A Qualified Person in Singapore must prepare plans that comply with approved guidelines, declare that compliance to the authorities, supervise construction to the standard the Planning Act and Building Control Act demand, and notify URA or BCA the moment works deviate from approved plans. These four obligations, plan preparation, supervision, declaration, and notification, form the statutory backbone of qualified person duties, and failing any one of them carries criminal exposure, not just a compliance headache.

TL;DR:

• A qualified person in Singapore must be appointed before planning permission and construction start, with responsibilities including plan preparation, supervision, declaration, and notification.
• The same architect or engineer can serve as both QP(D) and QP(S) on smaller projects, but larger projects usually split these roles to manage complexity and coordination.
• Missing or delayed notifications, declarations, or plan reconciliations can cause project delays, enforcement actions, or legal penalties, including fines and imprisonment.
• Supervision duties require immediate, documented responses to non-compliant work, especially during critical structural activities like piling, concreting, or excavation.
• Maintaining comprehensive, accessible documentation at each project stage, including declarations and instrumentation logs, significantly reduces the risk of compliance failures or delays.

Table of Contents

• Who Counts as a Qualified Person, and What Is the Legal Basis?
• What Does a QP Do When Preparing Plans and Declarations?
• What Are a QP’s Supervisory Duties on Site?
• How Many Site Supervisors Does a Project Need?
• How Do QPs Prevent URA and BCA Plans From Diverging?
• What Happens When a QP Is Replaced or Stops Acting?
• What Penalties Apply for Failing QP Duties?
• A Practical Checklist for QPs and Developers
• Why Strict QP Practice Protects Project Timelines
• How Aectechnicalsg Supports QP and Submission Compliance
• Where to Verify These Requirements Directly
• Sources
• FAQ

Who Counts as a Qualified Person, and What Is the Legal Basis?

A Qualified Person, under both the Planning Act and the Building Control Act, is either an architect holding a valid practising certificate or a registered professional engineer holding a valid practising certificate. That is the entire statutory test. It sounds simple, but the role splits into two distinct functions that Singapore’s regulatory system treats separately, and confusing them is one of the more common compliance mistakes on mid-sized projects.

A QP(D) is the qualified person for design and plan preparation. This is the professional who prepares the drawings submitted for planning permission and building plan approval, and who signs the declarations that accompany those submissions. A QP(S) is the qualified person for supervision, the professional responsible for overseeing construction on site to make sure the finished building matches what was approved on paper. On smaller projects, the same firm or individual often holds both roles. On larger or more complex developments, especially those with multiple contractors or phased construction, developers frequently split them, which raises the coordination burden discussed later in this article.

Appointment is not optional and not something a developer can delay until construction starts. The Planning Act requires a QP to be appointed before an application for planning permission is lodged with the Urban Redevelopment Authority (URA), and the Building Control Act requires a QP(S) to be in place before building works commence. For conservation projects, a separate declaration under Section 15(2)© applies, which is addressed in more detail in the section on cross-authority coordination below.

The developer, not the architectural firm or the contractor, bears ultimate responsibility for making sure a QP is appointed and remains appointed throughout the project lifecycle. If a QP resigns, is removed, or otherwise ceases to act, the project cannot legally continue without a replacement being notified to the relevant authority within the statutory window. This single point trips up more developers than any other aspect of qualified person compliance duties, largely because project teams treat QP appointment as a one-time administrative task rather than a continuous legal obligation. Readers wanting a deeper breakdown of how professional engineer registration interacts with QP status should see this explanation of PE compliance obligations for Singapore developers.

What Does a QP Do When Preparing Plans and Declarations?

The Planning Act requires a QP preparing plans to “take all reasonable steps and exercise due diligence” to ensure those plans comply with planning guidelines before submission. That phrase, due diligence, is deliberately broad, and URA’s DC17-05 circular treats it as a functional standard rather than a checklist: a QP has to actually verify compliance, not simply assert it.

In practice, this means the QP(D) checks setback requirements, plot ratio, height controls, and any planning conditions specific to the site before drawings ever reach URA’s desk. It also means signing a formal declaration confirming that verification was carried out. These declarations are not a formality tacked onto the submission. They are the mechanism URA and BCA use to place legal accountability on a named individual, rather than on a firm or a project generally.

Where declarations get submitted:

• To URA, at the point of planning permission application, confirming the plans conform to planning guidelines and any site-specific conditions.
• To BCA, at building plan submission stage, confirming structural and code compliance ahead of permit issuance.
• At Temporary Occupation Permit (TOP) or Certificate of Statutory Completion (CSC) stage, confirming the completed works match the approved plans, a declaration that effectively closes the loop opened at the design stage.

