an admin or tick box issue, the consultation makes clear that it is about much more than individual qualifications. It is about embedding competence management into the delivery of projects and treating it as a structured organisational requirement. For those of us working with BIM and information management, this consultation has real implications: it moves competence from being a desirable quality to a formal deliverable alongside drawings, models, COBie, and Uniclass-coded schedules.

What the ICC Is Proposing

The ICC is seeking views on draft guidance that will set the baseline for how competence is defined, managed, and evidenced across the built environment. The draft guidance includes several key expectations:

Competence Management System (CMS): Every organisation involved in design, construction, or asset management will need to develop and maintain a CMS. This isn’t just a policy document; it must outline how competence is measured, assured, and continuously improved.

Alignment with standards: The ICC points to existing frameworks such as ISO 19650 (information management), ISO 17024 (personnel certification), and BSI Flex 8670 (competence principles for the built environment). The intention is not to reinvent the wheel, but to create consistency across roles and projects.

Evidence at gateways: For higher-risk buildings, competence evidence will form part of the statutory Gateway 2 (before construction) and Gateway 3 (before occupation) submissions under the Building Safety Act.

Training and CPD: Competence is not static. Organisations must demonstrate ongoing professional development, clear role definitions, and a culture of upskilling.

This is not guidance to be read and filed away. It will directly shape how the Building Safety Regulator enforces competence across the sector.

Why This Matters for BIM Information Management

At first glance, competence management may not seem linked to ISO 19650 or information delivery. But in reality, it is inseparable. BIM workflows are increasingly the way competence is tested and evidenced.

1. Appointments and Exchange Information Requirements (EIRs):
Clients will begin adding clauses requiring demonstration of role competence in appointment documents. Information Managers should expect to see requests for proof of training, certification, or experience alongside the usual deliverables list.

2. Common Data Environment (CDE) metadata:
Deliverables stored in the CDE may need to carry metadata about the author’s competence. For example, a fire strategy drawing issued under PM_40_30 might need to be traceable back to a competent fire engineer, with credentials logged in the system.

3. COBie and contact data:
COBie already includes a Contact worksheet for recording project participants. Under this consultation, those entries may need to be supplemented with competence credentials — professional memberships, certification numbers, or evidence of training.

4. Uniclass and responsibility matrices:
The consultation strengthens the case for linking responsibility matrices, TIDPs, and CDE outputs with Uniclass PM codes. Not only can you track “who delivers what,” but now you can add “and are they competent to do so?”

5. Golden thread alignment:
The Building Safety Act requires a continuous, reliable record of safety-critical information. Competence evidence is now part of that golden thread. Without proof that the author was qualified to produce a deliverable, the golden thread is incomplete.

Practical Steps for Project Teams

So what should project and information managers do now?

Engage with the consultation: The draft guidance is open until 6 November 2025. Submit feedback on how competence evidence can realistically be integrated into BIM and CDE workflows. If you don’t, you may face requirements later that are harder to deliver.

Audit your current systems: Review your organisation’s training logs, CPD records, and appointment documentation. Are they aligned with what the ICC is proposing? If not, start closing the gaps.

Update your BEP and TIDP templates: Add fields for competence evidence. For example, alongside the deliverable code (PM_40_40: Design Drawings), include the role and competence requirements of the author.

Plan for competence metadata in your CDE: Speak to your CDE vendor or admin team about how competence information can be captured and linked to deliverables. This could be as simple as mandatory fields on file issue.

Train your teams: Make sure project participants understand that competence evidence is not just for HR files. It is now part of what will be checked at gateways and audits.

A Cultural Shift

Perhaps the biggest implication of this consultation is cultural. For years, the industry has focused on “what” is delivered — drawings, models, schedules. The ICC is now forcing us to ask “who” delivered it, and whether they were competent to do so.

This doesn’t mean endless bureaucracy. Done right, it simply means embedding competence into the same structured processes we already use for information management. Just as we validate a COBie file or check a drawing against the responsibility matrix, we will also validate that the author was competent for the task.

Conclusion

The ICC’s consultation is a wake-up call: competence is no longer optional or assumed. It is a deliverable in its own right, and one that must be managed with the same rigour as any BIM dataset.

For BIM and Information Managers, the challenge is to integrate competence assurance into existing workflows without adding unnecessary overhead. If we can do that, we won’t just be compliant with the Building Safety Act — we’ll also build a more reliable, professional, and trusted industry.

Responses to Setting Expectations for Competence Management close on 6 November 2025. If you care about how this will impact your projects, now is the time to have your say.