New consumer units are notifiable under Part P, even if they are a straight replacement - from the list of non notifiable work:
i.e. you can replace stuff, as long as it does not involve a new consumer unit. Your work is clearly involving a new consumer unit, so is therefore notifiable unfortunately...
1. Work consisting of -
(a) replacing any fixed electrical equipment which does
not include the provision of—
(i) any new fixed cabling; or
(ii) a consumer unit;
i.e. you can replace stuff, as long as it does not involve a new consumer unit. Your work is clearly involving a new consumer unit, so is therefore notifiable unfortunately...
