Reportable Work

I am refurbishing more than 50% of my roof; do I need to inform Building Control?

Yes. If you are refurbishing or replacing 50 per cent or more of your roof which includes an insulation upgrade, or the roof is already insulated to the Building Regulations requirements in force at the time of your installation, then you must notify Building Control

This can be done either by using an NFRC CPS Registered Contractor, who can self-certify the work, or by going directly to a Building Control body such as LABC. Once the work has been signed-off, you will receive a Building Regulations Compliance Certificate (BRCC), which is legally required.

If there is no insulation upgrade to the relevant area and the existing roof is less than the Building Regulations requirement for insulation at the time of your refurbishment, then this work would be in breach of the Building Regulations. No BRCC would be forthcoming and you may be liable to a fine.

If I am carrying out roofing refurbishment work but the insulation does not need upgrading, is it still reportable?

Yes. Even if your insulation does not need upgrading, you will still need to notify Building Control.

Are garage roofs reportable?

No. Unless the garage has fixed heating (not portable heaters), there is no legal requirement to notify the work.


Which flat roofing projects are reportable?

All domestic, commercial and industrial flat roofing projects are reportable if 50 percent or more of the roof is being refurbished or renewed and the insulation upgraded to Building Regulations in effect at the time of installation.

Will a change in the weight of the roof coverings require a structural survey?

For most roofing types an increase or decrease in load of 15 per cent is considered acceptable before a structural survey is deemed necessary.  An increase or decrease of more than 15 per cent will require a structural survey.

Can a roofing refurbishment job for a Grade 2 listed building be registered through NFRC CPS?

Yes, any Listed Building type can be registered through the scheme providing 50 per cent or more of the roof is being refurbished or renewed and the work is to a modern specification including the insulation. True ‘historic’ features such as a lack of underlay and the use of back-pointing or torching behind slates or tiles, use of wooden or lead pegs for slate fixings, cleft or riven battens cannot be accepted by NFRC CPS as they do not conform to the relevant modern British Standards.

Care must also be taken not to prejudice the character of the building. The specification for any such roofing works would have to be scrutinised on a case-by-case basis by our Technical Department to establish whether or not they can be registered through the scheme.

Does NFRC CPS cover work on property within a conservation area?

Yes. All buildings, in general, need to comply with the requirements of the Building Regulations. NFRC CPS Registered Contractors can undertake work they are authorised to do in a conservation area provided they have been trained and verified as competent in the relevant roofing skills that may be required in that area such as Kent peg tiles, stone tiling, random slating, and leadworks.

Is roofing refurbishment work on a conservatory roof reportable?

If doors between the lounge and conservatory exist then there is no need to upgrade the insulation in the conservatory roof. However, if the doors have been removed i.e. the lounge and conservatory become interlinked, then they must upgrade the insulation as the heat from the lounge will pass into the conservatory and out through the roof.

I am refurbishing a roof where only 50 per cent of it is a thermal element; is this work reportable?

Yes, if any part of the roof acts as a thermal element, then refurbishment work is notifiable to Building Control, who can be notified through the NFRC CPS.

I am replacing slates with clay tiles on a roof. Can this work be reported via the NFRC Competent Person Scheme?

This depends on the weight of the slates and the weight of the clay tiles. If the clay tiles represent an increase in load upon the structure of more than 15 per cent then the work should be reported directly through to Building Control. It can be registered through the NFRC CPS so as long as the structure and loadings are assessed by a qualified structural engineer and their report confirms suitability.

If a flat roof has no insulation requirement (for example it has no fixed heating nor is a dwelling), is it reportable?

If a flat roof is not being insulated because the room area below has no form of fixed heating (or cooling in the example of a cold store), such as a garage, then the work does not need to be reported. However, if it is not being insulated because of technical or economic reasons (i.e. payback less than cost), then it is reportable.

NFRC Competent Person Scheme

How is the scheme controlled?

NFRC CPS is licenced by Department for Levelling Up, Housing and Communities (DLUHC) and is accredited and annually audited by the United Kingdom Accreditation Service (UKAS)  and managed by The National Federation of Roofing Contractors Limited (NFRC).

