The BSR began calling buildings in for Building Assessment Certificate applications in April 2024, starting with the highest-risk buildings. The pace is increasing. As the BSR works through the registered building stock, more buildings are receiving call-in notices each quarter.
The Building Safety Regulator assesses whether the Principal Accountable Person has identified all building safety risks and taken reasonable steps to manage them before issuing a Building Assessment Certificate.>
— Building Safety Act 2022, s.91
This is not a distant regulatory exercise. If your building is registered with the BSR as a higher-risk building under section 78 of the Building Safety Act, the question is when your building will be called in, not whether.
The BSR is prioritising buildings based on risk factors:
Understanding the process removes the uncertainty. Here is how the BSR assessment works, step by step.
The BSR sends a formal notice to the principal accountable person (PAP) for your building. This notice states that you must apply for a Building Assessment Certificate within 28 days.
The 28-day clock starts from the date of the notice, not the date you receive it. If there is any delay in the notice reaching you -- because the PAP's contact details on the BSR register are out of date, for example -- the deadline does not move.
Action: Ensure your contact details on the BSR register are current. If the PAP has changed, update the registration immediately.Your application must demonstrate that you are complying with your duties under Part 4 of the Building Safety Act. This is not a questionnaire or a self-declaration. It is a substantive submission with supporting evidence.
The application requires:
| Area | What the BSR wants to see | |------|--------------------------| | Safety Case Report | Current, reviewed within the last 12 months, reflects actual building condition | | Golden Thread records | Accessible, version-controlled, complete Key Building Information under s.88 | | Residents' engagement strategy | Evidence of active engagement under s.91, not just a policy document | | Mandatory occurrence reporting | Functioning system with evidence of reports submitted and processes followed | | Fire risk assessment actions | Every action tracked, assigned, and evidenced -- with status (complete, in progress, overdue) | | Competence evidence | Qualifications, training records, contractor competence assessments |
For a detailed document checklist, see our Building Assessment Certificate preparation guide.
This is where the BSR assessment differs from many regulatory processes. The BSR does not simply check whether you have submitted the required documents. It evaluates whether your safety management systems are genuinely functioning.
The BSR reviewers will look for:
The BSR either:
The assessment is fundamentally about one question: is this building being managed safely?
Operating a higher-risk building without a valid Building Assessment Certificate after being called in for assessment is a criminal offence carrying an unlimited fine.>
— Building Safety Act 2022, s.98
The BSR is not looking for perfection. Every building has some overdue actions, some areas where records could be more complete, some processes that could be tighter. What the BSR is looking for is evidence of active, structured safety management -- a building where problems are identified, tracked, and addressed, even if some are still in progress.
Consider two buildings, both with 35 fire risk assessment actions.
Building A has 30 actions complete with evidence (photographs, contractor certificates, sign-off records), 3 in progress with contractors assigned and expected completion dates, and 2 overdue with documented escalation -- the building manager has recorded why they are overdue, what interim measures are in place, and the revised timeline. The Safety Case Report was last reviewed 4 months ago and reflects the current position. Building B has a spreadsheet listing 35 actions. Some are marked "done" with no evidence. Some have no assignee. The overdue actions have no escalation record. The Safety Case Report was prepared 18 months ago for the registration process and has not been reviewed since.Both buildings have outstanding actions. But Building A demonstrates active management. Building B demonstrates a compliance gap.
See how Brocade helps you track every action with evidence and audit trails -->You are the PAP for a 20-storey residential building with 84 flats. You registered the building with the BSR in 2023. In March 2026, you receive a call-in notice.
If you have been managing proactively:Your Safety Case Report was last reviewed in January 2026 after your annual fire risk assessment. You update it to incorporate a minor change -- new fire stopping work completed in February. Your Golden Thread records are held digitally with version history. You export the required information and verify completeness against the BSR's published checklist.
Your residents' engagement strategy has been active since registration. You compile: four building safety newsletters sent to residents, three complaints received and resolved (with response records), and minutes from the annual building safety meeting. Your occurrence reporting system has processed one report -- a fire door closer failure -- submitted to the BSR within the statutory timeframe.
