Does Your RTM Company Need a Building Safety Director?

TL;DR: Your RTM company is the Accountable Person for your higher-risk building. The Building Safety Act 2022 requires you to have competent people overseeing building safety -- but on a volunteer board, "everyone is responsible" quickly becomes "nobody is responsible." Designating a Building Safety Director gives the Building Safety Regulator a named, competent individual to point to. Here is what that role involves, who should take it on, and how to set it up properly.

#What Is a Building Safety Director?

The Building Safety Act 2022 does not create a statutory role called "Building Safety Director." You will not find that title in Part 4 of the Act. What the Act does require is that every Accountable Person has competent people managing building safety risks.

For RTM companies, the Accountable Person is the company itself -- the corporate entity that acquired the right to manage. But a company cannot assess risks, file reports, or liaise with the Building Safety Regulator. People do those things. The BSR expects you to name the individuals who are responsible, demonstrate their competence, and document their authority.

A Building Safety Director is the practical answer to that expectation. It is the director on your board who takes lead responsibility for BSA compliance -- not doing every task personally, but ensuring the right things happen, the right records are kept, and the right people are accountable when the BSR asks questions.

The duty to manage building safety risks sits with the Accountable Person. But within an organisation, the BSR expects to see named individuals with clear responsibilities and demonstrable competence.

-- BSR guidance on Accountable Person duties

This is different from the Building Safety Manager role, which was proposed during the passage of the Bill but removed from the final legislation. Some organisations use that title operationally, but it carries no statutory weight. For a detailed breakdown of the Accountable Person role, see Accountable Person duties under the Building Safety Act.

#When Does Your RTM Company Need One?

Not every RTM company has BSA obligations. The Act applies to higher-risk buildings in England:

• 18 metres or more in height, or 7 or more storeys, AND
• 2 or more residential units

If your building meets these criteria, your RTM company is the Accountable Person under section 72 of the BSA. In most RTM scenarios, the RTM company is also the Principal Accountable Person because it holds the management obligations for the common parts, including structure and exterior (see Accountable Person vs Principal Accountable Person for how to determine this).

There are over 12,300 active RTM companies registered at Companies House. Not all manage higher-risk buildings -- but those that do carry the full weight of BSA obligations. If your building qualifies, you need someone on your board who owns that responsibility.

Check if your building qualifies as higher-risk

#What if you have a managing agent?

Some RTM companies appoint managing agents to handle day-to-day operations. This does not transfer Accountable Person status. Your RTM company remains legally responsible. The managing agent acts on your behalf but does not assume your BSA duties.

This makes the Building Safety Director role even more important in RTM companies that use agents: someone on the board must oversee whether the agent is actually meeting your BSA obligations, not just managing repairs and service charges. For more on how RTM companies navigate BSA obligations generally, see RTM companies and the Building Safety Act.

#What Does a Building Safety Director Actually Do?

The role is about oversight, coordination, and accountability -- not doing every task personally. In practice, the Building Safety Director:

Owns the Safety Case. The safety case report is the central document demonstrating how your building's risks are identified, assessed, and managed. Someone must ensure it exists, stays current, and accurately reflects reality. That is the Building Safety Director.

Manages the mandatory occurrence reporting process. When a safety-related event occurs -- structural failure, fire spread risk, cladding issues -- the Accountable Person must report it to the BSR. The Building Safety Director ensures reporting procedures exist, the board knows when to trigger them, and reports are filed within the statutory timeframes.

Coordinates PEEPs and resident engagement. Personal Emergency Evacuation Plans for residents who need assistance during evacuation, plus the broader residents' engagement strategy under section 91. The Building Safety Director ensures these are in place, reviewed, and communicated.

Liaises with the BSR. When the BSR contacts your building -- inspection, information request, assessment -- the Building Safety Director is the named point of contact. They coordinate the response, gather evidence, and represent the RTM company.

Ensures the Golden Thread is maintained. The digital record of building safety information must be accurate, accessible, and up to date. The Building Safety Director ensures information flows into the system and nothing falls through the cracks.

Reports to the board and AGM. Regular updates on compliance status, upcoming deadlines, and outstanding actions. This keeps all directors informed and creates documented evidence of active governance.

Oversees contractor safety competence. When contractors work on fire safety systems, cladding, or structural elements, someone must verify their competence and check the evidence.

The key distinction: the Building Safety Director does not need to be the expert. They ensure expert work gets done, documented, and reviewed.

#The Competence Question

This is where most RTM directors get anxious. You are a volunteer. You might be an accountant, a teacher, or a retiree. The BSA is asking you to demonstrate competence in building safety management. What does that actually mean?

