Building Plan Submission – By Architect or Engineer

Author: Ir. Dr. Justin LAI Woon Fatt | 30 March, 2025

With the enactment of the Certificate of Completion and Compliance (CCC) in 2007, the Principal Submitting Person (PSP) and Submitting Person (SP) were introduced as the party to issue CCC for buildings. The Uniform Building By-Laws (UBBL) 1984 defines the PSP and SP as the Qualified Person which includes Architect, Professional Engineer with Practising Certificate (PEPC), or Registered Building Draughtsman authorized in handling submission [1]. In general, the PSP/SP will handle submissions for different internal departments in Local Authority (LA) and External Technical Agencies (ETA). The table below outlines the type of submission handled by the respective architect and PEPC.

According to the Street, Drainage and Building Act 1974, “building plans” means plans that include site plans, key plans, floor plans, sections, and elevations as set out specifically in any by-laws made under this Act. A “submitting person” means a qualified person who submits plans other than building plans to the local authority or relevant statutory authority in accordance with this Act or any by-laws made thereunder and include any other qualified person who takes over the duties and responsibilities of or acts for the first mentioned qualified person. Meanwhile, a “qualified person” means an Architect, PEPC, or building draughtsman registered under any written law relating to the registration thereof [2].

In Malaysia, as in many other countries, there are legal and practical consequences for not appointing Architects and PEPC in the building industry, which includes but not limited to:

1. 1. 1. Legal violations of building codes, regulations, compliances and laws governing construction. This can lead to legal penalties, fines, or even project shutdowns.
      2. Higher risk of construction defects, structural failures, and safety hazards, potentially endangering the lives of occupants and workers.
      3. Higher likelihood of substandard workmanship, which can lead to costly repairs, delays, and dissatisfaction among stakeholders.
      4. Neglecting to appoint qualified professionals can lead to cost overruns due to rework, delays, and legal expenses. Additionally, subpar construction quality may affect property values and rental income, resulting in financial losses for developers and investors.
      5. Failing to adhere to industry standards and best practices can damage the reputation of construction companies, developers, and other stakeholders involved in the project. This can impact future business opportunities and relationships within the industry.

Submission of building plans are usually submitted by Architect except for factories, which can be submitted by PEPC. This also aligned with BEM Circular No. 009 dated 2nd June 2020 made by a Joint Committee between the Board of Architects Malaysia (BAM) and Board of Engineers Malaysia (BEM) concerning the submission of building plans by Architect and PEPC. The revised appendices in the Joint Memorandum are as follows:

Appendix A: No person shall submit any Building Plan, report and specification for the under-listed works and/or services, unless he is an Architect, except where any engineering work is required (excluding any standard engineering work), such engineering plan and specification shall be submitted by a Professional Engineer with Practising Certificate [3].

Figure 1: Submission of plans by Architect

Appendix B: No person shall submit any Building Plan, including Engineering Plan, report and specification for the underlisted works and/or services, unless he is a Professional Engineer with Practising Certificate, except where any architectural work is required, such architectural plan shall be submitted by an Architect [3].

Figure 2: Submission of plans by PEPC

Appendix C: No person shall submit any Building Plan, report and specification for the under-listed works and/or services unless he is either an Architect or a Professional Engineer with Practising Certificate, except where any building under Appendix A is included, the plan needs to be prepared by an Architect and where any building under Appendix B is included, the plan needs to be prepared by a Professional Engineer with Practising Certificate [3].

Figure 3: Submission of plans by Architect or PEPC

Form F, F1 and G1 – G21

Only the Principal Submitting Person (PSP) can sign Form F or F1 (refer table 2), and Form G1 – G21 (refer table 3) shall be signed by the Submitting Person (SP) of the project which is based on the appendices stated above, and components are to be in accordance with the tables below.

Conclusion

In Malaysia, the issuance of CCC is a responsibility that borne by a PSP. With reference to BEM Circular No. 009 in 2020, both Architect and PEPC can act as PSP to submit building plans where the work is under-listed according to Appendix A, B and C, and finally issue the Form F when the project is completed. Meanwhile, for G1-G21 forms, the SP shall bear responsibility for different components according to the scope of work.

Failure to appoint qualified architects and engineers in the building and construction industry in Malaysia can lead to a range of serious consequences, including legal liabilities, safety hazards, financial losses, and damage to the project’s reputation. It is crucial for all parties involved in construction projects to prioritize the engagement of qualified professionals to ensure compliance, safeguard public welfare, and ensure the timely and successful completion of the project.

Ir. Dr. Justin LAI Woon Fatt
CEO/ Founder
IPM Group