Your fire risk assessment has 42 actions. 37 are complete with evidence. 4 are in progress with contractors assigned. 1 is overdue by 3 weeks -- the contractor was delayed, you have documented the reason, notified the fire risk assessor, and implemented an interim measure (additional fire safety signage and a temporary manual check).
You submit on day 18, leaving a buffer. The submission is not flawless, but it tells a clear story of active management.
If you have not been managing proactively:You receive the call-in letter and realise your Safety Case Report has not been updated since registration. Your fire risk assessment actions are in a spreadsheet with no evidence attached. You have a residents' engagement strategy document, but no evidence of implementation. You have 28 days to pull together what should have been maintained continuously.
This is why preparation matters. The assessment tests ongoing management, not last-minute assembly.
Do not wait for the call-in letter. These are the areas to get right now.
The Building Assessment Certificate application must include a copy of the safety case report, details of the safety measures in place, and evidence that mandatory occurrence reporting processes are operational.
Keep it current. Review it after every fire risk assessment, every significant building work, and at least annually. The BSR will check when it was last reviewed.
For guidance on preparing your Safety Case Report, see the Safety Case Report guide and our overview of what a building safety case involves.
Your Key Building Information under section 88 must be accessible, accurate, and version-controlled. The BSR expects digital records with audit trails showing when information was created, modified, and by whom.
Ensure you have: structural and fire safety drawings, fire safety system specifications and maintenance records, fire risk assessment records with full action tracking, records of all building work since registration, and a clear version history.
See the Golden Thread guide for the complete information requirements.
Under section 91, you need an active strategy -- not just a document. The BSR will look for evidence of:
Your mandatory occurrence reporting system needs to be documented and demonstrably active. If you have submitted occurrence reports, have the records ready. If you have not had any reportable occurrences, document your system: training records, escalation procedures, the process for identifying reportable events.
A building with zero reports over several years may prompt the BSR to question whether the system is genuinely capturing events.
Every action from your fire risk assessment should be:
Document the qualifications, training, and professional development of everyone involved in managing building safety -- including yourself, any Building Safety Manager, fire safety advisors, and key contractors.
{/ TODO: June W2 editorial calendar -- link to BSR Assessment Outcomes article when published /}
The BSR assessment process is the procedure by which the Building Safety Regulator evaluates whether the principal accountable person for a higher-risk building is complying with their duties under Part 4 of the Building Safety Act 2022. The BSR calls buildings in for assessment in priority order, and the principal accountable person has 28 days from the call-in notice to submit an application for a Building Assessment Certificate under section 79 of the Act.
The BSR evaluates your Safety Case Report, Golden Thread records (Key Building Information under section 88), residents' engagement strategy, mandatory occurrence reporting system, fire risk assessment action tracking, competence evidence for building safety personnel, and financial provision for safety-related works. The assessment is substantive -- the BSR reviews whether these systems are functioning, not just whether documents exist.
You have 28 days from receiving a call-in notice to submit your Building Assessment Certificate application. The BSR's review period after submission is not fixed by statute, but the regulator has indicated it aims to process applications within a reasonable timeframe. The total time from call-in to certificate issuance depends on the quality of your submission and whether the BSR requests additional information.
If the BSR is not satisfied with your application, it can refuse the Building Assessment Certificate. The BSR may issue a compliance notice under section 97 requiring specific improvements, a contravention notice under section 99 for active breaches, or require you to reapply after addressing identified issues. Continued non-compliance can lead to enforcement action including prohibition notices and prosecution.
Preparation means maintaining your compliance systems year-round, not scrambling when the call-in letter arrives. Keep your Safety Case Report current, maintain your Golden Thread records with version history, operate your residents' engagement strategy actively, ensure your mandatory occurrence reporting system is functioning, track every fire risk assessment action with evidence, and document competence for all safety-related personnel. The 28-day application window is a documentation exercise if your systems are already working.
The Building Safety Levy is a financial charge on developers who seek building control approval for certain types of residential building work in England. It is established under Part 4 of the Building Safety Act 2022 (sections 57 to 71) and collected by the Building Safety Regulator (BSR).
The Building Safety Levy is a charge on developers of new higher-risk buildings in England, intended to fund the remediation of historical building safety defects across the housing stock.
