Building control for a commercial re-roof: which route?
Updated 23 October 2026 · SEO Dons Editorial
Check your re-roof against the rules ↓
Does a commercial re-roof need building control at all?
Often, yes. GOV.UK lists replacing roof coverings on pitched and flat roofs among the alterations that may need building regulations approval. In the Regulations, work required by regulation 23 is building work, and a person who intends to replace or renovate a thermal element in a building covered by the energy efficiency requirements must give a building notice or an application, unless a scheme route applies. A roof is a thermal element where it separates a thermally conditioned part of the building from the outside; the roof of an unheated store is a different case.
Where do repairs and overlays fall?
The definition of renovation decides it. Renovating a thermal element means providing a new layer, other than where that layer is provided solely as a means of repair to a flat roof, or replacing an existing layer. A strip-and-recover replaces a layer, so it is renovation. An overlay used solely to repair a flat roof falls outside the definition; an overlay with another purpose, such as adding insulation, does not get that exception. The NFRC Competent Person Scheme treats an overlay with no insulation change as a repair that is not reportable through the scheme, though its FAQ page still cites BS 6229:2018, so read it as the scheme’s position, not current figures.
Two further tests apply. Regulation 23 requires the whole element to be improved, so far as feasible, where the renovation is a major renovation or covers more than 50% of its surface area; the Part L guide sets out the percentages and U-values. And an alteration is material if it would make a building stop complying with a relevant requirement, a list that includes external fire spread, so a re-cover of an unheated roof can still be building work if the new covering performs worse on fire; the BROOF(t4) guide explains the classes. Ask the building control body or the scheme before treating a job as a repair.
What are the three routes?
For work that is not on a higher-risk building, a commercial re-roof is signed off by a self-certifying contractor, by the council, or by a private approver.
| Route | Who supervises | How it starts | Closing document | Timings in the Regulations |
|---|---|---|---|---|
| Competent person scheme | The scheme inspects its registered contractor | The contractor registers the job; the owner gives no building notice or application | Certificate to the occupier; notice or certificate to the council | Within 30 days of completion |
| Council building control | The council | Application with full plans; notice before starting and within 5 days of starting | Completion certificate | Decision on the application within 5 weeks; certificate within 8 weeks of the completion notice |
| Registered building control approver | The approver | Initial notice given jointly with the approver to the council | Final certificate given to the council | Council may reject the notice within 5 working days and the certificate within 10 working days |
Route one: a roofer registered with a competent person scheme
GOV.UK names two schemes authorised for replacing roof coverings on pitched and flat roofs, including necessary connected work but not solar panels: NAPIT and CompetentRoofer, which is the scheme run by the National Federation of Roofing Contractors. The Regulations call these self-certification schemes. Where the work is within scope and done by a registered person, no building notice or application is needed. The contractor must give the occupier a copy of the certificate, and the council a notice or the certificate, within 30 days of completion. The certificate is evidence, but not conclusive evidence, of compliance.
The NFRC scheme says its registered contractors can self-certify domestic, commercial and industrial work where 50% or more of the roof is being refurbished, in felt, single-ply and GRP, liquid-applied waterproofing, mastic asphalt, reinforced bitumen membranes and sheeting. Regulation 23 speaks of more than 50%, so ask how a roof area is measured. Solar installations, structural work other than like-for-like and structural glazing such as atriums fall outside the scheme and go to building control. On commercial work the scheme sets the number of inspections by risk and complexity, notifies building control on completion and sends the owner a Building Regulations Compliance Certificate. Check the contractor is registered for your roof system in the scheme’s contractor directory; the contractor checking guide covers other registers.
Route two: the council’s building control team
The Fire Safety Order applies to any premises other than those it excludes, such as domestic premises, which in practice covers commercial and industrial buildings. For building work on those buildings, regulation 12(3) requires an application for building control approval with full plans, so a building notice is not available. The council must give its decision within five weeks, or a longer agreed period.
