Building safety remediation in Scotland: where now, where next?

This update explores the latest progress under the Scottish Government’s Cladding Remediation Programme, outlines priorities set for the months ahead and explains the introduction of a new regulatory framework, the Compliance Plan Approach, which aims to significantly strengthen building safety oversight in Scotland.

Understanding these changes is critical for anyone involved in the Scottish construction industry, especially in residential property ownership, management or development.

Latest Update on Cladding Remediation (Q2 2025)

The Scottish Government provided its latest quarterly update on 29 July 2025, revealing the current progress of the Cladding Remediation Programme as of 30 June 2025:

• Single Building Assessments (under the Housing (Cladding Remediation) (Scotland) Act 2024 “SBAs”) have been completed. All required remedial work, with repairs already underway in two cases;
• 12 more SBAs are currently in progress;
• Most SBAs (14) are funded by the Scottish Government, with one funded by a developer; and
• Geographically the majority are in Glasgow (9), followed by Edinburgh (5) and Aberdeen (1).

Progress has been slow since earlier this year, with only a slight increase in completed assessments. However, the Scottish Government notes that the quarterly release does not provide the complete picture of progress to mitigate cladding fire safety risk in Scotland because:

1. it does not include information on other types of assessment carried out prior to the publication of the SBA specification in June 2024; and
2. it is possible that developers or other organisations have started and/or completed more SBAs and/or remedial works than known at the time of this update. It is also expected that many more SBAs will be progressed following the Single Open Call.

Expressions of Interest via Single Open Call

The Single Open Call Initiative was launched in March 2025 to allow residential property owners or their representatives to notify the Scottish Government about cladding concerns and request funding for a statutory SBA. Properties are in scope for the Call if they meet the definitions used in the Housing (Cladding Remediation) (Scotland) Act 2024. In other words, buildings that are 11 metres or higher which have an external wall cladding system, contain at least one flat intended to be used as a dwelling and were constructed or have undergone development anytime between 1 June 1992 and 1 June 2022. The Call asks for expressions of interest to identify such buildings which may need assessment.

As of 30 June 2025, the Scottish Government had received 600 expressions of interest via the Single Open Call. This is up from 32 earlier in the year. As of 24 July, 258 initial grant funding offers had been issued by the Scottish Government. It has come to light that most submissions came from factors or property managers, local authorities and registered social landlords.

Cladding Remediation Programme – Next Phase

In August 2025, the Scottish Government published its plans for the next phase of the Cladding Remediation Programme, announcing a focus across five priority areas:

• Expanding SBAs across all housing sectors.
• Accelerating life-safety mitigation measures where risks to life have been identified.
• Progressing remediation pathways for buildings with completed SBAs.
• Securing full reassurance for all publicly owned residential buildings over 11 metres.
• Establishing clear remediation pathways for residential buildings over 18 metres.

The Scottish Government said it intends to implement these objectives between Autumn 2025 and March 2026 through the following key actions and an additional £20 million of funding, to accelerate the transition from assessment to remediation and provide long-term assurance for residents in affected buildings:

• Increased SBA Funding: Stage One funding for SBAs under the Single Open Call will be raised from £10million to £20million for eligible applications submitted by 31 December 2025.
• Equal Access to Funding: Funding will be available on an equitable basis to both private and social housing sectors to support assessment, mitigation and remediation.
• Stage Two of the Single Open Call: Launched on 7 August 2025, Stage Two will provide further funding for properties where Stage One SBAs identified the need for mitigation or cladding remediation.
• Life-Safety Mitigations: A separate £10 million fund will support the installation or upgrade of interlinked fire alarm systems in private, multi-owner buildings, while remediation is being planned.
• Remediation Works Commencement: For buildings where SBAs (commissioned by the Scottish Government) confirm remediation is required, support and potential funding will be provided to initiate technical design work.
• Pathways for High-Rise Buildings (18m+): By October 2025, remediation pathways should be established for all in scope high-rise buildings. Where owners or developers are not taking action, the Scottish Government says it will intervene directly, “to ensure these buildings are brought onto a funded and trackable remediation pathway as soon as possible.”
• Publicly Owned Buildings (11m+): A data-gathering exercise is to be concluded by October 2025, identifying any outstanding assessment or remediation needs in local authority and RSL-owned buildings.
• Developer Remediation Contracts: Responsible developers will be required to sign formal remediation agreements by 31 October 2025, legally committing them to assessing and remediating buildings of 11 metres and higher for which they have accepted responsibility, in line with Scottish Government standards.