The purpose is straightforward: developers who profit from building new homes contribute to the cost of fixing historical safety defects in existing buildings. The levy revenue is paid into the Building Safety Fund, which finances remediation works -- primarily cladding and fire safety defect remediation -- in higher-risk buildings across England.
The levy sits within a broader remediation funding landscape that includes the developer self-remediation contracts (where major developers have committed to fixing life-critical defects in buildings they developed), the Building Safety Fund for non-developer-responsible buildings, and leaseholder protections under Schedule 8 of the Building Safety Act.
The Building Safety Levy applies to developers seeking building control approval for new higher-risk buildings. Existing building managers are not directly liable for the levy, but may see its effects in construction costs and service charge implications.
The levy is charged to developers -- specifically, those seeking building control approval for prescribed building work in England. You do not pay the levy as a building manager, accountable person, or leaseholder.
The government's 2023 consultation proposed that the levy would apply to:
The consultation proposed exemptions or reduced rates for:
The levy amount will be determined by regulations setting out the methodology. The government's consultation proposed a calculation based on the number and type of new dwellings created by the development, with rates varying by location to reflect regional differences in development economics.
This is not a flat fee. A 200-unit development in central London would pay a different levy amount than a 20-unit scheme in a regional town. The intention is to raise significant revenue without making development unviable.
If the levy is charged to developers, why does it matter to you as a building manager? Three reasons.
If your building has historical fire safety defects -- defective cladding, missing fire stopping, inadequate compartmentation -- the Building Safety Fund may be the mechanism that pays for remediation. The levy is one of the funding streams that keeps the Building Safety Fund operating.
Understanding the levy timeline helps you understand the remediation funding timeline. If your building is awaiting a Building Safety Fund decision, the levy's launch in October 2026 signals that the government expects the remediation programme to continue for years, with ongoing funding.
For building managers, this means:
If you manage buildings in developments where new phases are being built alongside existing occupied buildings, the levy could affect development economics. Developers may:
Even where the Building Safety Fund covers the cost of major remediation, the building manager often needs to manage:
The relationship between safety obligations and financial management is where complexity lives. A building manager who tracks fire risk assessment actions but not the associated costs, or who manages remediation contractors but not the Section 20 consultation timeline, is managing only half the picture.
See how Brocade connects compliance tracking with service charge management -->You manage a 12-storey residential building with 60 flats, built in 2005. A building survey has identified defective fire stopping in service risers and combustible insulation in the external wall system. The estimated remediation cost is 1.8 million pounds.
Your building has applied to the Building Safety Fund. The application is under review. In the meantime, you have implemented interim safety measures: enhanced fire patrols, a waking watch for three months (now replaced by a common alarm system), and temporary fire stopping in the most critical locations.
The Building Safety Fund approves your application and covers 1.5 million pounds of the remediation cost. The remaining 300,000 pounds -- covering project management, interim measures already incurred, and works the Fund considers outside scope -- falls on the service charge.
With 60 leaseholders, that is 5,000 pounds per leaseholder. This exceeds the Section 20 threshold of 250 pounds, so you must run a full consultation before you can recover these costs. You need to track:
The Building Safety Levy does not operate in isolation. It is one piece of the government's remediation funding strategy.
Over 50 major developers have signed the government's remediation contract, committing to fix life-critical fire safety defects in buildings over 11 metres that they developed. These developers fund remediation directly -- the Building Safety Fund and the levy are not involved.
If your building was developed by a contract signatory, the developer should be funding the remediation. If the developer is not fulfilling its commitments, the BSR can use enforcement powers.
The Building Safety Fund covers remediation costs for buildings where the original developer cannot be identified, has become insolvent, or is otherwise not funding the work. The levy is one of the funding streams for this programme.
The interaction between leaseholder protections, Building Safety Fund contributions, and service charge obligations is another area where compliance and financial management must work together. Tracking which costs are recoverable, which are protected, and which require consultation is essential -- and this is exactly the kind of complexity that breaks down in spreadsheets.
Even though the levy does not directly charge building managers, there are practical steps to take now.