The person doing the work gives notice of intention to start at least two days beforehand and a commencement notice within five days of starting. The council may ask to be told when specified stages are reached so that it can inspect them. After completion a notice follows within five days, and if the council is satisfied after taking all reasonable steps it gives a completion certificate within eight weeks of receiving it. Fees are set by each council: see the building control costs guide, and the completion certificate guide for the end of the process.
Route three: a registered building control approver
Registered building control approvers replaced approved inspectors when section 49 of the Building Act 1984 was omitted on 6 April 2024. Every private business doing building control work in England and Wales must be registered with the Building Safety Regulator, and the public register shows each approver’s name and address, registration number, type of work, start and end dates of registration and any conditions.
The person intending to carry out the work and the approver give the council an initial notice jointly. Once the council accepts it, the approver takes over inspection, supervision and certificates, and gives the council a final certificate when satisfied the work is complete. The council has five working days to reject an initial notice and ten working days to reject a final certificate. GOV.UK says approvers negotiate their fees directly with you. If an approver is unable to continue, at least one council says the initial notice reverts to the local authority, so check the register for the approver’s scope and dates before appointing.
How does the route affect guarantees, sale and lease paperwork?
Each route ends in a different document, and the Regulations treat all of them as evidence, not conclusive evidence, that the requirements were met. GOV.UK’s example is selling a home; a commercial owner should ask, before choosing a route, which documents a buyer, tenant, lender, insurer or guarantor is likely to want. The NFRC scheme offers an insurance-backed guarantee on some commercial projects, but above a value the scheme sets it is not mandatory, and the contractor must document that in the contract. The guarantees guide explains guarantee types; whether one asks for building control evidence depends on its wording.
What about higher-risk buildings and the other nations?
Building work on an existing higher-risk building needs Building Safety Regulator approval except in certain cases, which include work done under a competent person scheme; the higher-risk buildings guide covers it. Wales, Scotland and Northern Ireland have their own systems, set out in the guide to re-roofing rules across the UK. Whether the roof should be repaired or replaced in the first place is a separate decision: see the repair or replace guide.
Sources
- The Building Regulations 2010, regulations 2, 3, 12, 14A, 16, 17, 20, 23 and Schedule 3, legislation.gov.uk, checked 22 October 2026
- legislation.gov.uk: Building Act 1984 (sections 47, 49, 51), Building (Registered Building Control Approvers etc.) (England) Regulations 2024 (regulations 6 and 13), Regulatory Reform (Fire Safety) Order 2005 (article 6), checked 22 October 2026
- GOV.UK: Building regulations approval, How to apply, Competent person scheme: current schemes (updated 17 September 2026) and Find a registered building control approver in England, checked 22 October 2026
- NFRC Competent Person Scheme: scope, building control, commercial and FAQ pages, checked 22 October 2026
- Making an application, Cornwall Council, checked 22 October 2026
Common questions
Is building control the same as planning permission?
No. GOV.UK says building regulations approval is different from planning permission and that you might need both. The Building Regulations 2010 cover the construction and extension of buildings, and many alterations such as replacing roof coverings, so check both before work starts.
Can my roofer certify their own work?
Only a roofer registered with a scheme authorised for roof coverings can, and only for work within that scheme’s scope. The certificate is evidence of compliance, not conclusive evidence, and work outside the scheme goes to the council or a registered approver.
Can a commercial roof use a private approver rather than the council?
Yes, where the building is not higher-risk. GOV.UK says you can choose your local authority’s building control department or a private registered building control approver. Check the approver on the Building Safety Regulator’s register first.
What happens if the approver stops trading mid-project?
At least one council says the initial notice reverts to the local authority if the approver cannot continue. The legislation on council charges includes a charge for considering building work that reverts to local authority control, so ask the council what it will need.
Related guides
Check your re-roof against the rules
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