Alternative solutions, where a design departs from prescriptive code requirements but achieves an equivalent safety or performance outcome, carry an extra layer of scrutiny. An independent specialist QP, someone not involved in the original design, must certify that the alternative solution meets the intended performance standard. That certifier has to verify the underlying calculations, test data, or precedent applications independently, not simply endorse the original designer’s assumptions. Skipping this independent check is one of the more frequent findings in post-incident reviews of building compliance failures.

A clean plan submission package generally includes:

• Architectural and structural drawings bearing the QP’s registration number and signature
• The signed declaration of compliance with planning guidelines or building code requirements
• Supporting calculations for any alternative solution, plus the independent certifier’s endorsement
• Site investigation reports where foundation, tunneling, or significant earthworks are involved
• A copy of the URA-approved plans, where building plan submission follows planning permission

Missing any one of these documents is a common reason BCA or URA returns a submission for resubmission, which quietly adds weeks to a project timeline that a five-minute document check could have avoided.

What Are a QP’s Supervisory Duties on Site?

Supervision is not a periodic site visit followed by a signature. The Building Control Act requires the supervising QP to take reasonable steps and exercise due diligence to ensure works conform to the approved plans and the Written Permission issued for the project. “Reasonable steps” is a standard that scales with risk: a low-rise landed extension and a 40-story tower do not demand the same supervisory intensity, and BCA expects the QP to calibrate accordingly.

Certain construction activities demand the QP’s direct, immediate presence rather than periodic checks. These are the moments where an error is expensive, sometimes irreversible, and where documentation after the fact cannot undo a structural defect.

1. Piling operations, where pile depth, verticality, and load capacity must be verified as work proceeds, not inferred afterward from records.
2. Concreting of critical structural elements, including columns, transfer beams, and slabs, where the QP or a delegated, competent representative confirms mix design, placement, and curing conditions on site.
3. Pre-stressing and post-tensioning operations, where tendon tensioning sequences directly affect structural capacity and errors are difficult to detect visually once complete.
4. Excavation and shoring works near existing structures, where ground movement can affect adjacent buildings and where instrumentation monitoring becomes mandatory.

Instrumentation and monitoring obligations run alongside physical supervision. Where site investigation or excavation works are proposed, BCA’s amendment regulations require field and laboratory data, pre-construction condition surveys of adjacent buildings, and ongoing instrumentation readings during works. The supervising QP has to set trigger and alert levels for that instrumentation before works begin, and notify the Commissioner of Building Control if readings exceed those thresholds. Periodic reporting, not just a final report at project close, is the expected standard for any project where ground movement risk exists.

When a QP discovers non-compliant work already underway, the response sequence matters, both for safety and for the QP’s own legal position.

1. Stop the specific non-compliant activity immediately, rather than allowing it to continue while a decision is made.
2. Notify the competent authority of the contravention without unreasonable delay, since the statutory duty to notify is itself enforceable independent of the underlying defect.
3. Direct remediation works and confirm the corrected work now conforms to approved plans before allowing the activity to resume.
4. Document the discovery, the instruction to stop, the remediation, and the re-inspection in site records, since this documentation is what supports any future defense that reasonable steps were taken.

Pro Tip: Keep a dated site diary entry for every stop-work instruction, even minor ones. Regulators and insurers weigh documented, timely intervention far more heavily than a QP’s verbal assurance that “it was handled,” and a thin paper trail is the single most common weakness we see in enforcement cases.

How Many Site Supervisors Does a Project Need?

BCA does not leave staffing levels to guesswork. It publishes minimum site-supervisor counts, resident engineers (RE) and resident technical officers (RTO), tied to project value and construction phase, and QPs are expected to justify their staffing decisions against BCA’s Framework for Risk-based Inspection rather than treating the minimum table as a ceiling.

The exact staffing figure a project needs depends on complexity, not just contract value, which is why BCA’s risk-based framework exists at all. A high-value but structurally simple warehouse may need less supervision than a mid-value project involving deep excavation next to an MRT tunnel. QPs who want to reduce staffing below the standard tier need to justify that reduction against the risk framework and notify BCA accordingly, rather than simply deciding it internally.

Site supervisors themselves cannot be appointed informally. They must hold accreditation through the Joint Accreditation Committee of the Institution of Engineers Singapore and the Association of Consulting Engineers Singapore. Appointing an unaccredited supervisor for structural works is itself a compliance gap, independent of how well that person actually performs the role.

How Do QPs Prevent URA and BCA Plans From Diverging?