If your building has potential fire safety defects, understand where you stand:
If remediation costs (even partial) may fall on the service charge:
Remediation programmes generate both safety obligations and financial obligations. Tracking them separately -- safety in one system, costs in another -- creates gaps. When the BSR assesses your Building Assessment Certificate application, they will look at your safety management. When leaseholders challenge costs at tribunal, they will look at your financial management. Both need to be in order.
Brocade connects compliance tracking with service charge management, so you can see the safety status and cost status of every action in one place. When a fire risk assessment action triggers remediation, you can track the contractor, the cost, the Section 20 consultation, and the service charge demand alongside the compliance record.The levy rates, exemptions, and collection mechanism will be set by regulations before October 2026. Monitor GOV.UK announcements and BSR communications for updates.
The Building Safety Levy is a charge on developers seeking building control approval for certain higher-risk building work in England. It is established under Part 4 of the Building Safety Act 2022 (sections 57 to 71) and is intended to fund the remediation of historical building safety defects. The levy is collected by the Building Safety Regulator and paid into the Building Safety Fund.
The Building Safety Levy is expected to launch in October 2026, subject to secondary legislation setting the levy rates and collection mechanism. The government consulted on the levy design in 2023 and is expected to publish final regulations before launch.
The levy is charged to developers, not directly to building managers or leaseholders. However, developers may factor levy costs into new-build pricing, which could indirectly affect purchase prices and ground rents. For existing buildings, the levy itself does not create a new service charge liability. However, remediation works funded by the Building Safety Fund -- which the levy finances -- may still trigger Section 20 consultation requirements when costs are passed through service charges.
No. The levy applies to developers seeking building control approval for prescribed building work in England. The government has indicated that the levy will apply to residential developments that create new dwellings and certain mixed-use developments. Exemptions and reduced rates may apply to affordable housing, community-led housing, and certain regeneration projects. Final details will be set by regulations.
The levy sits alongside the developer self-remediation programme. Major developers who signed the remediation contract have committed to fixing life-critical fire safety defects in buildings they developed. The levy provides an additional funding mechanism by charging developers who are building new residential properties, creating a broader contribution to remediation costs across the industry.
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A higher-risk building under the Building Safety Act 2022 must be at least 18 metres in height or at least 7 storeys tall, contain at least two residential units, and be located in England.>
— Building Safety Act 2022, Part 4
A higher-risk building is a residential building in England that is at least 18 metres tall or has at least 7 storeys, and contains at least two residential units. This definition, set out in section 65 of the Building Safety Act 2022, determines which buildings fall under the full Part 4 safety regime including registration, Accountable Person duties, and the Golden Thread.
Section 65 of the Building Safety Act 2022 gives the Secretary of State power to define higher-risk buildings by regulations. The Higher-Risk Buildings (Descriptions and Supplementary Provisions) Regulations 2023 set out the specific criteria:A building is a higher-risk building if it:
The measurement matters because a building near the threshold could fall in or out of the regime depending on how you measure it. The Regulations specify:
The 7-storey threshold is an alternative to the 18-metre test -- a building qualifies if it meets either criterion. When counting storeys:
Many higher-risk buildings are not purely residential. A common configuration in urban areas is commercial on the ground floor (retail, offices, restaurants) with residential above. The key question is whether the building contains at least two residential units.
If it does, the entire building is subject to the higher-risk building regime -- including the commercial portions. The Accountable Person duties apply to the common parts of the whole building, not just the residential section.
This creates an important obligation for building managers: commercial leaseholders may not be directly subject to the Building Safety Act, but the building's safety arrangements must account for the risks their operations create (cooking extraction, waste storage, public access) and how those risks interact with the residential portions.
A building can also lose its higher-risk status. If a building is converted so that it no longer contains at least two residential units -- for example, conversion to a hotel or office use -- it would no longer meet the definition. Similarly, if structural changes reduce the building below 7 storeys and 18 metres, the regime would cease to apply.
Building height is measured from ground level to the floor surface of the top storey, not to the roof. This measurement method is prescribed in the regulations and determines whether a building falls within scope.
However, conversion is rare for buildings of this scale, and the PAP should not assume the regime will cease to apply without confirming with the BSR. De-registration requires notifying the BSR and providing evidence that the building no longer meets the criteria.
