Who Signs Off Access

The gap between the drawing and the door

Many applications for planning permission in England and Wales must be accompanied by a design and access statement — a document setting out how the proposals meet the needs of disabled people. In principle, this is a serious instrument: it commits the applicant, on record, to specific design decisions. In practice, it is rarely read by anyone again after the planning officer approves it.

Planning authorities check access statements against local plan policies and, where relevant, national guidance such as Approved Document M in England — the part of the Building Regulations covering access to and use of buildings. Approval at planning stage, however, is a policy judgement, not a technical one. The dimensional checking, the handrail heights, the door-force measurements — those belong to building control, which runs on a separate track entirely.

Building control can be carried out either by the local authority or by an approved inspector operating as a private body. Either route produces a completion certificate at the end. That certificate confirms the building was constructed in accordance with the approved plans and meets Building Regulations. It does not certify that the access statement from the planning application was honoured. Nobody is formally required to reconcile the two.

Where provision shrinks

The most common mechanism for access regression is value engineering — the systematic trimming of cost during detailed design and construction that tends to fall hardest on provisions that are not load-bearing, literally or figuratively. A turning circle in a wheelchair-accessible toilet is expensive in square footage; a tactile warning strip costs money to install correctly; a platform lift is cheaper to omit if there is a step-free alternative route, however inconvenient, to justify the deviation. None of these changes necessarily breach Building Regulations, which set minimum standards only. All of them may breach what the access statement committed to.

The access statement belongs to the planning file. It sits with the local planning authority. The building control file sits elsewhere — with the local authority building control team or with the approved inspector. There is no statutory duty to cross-reference them at practical completion. A facilities manager receiving a new building may have the completion certificate in hand and no access statement at all.

Design-and-build contracts compound this. Where a contractor takes on both design development and construction, the employer's requirements document — not the access statement — becomes the controlling text. If accessibility requirements are written loosely there, they will be delivered loosely. A clause in the contract outlasts everyone who wrote the policy: the moment access provisions are left to interpretation rather than specified precisely, interpretation tends toward economy.

What a tighter process looks like

Local authorities that take access provision seriously at planning stage appoint access officers — sometimes qualified in architecture or planning, sometimes drawn from occupational therapy — who engage with applications before submission and track conditions through to discharge. Where this works, it works because the same person holds the thread. That is a resource question, and most planning departments are stretched well beyond it.

The practical fix does not require new legislation. It requires the access statement to be a live document, referenced explicitly in building control submissions and checked against the as-built condition before the completion certificate is issued. Some local authorities and larger developers already operate this way under internal protocol; it is not standard.

For commissioners, project managers and employers taking on a new or refurbished building, the question worth asking before handover is not "do we have the completion certificate?" but "can we show that what was built matches what was promised?" The access statement, the approved plans, the as-built drawings and a walk-through by someone who knows what they are looking at — that combination closes the gap that the formal system leaves open.