Plan mismatches between what URA approved for planning permission and what gets submitted to BCA for building plan approval are one of the most common, and most avoidable, sources of project delay. It happens when the design team revises drawings after planning approval, whether for cost, buildability, or client changes, without formally reconciling those revisions against the original URA submission before passing plans to the supervising QP or the BCA submission team.

The fix is procedural, not technical: the URA-approved plans have to be physically supplied to the supervising QP and cross-checked against the BCA submission set before construction begins. Treating this as optional, because “the changes are minor,” is exactly the assumption that produces expensive rectification orders later.

Conservation works carry an additional, specific requirement. Under Section 15(2)© of the Planning Act, a QP working on a conservation building must submit a distinct declaration at building plan submission, confirming that proposed works respect the conservation guidelines attached to that building, separate from standard structural or planning compliance. This is a narrower, more document-heavy process than standard new-build submissions, and it is where readers pursuing conservation works approval most often lose time to avoidable rework.

Practically, the coordination sequence looks like this:

• URA-approved plans get shared with the supervising QP and the BCA submission team before any building plan drafting starts.
• Annex A declaration forms, referenced in URA’s DC17-05 circular, accompany the notification of QP appointment or any change in appointment.
• For conservation buildings, the Section 15(2)© declaration accompanies the building plan submission itself, not a later stage.
• Any post-approval design revision triggers a fresh reconciliation against the original URA-approved plans before it reaches the contractor.

A closer look at BCA’s own role in the submission chain helps clarify why this handoff between authorities is where so many otherwise well-run projects lose weeks.

What Happens When a QP Is Replaced or Stops Acting?

Singapore’s regulatory framework treats QP appointment changes as a formal, time-bound event, not an internal HR matter. Under the Planning Act extracts governing these duties, a new QP appointment during the planning stage must be notified to URA within 7 days, and when a QP ceases to act altogether, whether by resignation, removal, or the end of an engagement, notification to URA or BCA is due within 14 days.

The outgoing QP carries an exit duty that project teams often overlook entirely: a declaration stating whether works had commenced during their appointment and, if so, confirming that whatever was built during that period complies with the approved plans. Skipping this step leaves a compliance gap that can surface much later, sometimes at TOP or CSC stage, when it is far more expensive to resolve.

What the exit process actually requires:

• Outgoing QP files a declaration covering the scope of works completed under their supervision and its compliance status.
• Developer appoints a replacement QP without a gap in coverage, since works generally cannot proceed legally without an appointed QP in place.
• The Annex A notification form is submitted to URA or BCA within the 14-day window, naming the incoming QP and confirming the transition.
• Incoming QP reviews site records, instrumentation logs, and prior declarations before assuming supervisory responsibility, rather than starting with a blank file.

Developers who treat this as paperwork rather than a legal handover are the ones who discover, months later, that a gap in QP coverage complicates their TOP application.

What Penalties Apply for Failing QP Duties?

Failing to notify, failing to supervise, or failing to submit required declarations are criminal offenses under both the Planning Act and the Building Control Act, not just administrative lapses that draw a warning letter. Penalties scale with the severity of the failure and can include substantial fines and, for the more serious breaches, imprisonment, particularly where the failure contributed to structural failure or a safety incident.

Singapore’s law does provide a statutory defense: a QP is not automatically liable if they can show they did not know, and could not reasonably have discovered, the non-compliance in question. That defense lives or dies on documentation. A QP who can produce dated site diaries, instrumentation logs, stop-work notices, and inspection records has a real basis to argue reasonable steps were taken. A QP who cannot produce that paper trail is relying on memory against a regulator’s enforcement file, which is not a position anyone wants to be in.

Practical risk mitigation for QPs and developers alike comes down to a short list of habits: insist on independent specialist certification for every alternative solution rather than in-house sign-off, keep contractual scopes between QP(D), QP(S), and site supervisors explicit so no duty falls into a gap between roles, retain site records well beyond project completion, and build in a routine cross-check between URA-approved plans and current BCA submissions at every major design revision. None of this is expensive compared to the cost of a stop-work order or a rectification instruction issued after TOP.

A Practical Checklist for QPs and Developers

Most compliance failures trace back to a missed step at a predictable point in the project, not a mysterious or novel problem. A short checklist at each stage closes most of that gap.

1. Before appointment: verify the QP’s practising certificate is current, confirm whether the scope requires a QP(D), a QP(S), or both, and lock in appointment before lodging any planning permission application.
2. At plan submission: confirm every declaration required by URA and BCA is signed and attached, and that an independent specialist has certified any alternative solution in the design.
3. During supervision: maintain a live site diary covering critical structural activities, keep instrumentation logs current against pre-set trigger levels, and document every stop-work instruction the moment it happens.
4. At handover or replacement: file the outgoing QP’s declaration of works completed, submit the Annex A notification within the statutory window, and brief the incoming QP against existing site records before they take over supervision.