If your building is a higher-risk building, it must be registered with the Building Safety Regulator. Registration is the Principal Accountable Person's responsibility under section 77.
Higher-risk building status triggers the full Building Safety Act Part 4 regime: mandatory registration, Accountable Person duties, Golden Thread requirements, Safety Case Reports, and Building Assessment Certificates.
The BSR required all existing higher-risk buildings to be registered by 1 October 2023. If your building is not yet registered, treat this as urgent -- failure to register is itself a compliance breach.
For buildings that have been newly built or have newly qualified (for example, through change of use or additional storeys), registration must happen before the building is occupied or as soon as reasonably practicable after the change.
Registration requires providing the BSR with Key Building Information (KBI), including:
For a comparison of who is responsible for registration versus other duties, see our article on Accountable Person vs Principal Accountable Person.
Once your building is classified as higher-risk and registered, the full Part 4 obligations of the Building Safety Act apply. This section summarises what that means for day-to-day management.
Every higher-risk building must have at least one Accountable Person and a designated Principal Accountable Person. The AP is anyone holding a legal estate in the building's common parts or with a repairing obligation. The PAP is the AP who holds the legal estate in the structure and exterior -- typically the freeholder.
For a detailed breakdown of these roles and their duties, see our AP duties explainer and PAP responsibilities guide.
The Golden Thread is the complete, accurate, digital record of all building safety information. For higher-risk buildings, maintaining the Golden Thread is a legal requirement under section 88 and the Higher-Risk Buildings (Keeping and Provision of Information) Regulations 2024.
This includes structural records, fire safety system documentation, maintenance histories, contractor certifications, risk assessment findings, and records of remediation work. The records must be digital, up to date, and accessible to relevant persons.
The BSR will call in higher-risk buildings for assessment over time. When called, the PAP has 28 days to apply for a Building Assessment Certificate (BAC) under section 78. The BAC assessment evaluates whether the building is being managed safely and whether the PAP is fulfilling their obligations.
Preparing a Safety Case Report in advance is one of the most important steps for BAC readiness, as it forms a core part of what the BSR evaluates.
Higher-risk buildings are subject to mandatory occurrence reporting under section 87. Certain safety events -- structural failures, fire spread beyond the room of origin, failure of fire safety systems -- must be reported to the BSR as soon as they are identified, with a written report following within 10 working days.
The higher-risk building classification also has financial management implications. Service charges for higher-risk buildings must account for compliance costs -- risk assessments, Golden Thread maintenance, specialist contractors, BSR engagement, and Safety Case Report preparation. These are not discretionary expenses; they are costs of meeting your legal obligations. A building safety compliance platform can help you track these obligations systematically and demonstrate compliance when the BSR calls your building in for assessment.
For buildings subject to section 20 consultation requirements, major safety works may trigger leaseholder consultation. Understanding the intersection of building safety obligations and service charge law is essential for transparent financial management.
Consider Maple Court, a residential building that appears to have 6 storeys above ground. The managing agent has assumed it falls outside the higher-risk regime. But on closer inspection:
This scenario is common. Many buildings near the threshold are borderline. If your building is close to 18 metres or 7 storeys, measure carefully using the statutory method. Getting it wrong in either direction is problematic: treating a qualifying building as exempt means you are not meeting your legal obligations, while treating a non-qualifying building as higher-risk wastes resources on obligations that do not apply.
A higher-risk building is a building in England that is at least 18 metres in height or has at least 7 storeys, and contains at least two residential units. This definition is set out in section 65 of the Building Safety Act 2022 and further specified in the Higher-Risk Buildings (Descriptions and Supplementary Provisions) Regulations 2023.
Building height is measured from ground level to the top of the floor surface of the highest storey of the building. Ground level means the lowest level of ground adjacent to the outside of the building. This measurement method is specified in the Higher-Risk Buildings (Descriptions and Supplementary Provisions) Regulations 2023 and differs from some other measurement conventions used in planning.
Yes. All higher-risk buildings must be registered with the Building Safety Regulator (BSR). The initial registration deadline was 1 October 2023. The Principal Accountable Person is responsible for registration under section 77 of the Building Safety Act. Any building that newly qualifies as higher-risk must be registered promptly.