The BSR's competence framework does not require formal professional qualifications for Accountable Persons or their representatives. It requires demonstrable competence -- meaning you can show you understand:

• The regulatory framework: what the BSA requires of your building
• Your building's risk profile: what the specific hazards are (fire, structural, etc.)
• Your safety management systems: how risks are identified, assessed, managed, and recorded
• When to seek specialist help: knowing the limits of your knowledge and bringing in professionals

For volunteer directors taking on the Building Safety Director role, competence typically comes from a combination of:

Structured training. TPI, FPRA, and RICS all offer courses for building managers and Accountable Persons. The BSR also publishes free guidance on GOV.UK.

Self-directed learning. BSR guidance documents, industry webinars, and professional networks. The BSR covers each obligation in detail on its website.

Professional advisers. Fire risk assessors, structural engineers, building safety consultants. The Building Safety Director does not need to be the expert -- but they need to know when to bring experts in.

Document everything. The BSR will not test you with an exam. They will look at what training you have completed, what guidance you have read, what professional advice you have sought, and whether your decisions show an understanding of building safety principles. A training log, a reading list, and records of professional consultations build your competence evidence over time.

#What Happens Without One?

When no single director owns building safety, responsibility diffuses across the board. This creates three specific problems:

The "everyone's job is nobody's job" failure. Board minutes say "building safety discussed." But who is following up on the fire risk assessment actions? Who checked whether the contractor completed the compartmentation work? Who filed the mandatory occurrence report within the statutory deadline? When responsibility is shared equally, no one feels personally accountable for the outcome.

BSR enforcement becomes harder to defend. The BSR can issue compliance notices and contravention notices to Accountable Persons who fail to comply. When every director shares responsibility equally, demonstrating due diligence becomes harder. A designated Building Safety Director with documented competence is the strongest evidence your RTM company takes its obligations seriously. See Building Safety Act penalties for non-compliance for more on the enforcement framework.

Personal liability risk increases. Under company law, individual directors can face personal liability if the company commits an offence and the failure is attributable to their consent, connivance, or neglect. If no one was specifically responsible for building safety and something goes wrong, every director is potentially exposed. Designating a Building Safety Director -- with proper authority, resources, and documented activity -- actually protects the rest of the board by showing responsibility was allocated and actively managed.

The Building Safety Act 2025 update covers recent enforcement activity and the BSR's evolving approach to compliance assessment.

#How to Appoint a Building Safety Director

This does not require complex governance. It requires clarity and documentation.

#1. Board resolution

Pass a formal resolution at a board meeting (or by written resolution under your articles) appointing a named director as Building Safety Director. Record it in the minutes with the date, the director's name, and the scope of their authority.

#2. Define scope and authority

Document what the Building Safety Director is authorised to do:

• Engage fire risk assessors and building safety consultants within an agreed budget
• Submit mandatory occurrence reports to the BSR on behalf of the company
• Coordinate the residents' engagement strategy
• Access and maintain the building's safety records
• Report to the board at agreed intervals (monthly or quarterly)
• Escalate urgent safety issues to the full board without waiting for the next scheduled meeting

#3. Ensure adequate resources

The role needs time and budget. If the Building Safety Director is a volunteer, the board should acknowledge the time commitment (typically 5-10 hours per month for a single building) and authorise reasonable expenditure on training, professional advice, and safety management tools.

#4. Set up a reporting cadence

Monthly written updates to the board covering: compliance status, outstanding actions, upcoming deadlines, contractor activity, and any BSR correspondence. Quarterly presentation at board meetings for discussion and decision-making.

#5. Document competence development

Start a training log from day one. Record courses completed, guidance documents read, webinars attended, and professional advice received. This becomes your competence evidence for the BSR.

#Practical Next Steps

If your RTM company manages a higher-risk building and has not yet designated a Building Safety Director, here is what to do this month:

1. Confirm your building's HRB status. Use the building checker tool or check the BSR public register.

2. Identify a willing director. Someone organised, available, and willing to learn -- not necessarily the most technically knowledgeable person on the board.

3. Pass a board resolution. Use the checklist above.

4. Book initial training. TPI, FPRA, or a local BSA training provider. Even a single introductory course demonstrates you are building competence.

5. Audit your current safety records. Does your RTM company have a safety case? PEEPs? FRA action tracking? Identifying the gaps is the new Building Safety Director's first task.

6. Set up a compliance tracking system. The Building Safety Director needs a single place to track obligations, deadlines, and evidence.

The BSR does not expect perfection. It expects demonstrable effort and a clear structure for managing building safety. Appointing a Building Safety Director is the single most effective step an RTM board can take.