Pro Tip: Build a single shared folder, accessible to the developer, the QP(D), and the QP(S), that holds every declaration, instrumentation log, and notification form from day one. The projects that struggle at TOP are almost always the ones where this documentation lived in three different inboxes.

Developers managing multiple concurrent submissions, structural, façade, and M&E, often find it faster to centralize authority submission management with a single consultancy rather than tracking each authority’s requirements independently, particularly on projects juggling URA, BCA, and SCDF timelines at once.

Why Strict QP Practice Protects Project Timelines

Most of the delayed TOP applications this industry sees trace back to the same two root causes: a plan submitted to BCA that quietly drifted from what URA approved months earlier, and a supervision gap where nobody caught a structural deviation until it was already cast in concrete. Neither failure looks dramatic in the moment. Both are expensive once discovered late.

Rigorous QP practice is not paperwork for its own sake. It is the mechanism that catches a plan mismatch in week three instead of week thirty, and that turns a potential stop-work order into a documented, minor correction. Developers who treat QP appointment and supervision as a continuous discipline, not a one-time filing, consistently see fewer rectification orders and cleaner TOP applications. That is the actual payoff of following qualified person compliance duties closely, and it is worth the discipline it demands.

— Aman

How Aectechnicalsg Supports QP and Submission Compliance

Some consultancies coordinate PE and QP endorsements, authority submissions, and RE/RTO supervision support under one engagement, helping to prevent plan-reconciliation and documentation gaps.

Our engagement flow starts with a scope check to confirm whether your project needs a QP(D), a QP(S), or both, followed by a documents review against URA and BCA requirements, then direct support through submission and, where needed, site supervision. That covers PE endorsement and authority submissions, statutory submissions across URA, BCA, SCDF, JTC, LTA, PUB, and NEA, and periodic structural and façade inspection work for buildings already in use. If your project is approaching a planning permission deadline or you need a QP appointment reconciled against an existing submission, review our full range of engineering and QP support services and get in touch to scope your project.

Where to Verify These Requirements Directly

Every duty described above traces back to a specific statute or circular, and it is worth reading the primary source before relying on a summary, including this one. URA’s DC17-05 circular and its statutory extract set out notification timelines and declaration duties in full. BCA’s page on site-supervisor requirements and risk-based inspection covers staffing tiers, and the 2008 amendment regulations detail instrumentation and site investigation obligations. Annex A notification templates are published within the URA circular itself.

Sources

• Amendments to Planning Act (Cap. 232) – Duties of Developers/ Property Owners and Qualified Persons | URA
• Building Control (Amendment) Regulations 2008 | BCA (pdf)

FAQ

What Are the Duties of a Qualified Person?

A Qualified Person must prepare plans that comply with planning and building guidelines, declare that compliance to URA and BCA, supervise construction to ensure it matches approved plans, and notify the relevant authority of any contravention without delay. These duties are set out in the Planning Act and Building Control Act and apply from appointment through project completion.

Who Is a Qualified Person in Singapore?

A Qualified Person is an architect or a registered professional engineer holding a valid practising certificate, appointed either to prepare plans (QP(D)) or to supervise construction (QP(S)). Appointment must occur before planning permission is sought or before building works begin.

What Is the Difference Between QP and PE?

A Professional Engineer (PE) is a registration status held by an engineer who has met examination and experience requirements under the Professional Engineers Act. A Qualified Person is a functional role, held by either an architect or a PE, that carries specific statutory duties for plan preparation or site supervision under the Planning Act and Building Control Act; not every PE acts as a QP on a given project.

What Are the Requirements to Become a Qualified Person?

An individual needs either a valid architect’s practising certificate or a valid professional engineer’s practising certificate to qualify as a QP under Singapore law. Beyond that base credential, appointment to a specific project requires the developer to formally notify URA or BCA within the statutory windows, generally 7 days for a new appointment and 14 days if a QP ceases to act.

Can the Same Person Be QP(D) and QP(S) on One Project?

Yes, the same architect or engineer can hold both roles on smaller or less complex projects, handling plan preparation and site supervision under a single appointment. Larger developments often split the roles between different professionals or firms to manage workload and specialization, which increases the coordination duties described in cross-authority plan reconciliation.

Recommended

• PE compliance in Singapore: what developers must know
• Singapore Building Owner Legal Obligations: Full Checklist
• PE Registration Requirements Singapore List: The Full Checklist
• Singapore PE Continuing Education Checklist for Renewal