Yes, if the building meets the height or storey threshold and contains at least two residential units. A building with commercial units on the ground floor and residential flats above still qualifies if it is at least 18 metres tall or has at least 7 storeys. The residential units trigger the regime; the presence of commercial space does not exempt the building.
Higher-risk buildings are subject to Part 4 of the Building Safety Act 2022, which includes: registration with the BSR, designation of Accountable Persons, the Building Assessment Certificate process, mandatory occurrence reporting, the Golden Thread of building information, Safety Case Reports, and residents' engagement strategies. These obligations do not apply to buildings below the height and storey thresholds.
The Building Safety Act 2022 created a clear chain of accountability for every higher-risk building in England. Before the Act, building safety responsibility was often fragmented across freeholders, managing agents, and management companies -- with no one person or organisation clearly answerable when things went wrong.
The Act fixes this by defining two specific roles: the Accountable Person and the Principal Accountable Person. These are not interchangeable labels. Each carries distinct legal obligations, and getting confused about which role you hold can mean either doing too little (and facing enforcement) or duplicating effort that belongs to someone else.
This article explains who holds each role, what each role requires, and how the two work together. For a deeper look at AP duties specifically, see our Accountable Person duties explainer. For full PAP responsibilities, see the PAP responsibilities guide.
Under section 72 of the Building Safety Act, you are an Accountable Person if you:
The Accountable Person is defined in section 72 of the Building Safety Act as any person who holds a legal estate in possession in the common parts of a higher-risk building, or who has a repairing obligation for those common parts.>
— Building Safety Act 2022, s.72
A building can have multiple APs. The freeholder might hold the legal estate in the structure and exterior, while a management company has a repairing obligation for internal common areas. Both are Accountable Persons with independent legal duties.
The PAP is the specific Accountable Person who holds the legal estate in possession in the structure and exterior of the building, as defined in section 73.
The Principal Accountable Person is the Accountable Person who holds the legal estate in the structure and exterior of the building, and they carry the primary legal responsibility for building safety compliance.>
— Building Safety Act 2022, s.73
In most buildings, this is the freeholder. But there are important nuances:
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This is the core question building managers ask: "What am I actually required to do?" The answer depends on which role you hold. The table below shows which duties fall on every AP and which are additional PAP-only responsibilities.
| Duty | Accountable Person (AP) | Principal Accountable Person (PAP) | |------|:-----------------------:|:----------------------------------:| | Assess building safety risks (s.83) | Yes -- for your part of the building | Yes -- for your part of the building | | Take all reasonable steps to prevent major incidents (s.84) | Yes | Yes | | Maintain the Golden Thread (s.88) | Yes -- for your part | Yes -- overall responsibility | | Report safety occurrences (s.87) | Yes | Yes | | Cooperate with other APs (s.72, s.74) | Yes | Yes -- plus duty to coordinate | | Register the building with the BSR (s.77) | No | PAP only | | Apply for Building Assessment Certificate (s.78) | No | PAP only | | Prepare the Safety Case Report (s.85) | Contribute information | PAP leads preparation | | Prepare residents' engagement strategy (s.91) | Contribute | PAP leads | | Establish complaints system (s.93) | No | PAP only | | Designate individual contact for BSR (s.74) | No | PAP only (when PAP is an organisation) |
The pattern is clear: every AP has safety duties for their part of the building. The PAP has those same duties plus the coordination, registration, and reporting duties that apply to the building as a whole.
See how Brocade helps accountable persons track complianceConsider Lakeside Tower, a 14-storey residential building with 72 flats. The ownership structure creates two Accountable Persons:
Neither can assume the other is handling everything. If the RMC identifies damaged fire stopping in a corridor riser that penetrates the structural wall, it must report this to the PAP -- because the structural element falls under the PAP's responsibility. The PAP cannot claim ignorance if the RMC raised the issue and the PAP failed to act.
This cooperation duty is not theoretical. The BSR will assess whether APs have effective arrangements for sharing information and coordinating safety management. A building where the freeholder and management company operate in silos is a building with compliance gaps.
You may encounter the term Building Safety Manager (BSM) in industry discussions, training materials, or even in your own organisation's structure. It is worth understanding what this role is -- and what it is not.
