Registered access auditors and what the register means

A registered access auditor is someone whose competence in access and inclusive design has been assessed against evidenced experience and entered on the national register maintained for that purpose. Registration is not a licence, and planning legislation does not require an access audit to be produced by a registered person. What registration does is answer the question a case officer asks when an access statement makes a claim: on what basis.

For an architect, the practical value is narrower and more useful than the title suggests. A registered auditor reviews what you have drawn against Approved Document M, the British Standard and the local policy, and tells you which departures you will have to justify.

What an access audit covers in a planning context

An access audit in a planning submission is not a building control exercise, and confusing the two produces a document nobody can use.

At planning stage the questions are the ones the layout decides: how a person reaches the entrance from the street and from the parking, whether the approach is step free and at what gradient, where the accessible parking bays sit and how many there are, whether the entrance is level and legible, how vertical circulation works including lift provision and lobby dimensions, how the unit mix delivers any wheelchair user dwellings policy requires, and how the external spaces are usable.

What belongs at technical design stage is the detail that does not change the planning application: ironmongery, door opening forces, sanitary fittings, colour contrast of internal finishes, alarm specifications.

An audit that spends four pages on WC layouts and one paragraph on the approach gradient has been written for the wrong stage. Say so to the consultant when you brief them.

The register and how membership is assessed

The national register for access consultants and auditors assesses applicants on evidenced competence rather than on a single qualification. It maintains more than one category, with auditor and consultant set at different depths of role, and entry involves submitting worked examples for assessment by peers.

That structure is worth understanding because it tells you what to ask for. A registered auditor is assessed on the ability to audit an environment against the standards. A consultant category signals advisory work on design development, which is closer to what a major scheme needs at planning stage.

Neither category is a statutory competence in the sense that a licensed ecologist or a competent person under the Environment Act 2021 regime is, and the difference matters when you are explaining to a client why one appointment is optional and another is not. The wider position on what the statute means is set out in the article on competent person in planning legislation.

Ask for the individual's registration, their category, the date of entry and whether it is current. Ask also for two examples of schemes of comparable type, because access consultancy on a listed building conversion is a different discipline from access consultancy on a new leisure centre.

Approved Document M and the optional requirements

Approved Document M covers access to and use of buildings, in two volumes: dwellings, and buildings other than dwellings.

For housing, the three standards in the dwellings volume are the point where planning and building regulations meet. The baseline applies to all new dwellings. Above it sit two optional requirements, one for accessible and adaptable dwellings and one for wheelchair user dwellings, and they only apply where a local plan policy requires them.

That is the sentence to hold onto. The optional requirements are delivered through planning policy, not through the regulations on their own, so the local plan is the first document to read. In London, Policy D7 of the London Plan requires 10 per cent of dwellings to meet the wheelchair user standard and the remainder to meet the accessible and adaptable standard. Elsewhere the proportion varies, and some authorities have no policy at all.

The consequence for design is structural. Wheelchair user dwellings need larger circulation, larger bathrooms, a hoist route in some layouts and, in flats, careful positioning relative to the lift. Retro-fitting ten per cent of units to that standard after the plan is fixed usually means losing a unit.

BS 8300 and where it goes further

BS 8300 covers the design of an accessible and inclusive built environment, in parts dealing with the external environment and with buildings. It is not a regulatory requirement, and it is more demanding than Approved Document M in several places.

Where it commonly goes further: visual contrast between surfaces expressed as a difference in light reflectance value, gradients and the frequency of level landings on an external approach, resting places along a long route, door opening forces, and the treatment of glazed doors and screens.

Councils cite it. Local design guidance and inclusive design supplementary documents frequently ask for BS 8300 rather than the minimum in the Approved Document, and an officer who has asked for it will notice a statement that answers only the regulations. Where you are following the Approved Document and departing from the standard, say which clause and why.

Do not reproduce tables from the standard in a submission. Summarise, cite the clause and attribute it.

External routes, thresholds and wayfinding

Most access problems at planning stage are outside the building.

The step free route from the public footway to the principal entrance is the one to draw first, with spot levels. It has to work with the drainage design, the tree pits, the cycle stands and whatever the highway authority requires at the back of footway. On a sloping site it will drive the finished floor level, and on a tight urban plot it sometimes drives the position of the entrance itself.

Then the specifics:

• Accessible parking bays, their number as policy requires, their dimensions with transfer zones, and their distance to the entrance
• Dropped kerbs and tactile surfaces at any crossing on the route
• Level thresholds at the entrance, with the upstand within the permitted tolerance and a drainage solution that works
• Turning and manoeuvring space at doors, in lobbies and at any change of direction
• Lighting of the route, and the avoidance of deep shadow at level changes
• Wayfinding that works without colour alone, with legible signage positions shown on the plans

Level thresholds and drainage are the recurring conflict. Solve it on a section at planning stage rather than discovering it on site, because the fix at that point is a gully in the wrong place.

When to appoint, relative to the layout freeze

Before the layout freezes. That is the whole answer, and it is ignored constantly.

Access input received after the plans are fixed can do two things: confirm compliance, or generate a list of problems that cannot be solved without redrawing. Received two weeks earlier, the same input changes a core position and costs nothing.

The trigger points to appoint by are the first fix of the ground floor level and external levels strategy, the decision on lift provision and core layout, and the unit mix schedule if any wheelchair user dwellings policy applies. Once those three are set, the access strategy is largely determined.

A short review at concept stage, then a fuller audit once the planning drawings are substantially complete, is the pattern that works. Where a scheme needs a reviewer to sign off technical content, the professional directory is the route to one.

What a usable deliverable looks like

Ask the brief to require a document you can submit and a document you can build from. That means:

1. A statement of the policy and standards applied, naming the local plan policies and the versions of the Approved Document and the British Standard.
2. Marked-up drawings, not a text-only report, showing the step free route, the accessible bays, the level thresholds and the accessible units.
3. A schedule of compliance by clause, with a clear column for compliant, departure or not applicable.
4. Every departure listed with the reason and the mitigation, in one table.
5. The wheelchair user dwelling schedule where policy requires one, by unit number and floor.
6. A note on what remains to be resolved at technical design, so nothing is presented as settled that is not.

The access content then feeds the Design and Access Statement, which is the document the procedure order requires for major development and for most work to listed buildings. Where the authority is also discharging its equality duty, an Equalities Impact Assessment sits alongside it, though that duty falls on the decision maker rather than on the applicant.

This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.