Will I get a Warranty?

All domestic roof refurbishments will be automatically issued with a ten-year Insurance Backed Insolvency Guarantee, which reinforces the contractor’s workmanship guarantee.

What if I have a problem with work carried out by a NFRC CPS Registered Contractor?

Should you have any problems with the roof following completion of the work we recommend that you contact the roofing contractor in the first instance and then complete their dedicated complaints procedures. Should you fail to achieve a satisfactory outcome, you should contact NFRC CPS via the online complaint form.

My roof needs a structural alteration, can NFRC CPS authorise this change?

No. This work is out of scope of the scheme and will need to be reported directly to Building Control.

Can an NFRC CPS Registered Contractor replace my roof light?

Yes. An NFRC CPS Registered Contractor can replace a roof light but, if any structural alterations are required such as cutting into an /or re-forming the accommodating gap in the rafters as opposed to a like-for-like replacement, then this work has to be reported to Building Control.

Can an NFRC CPS Registered Contractor install solar panels on my roof?

An NFRC CPS Registered Contractor cannot ‘self-certify’ the installation of solar panels.

However, if the Registered Contractor has been trained and has achieved certificated competency to install solar panels by the manufacturer, then they can install the panels in your roof. However, they cannot self-certify or commission the completed system unless they are also registered with the Microgeneration Certification Scheme (MCS) which is usually the domain of a qualified and MCS registered electrician.

If I convert a flat roof to a pitched roof can an NFRC CPS Registered Contractor self-certify this?

No. This falls outside the scope of the CPS Scheme as the work is classed as new and not refurbishment. This would need to be notified via Building Control as there are structural elements involved (such as the pitched element) and also possibly the local authority Planning Department.

Is the NFRC CPS Scheme a Trade Association?

No. NFRC CPS is a UKAS Accredited certification body, created to authorise roofing contractors to self-certify the roofing work they complete and to make sure that this work complies with the Building Regulations and relevant British Standards in effect at the time of installation.


What is a ‘cold roof’?

For both pitched and flat roofs, cold roofs are where insulation is placed between the ceiling joists and for pitched roofs, also over the joists. The flat roof application requires that cross ventilation be provided over the insulation and under the decking and which, if not properly created, can lead to the formation of interstitial condensation and promote rot. The latest British Standards (6229:2018) regarding this type of installation openly discourages its application in favour of a warm system which dramatically reduces the condensation risk.

The pitched roof application requires ventilation at both the eaves and top edge.

What is a ‘warm roof’?

For a pitched roof, this is where insulation is placed over, underneath, or between the rafters or a combination of all three, and then roofing material such as slates or tiles is placed on-top.

For a flat roof, it means that insulation is placed on an Airtight Vapour Control Layer on the supporting deck and then a waterproof outer layer fixed on top.

What is the minimum insulation that should be in a roof to meet the minimum U-value of 0.35 WmK threshold value?

Roughly 140 – 150 mm for “quilt” type insulation and 75 – 80 mm for rigid board type insulation depending on material/manufacturer.

What is the thickness of insulation that will give a U-value of 0.16 W/m2K?

Roughly 300 mm for quilt type insulation and 120 mm for rigid board insulation depending on material/manufacturer.

Pitched Roofs

When stripping an old roof and it is found to be close boarded, is there a requirement to upgrade the insulation underneath?

If the total U-value including the existing insulation does not meet the threshold requirements of Part L of the Building Regulations (i.e. U=0.35), then yes, the insulation will need to be upgraded.

If a house has a fully boarded loft with insulation between the ceiling joists, can extra insulation be added over the boards if required to top up?

Yes. Extra insulation can be applied over the boards but, ensure that ventilation is not blocked at the eaves.

Flat Roofs

I am NOT stripping the waterproofing off a flat roof—do I need to upgrade the insulation?

If the existing in-situ insulation is proved to have a maximum U-value of 0.35 then there is no requirement for any extra insulation to be fixed and the overlay of new waterproofing can be secured directly to the existing system (subject to material manufacturers recommendations) and registered through the scheme resulting on completion of works, in the issue of a BRCC.