The BSM role was proposed during the passage of the Building Safety Bill as a statutory role sitting between the AP and the BSR. The intention was for building owners to appoint a named, competent individual responsible for day-to-day safety management.
The BSM role was removed from the final Act. It does not appear in the Building Safety Act 2022 as enacted. There is no statutory requirement to appoint a Building Safety Manager.That said, many building owners and management companies use the BSM title operationally. They appoint someone -- often a building manager, facilities manager, or specialist consultant -- to coordinate building safety activities on a day-to-day basis. This is good practice and may help demonstrate that you are taking "all reasonable steps" to manage safety.
But the BSM (however titled) is not an Accountable Person or PAP unless they independently meet the criteria under sections 72 or 73. Appointing a BSM does not transfer or reduce the legal responsibilities of the AP or PAP. The AP or PAP remains legally answerable for building safety, and the BSM acts on their behalf.
Building managers frequently make these mistakes when trying to work out their responsibilities. Each one can leave compliance gaps.
Mistake 1: "Our managing agent is the Accountable Person." A managing agent does not hold a legal estate in the building. They act on the owner's behalf. The freeholder or other legal estate holder remains the AP. The agent may carry out AP functions, but the legal duty stays with the estate holder. Mistake 2: "We only have one person responsible, so the AP/PAP distinction does not matter." If your building has only one AP, you are automatically the PAP. This means you carry all duties -- both the shared AP duties and the PAP-only duties like registration and the Safety Case Report. The distinction still matters because it tells you the full scope of what is required. Mistake 3: "The RTM company took over, so the freeholder is no longer involved." The freeholder remains the PAP. Right to Manage transfers management functions, not the legal estate in the structure and exterior. The freeholder must still register the building, prepare the Safety Case Report, and coordinate with the RTM company on safety matters. Mistake 4: "Our Building Safety Manager handles all of this." The BSM is not a statutory role. Appointing one does not transfer AP or PAP duties. The AP/PAP remains legally responsible regardless of internal management arrangements.For the complete guide to PAP identification across different ownership structures, including RTM, RMC, and complex multi-AP buildings, see our PAP responsibilities guide.
In some buildings, the ownership structure makes AP and PAP identification genuinely difficult. Complex head lease arrangements, disputes about the legal estate, or buildings where the freehold has changed hands without proper notification can all create uncertainty.
If you are unsure whether you are an AP or PAP:
For a comprehensive overview of the Building Safety Act and all its requirements, see our Building Safety Act Complete Guide.
An Accountable Person (AP) is anyone who holds a legal estate in a higher-risk building's common parts or has a repairing obligation for them, as defined in section 72 of the Building Safety Act 2022. The Principal Accountable Person (PAP) is the specific AP who holds the legal estate in the building's structure and exterior, under section 73. Every higher-risk building has at least one AP, and one AP is always designated the PAP.
Yes. A building can have multiple Accountable Persons if different parties hold legal estates in different common parts or have separate repairing obligations. For example, a freeholder may be the AP for the structure and exterior while a Resident Management Company is a separate AP for internal corridors and lobbies. The AP who holds the legal estate in the structure and exterior is the Principal Accountable Person.
The PAP has all the duties of an AP plus additional responsibilities: registering the building with the Building Safety Regulator, applying for a Building Assessment Certificate when called, coordinating safety management across all APs, preparing the Safety Case Report, and establishing the residents' engagement strategy and complaints system. These additional duties are set out in sections 77, 78, 85, 91, and 93 of the Building Safety Act 2022.
No. The Building Safety Manager (BSM) role was proposed during the passage of the Building Safety Bill but was removed from the final Act. It is not a statutory role. Some organisations use the title operationally for the person who coordinates building safety activities, but that individual is not an Accountable Person or PAP unless they independently meet the legal criteria under sections 72 or 73.
Cooperation between APs is a legal duty under sections 72 and 74 of the Building Safety Act 2022. If APs fail to cooperate, the Building Safety Regulator can take enforcement action. Gaps in safety management caused by poor coordination could give rise to a risk of death or serious injury, which is a criminal offence under section 101. The PAP has a specific duty to take all reasonable steps to ensure cooperation.
