The Control of Asbestos Regulations 2012 (CAR 2012) is the legal backbone of every asbestos project in Great Britain — it defines the duty to manage, licensing, notification, training and the clearance process that hands a building back safely. The HSE has now consulted on the first significant updates to how those regulations work in practice, with the consultation closing in January 2026. As an HSE-licensed contractor, we followed it closely — and we think the direction of travel is right.
The headline regulatory change: after licensed removal, the four-stage clearance analyst would be appointed independently of the removal contractor — by the client or duty-holder — removing any perceived conflict of interest in certifying an area safe for reoccupation. We welcome this without reservation. Our work is designed to pass a rigorous, independent clearance every time — an analyst with no commercial tie to us simply makes the certificate you receive stronger. It’s how confidence in the Certificate of Reoccupation should work.
The HSE also proposes to raise survey quality through improved guidance — making sure duty-holders understand what a competent survey involves and how to commission one. We see the consequences of poor surveys constantly: missed materials found mid-project, vague reports full of caveats, and refurbishments priced on incomplete information. A quality management or refurbishment survey is the foundation of every safe, accurately-priced asbestos project.
The third proposal clarifies what genuinely constitutes NNLW. The categories matter: licensed, NNLW and non-licensed work are legally distinct, and HSE research found higher-risk materials — including work on asbestos insulating board — being misclassified to avoid licensed contractors. Clearer boundaries protect building occupants and level the playing field for contractors who do it properly. If you’re unsure which category your material falls into, our guide to licensed vs non-licensed asbestos work explains the difference.
Nothing in CAR 2012 has changed yet — the HSE is analysing consultation responses. But the direction is clear: more independence, better surveys, tighter classification. Getting your asbestos register, management plan and survey information in order now means any regulatory change lands as a non-event. The full proposals are on the HSE consultation page.