Further, the Scottish Government set out aims that by 2029 every high-risk residential building of 18 metres and higher will have been resolved, by way of being made safe, decommissioned or replaced. Also by 2029, buildings of 11m to 18m in height will be on “a clear pathway to resolution”.

This is an ambitious timetable, looking to achieve significant progress by 2026 and beyond.

Compliance Plan Approach

For some time, the Scottish Government has been developing the Compliance Plan Approach (“CPA”), through the Compliance Plan Working Group and early adopter trials. This has been progressed further, as part of the Scottish Government’s response to the Grenfell Inquiry Phase 2 recommendations.   

The CPA is a framework aimed at improving accountability and evidencing compliance in future building projects. The new approach is designed to:

• Minimise the risk of completed buildings failing to comply with the building regulations and approved building warrant plans.
• Improve procedural compliance to support the delivery of safer buildings and legal occupation of buildings.
• Support the relevant person (normally the building owner/developer) to control the work on site to comply with building regulations and the approved building warrant plans and the building regulations, and to provide supporting evidence.
• Ensure that planned local authority verification inspections, checks and evidence within the approved building warrant compliance plan are fully achieved.

A Compliance Plan (“CP”) is to be developed at the outset of each qualifying project. The Compliance Plan will be submitted as part of the building warrant application and must be approved by local authority verifiers prior to construction. Once submitted, the CP will enable the verifier to assess whether the completion certificate and its compliance statement have been lawfully issued. It will also set out when the verifier should be notified, what their inspection and evidencing requirements are and the adequacy of their response.

A new role of Compliance Plan Manager (“CPM”), responsible for managing and overseeing the compliance process for all high-risk building projects is to be introduced. It means supporting the building owner (or relevant person as described in the Building (Scotland) Act 2003), to fulfil their duty to evidence and deliver a building compliant with the building regulations. The role of the CPM is primarily to be about coordination, oversight and information management, i.e. ensuring the process of achieving compliance takes place, for which they are dependent on other project stakeholders. This approach is designed to improve accountability and ensure that buildings meet safety standards before they are completed.

While legislation is still required for full implementation, guidance will be published in 2026 encouraging early voluntary adoption of the CPA principles. This guidance will outline the steps that a CPM is expected to take prior to the statutory requirement to collaborate with all parties to propose and monitor the CP.

The Scottish Government has commented that the publication of revised guidance will support a transition from the “early adopters” phase to an “early majority” ahead of legislative enforcement. It is hoped that this phased approach will allow ongoing feedback, review, and refinement of the CPA framework, ensuring it becomes established practice and is fine-tuned in advance of the legislation.

This marks a significant shift in regulatory practice, and the extent of early voluntary adoption remains to be seen.

Conclusion

While the Scottish Government has outlined ambitious plans and committed additional funding to accelerate cladding remediation, progress on the ground remains slow and uneven. The limited number of completed SBAs, alongside the still-developing regulatory framework, means many property owners continue to face uncertainty about timelines, responsibilities and available support.

The forthcoming introduction of the CPA (albeit initially on a voluntary basis) and the Scottish Building Safety Levy also signals a shift toward stricter oversight throughout design and construction, but without the full legislative detail, stakeholders are left to prepare with limited clarity. (You can read more about the  Scottish Building Safety Levy in our last edition of Construction Matters here.)

For owners, developers and managers of affected buildings, the path forward is still far from straightforward. It is essential to stay informed and our Building Safety Group offers guidance and support in navigating what remains a challenging and shifting regulatory environment.

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