If there is no insulation, or the existing in-situ insulation’s performance is proven to be over the basic maximum 0.35 U-value requirement, there is no extra insulation installed, and the roof is overlaid with new waterproofing, then this is not reportable through the scheme as this is classed as a repair and no BRCC can be applied for or issued.

You should know, however, that if the work is within the scope of the scheme and is reportable, it is a requirement that the insulation U-value is brought down to the required maximum of 0.16 or you may risk a fine.

For flat roofs when the timber deck is not being replaced, is there a requirement to upgrade the insulation underneath?

This is referring to a cold type roof system which is now not recommended for use by the current British Standard 6229:2018. It would be advisable to replace this with a warm type roof system as this reduces condensation risk.

However, if the cold system has to remain, the total U-value including the existing insulation does not meet the requirements of Part L of the Building Regulations, then yes, the insulation will need to be upgraded if technically and economically possible.

A flat roof needs to be refurbished; if the waterproofing is replaced what is the minimum thickness of insulation required?

It depends on the U-value of the insulation and the detailing or situation of the roof, but usually, 120 mm of rigid board is sufficient.

A flat roof that is a thermal element needs to be refurbished, and I don’t know how much insulation there is in the void between the ceiling and the roof. What should I do?

The extent of the insulation must be determined to see if it meets the requirements of the Building Regulations. Any insulation is unlikely to meet the minimum standard if it is between the ceiling joists such as a cold roof and so the contractor will need to address this.

This usually entails creating a warm roof by removing existing insulation, sealing any ventilation, applying a vapour control layer (VCL) to the decking, adding insulation to the top of the roof and then applying new waterproofing.

Churches and graded/listed buildings

When refurbishing a church roof—does the insulation need upgrading?

Churches are outside the requirements of Part L of the Building Regulations, so the insulation would not need upgrading. However, church offices, halls, meeting rooms and so on are included and would need the insulation to be upgraded if currently over the threshold.

I am stripping and replacing the tiles on a Victorian church hall. There is about 100 mm of insulation in the roof space, must the insulation be upgraded; the church has very little funds?

Yes. Unless the roof was the actual church it must be upgraded to current standards.

Building Regulations

I am tendering to strip and re-slate a Grade II listed building. I intend to use Spanish slate rather than Welsh slate like the original. Am I allowed to do this and do I need to upgrade the insulation?

The first part of the question is a planning not Building Regulations issue. Changes to the materials or appearance of a listed building should be checked with the Planning Department of the local authority and any other involved bodies such as English Heritage.

With regard to the insulation, most historic or listed buildings will still need to comply with the current building regulations, and you would need to upgrade the insulation if required. However, the work must not prejudice the character of the building or cause degradation of the fabric by using inappropriate materials or design.

For a roof over a block of flats does each flat have to have a Building Regulations Compliance Certificate (BRCC)?

Yes. Each flat within the building will need to be registered. Even if they are not directly under the roof, the roof and its function (weather protection / thermal efficiency) is serving the whole building.

I’ve seen a roofing contractor not abiding by Building Regulations; can I do anything about this?

Yes. If you suspect that a roofing contractor may be breaking the law by not complying with Building Regulations, you may anonymously report them by contacting admin@nfrccps.com or your local Building Control.

I’ve lost my Building Regulations Compliance Certificate; can I get a new one?

Yes. You can apply for another copy of the Certificate (which you will need when you come to sell your home) but there will be an administration charge.

What happens if I ignore the Building Regulations?

If the work is found not to be compliant with the Building Regulations, the building owner may be served with an enforcement notice from the local authority requiring alteration or removal of work at their own cost.

The building owner would not get a BRCC for the work carried out. This will cause problems for the property owner when they come sell the property. Solicitors carry out searches to prevent the risk of claims made against their own professional indemnity insurance should defects be found which only become apparent after the sale of the property.

There is also the risk of prosecution; under Section 35 of the Building Act, any contractor not abiding by the Building Regulations faces an unlimited fine.