The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 came into force on 6 April 2026. If your higher-risk building doesn't yet have Personal Emergency Evacuation Plans in place, you are technically non-compliant.
Fire and Rescue Authorities assess whether the Responsible Person is taking reasonable steps toward PEEPs compliance. A building that missed the deadline but shows active progress is in a fundamentally different position from one that has done nothing.>
— Fire Safety (Residential Evacuation Plans) Regulations 2025
Here's what that means in practice: Fire and Rescue Authorities enforce PEEPs under the Regulatory Reform (Fire Safety) Order 2005. They have the power to inspect your building, review your processes, and issue enforcement notices. But enforcement is not a cliff edge. Authorities assess whether the Responsible Person is taking reasonable steps — and that distinction matters.
A building that missed the deadline but has letters sent, assessments scheduled, and plans being drafted is in a fundamentally different position from one that has done nothing.
The plan below gets you from zero to demonstrable compliance in four weeks.
Your first priority is evidence of action. By the end of this week, you should have written to every resident in the building.
The regulations require "reasonable endeavours" to identify residents who need evacuation assistance. A single unanswered letter may not meet that bar — documented follow-up attempts are essential.Send identification letters immediately. Write to every household asking whether anyone may need help evacuating in an emergency. Be specific — don't ask "do you need assistance?" Ask concrete questions: "Can you independently descend the stairs to ground level if the lift is unavailable?" "Would you hear a fire alarm from inside your flat with the door closed?" Cover all relevant circumstances. The regulations cover residents with mobility impairments, sensory impairments, cognitive conditions affecting emergency response, and temporary conditions such as pregnancy or recovery from surgery. Record everything. Log the date each letter was sent, the method of delivery, and the flat number. This is your first piece of compliance evidence. If the Fire and Rescue Authority inspects next week, you can show letters went out on a specific date. Follow up non-responses. If you don't hear back within five days, send a second letter or try an alternative contact method — a door knock, a phone call, or a message through your building management app. Record every attempt. The regulations require "reasonable endeavours," and a single unanswered letter may not meet that bar.
For every resident who identifies as needing assistance, arrange a person-centred fire risk assessment (PCFRA).
Book assessments now. Contact each identified resident to schedule a face-to-face assessment. If you have a fire risk assessor on contract, brief them on the PCFRA requirements — these are different from a standard fire risk assessment. Assess individually. Each PCFRA must consider the resident's specific needs, their flat's location relative to escape routes, available equipment such as evacuation chairs or refuge points, and the building's evacuation strategy. A generic assessment applied to multiple residents is not compliant. Handle refusals properly. Residents can decline to participate at any stage. If someone refuses, record the date, their decision, and keep the record on file. You still have a duty to consider general evacuation provisions for that resident, but you cannot compel engagement. Read the full PEEPs implementation guide →With assessments complete, create an individualised PEEP for each resident.
Each plan must be tailored. A template with a name swapped in is not compliant. Each PEEP should specify the resident's evacuation method (assisted descent, horizontal evacuation to a refuge, evacuation lift), equipment required (evacuation chair, carry sheet, visual or vibrating alert), who will assist, how the resident will be alerted, and how often the plan will be tested. Get resident agreement. The regulations require resident consent at every stage, including whether they agree with their evacuation statement and whether they consent to their information being shared with the Fire and Rescue Authority. Document this agreement — a signature and date on the plan, or a recorded confirmation. Store plans accessibly. Plans need to be available to anyone who might need them in an emergency — the building's fire warden, concierge staff, or a visiting firefighter. If your building has a secure information box, place a copy of the building emergency evacuation plan inside it.Fire and Rescue Authorities have indicated that PEEPs compliance is an early enforcement priority. If an inspector arrives while you're mid-way through this plan, here's what matters:
Prosecution is not the first enforcement step for PEEPs non-compliance. Fire and Rescue Authorities typically begin with informal advice, then enforcement notices, before escalating to prosecution under the Fire Safety Order.Show your evidence trail. Dated letters, a response log, booked assessment appointments, draft plans in progress. Each piece demonstrates that you're actively working toward compliance, not ignoring your obligations. Understand the enforcement ladder. Prosecution is not the first step. The typical sequence is:
Yes. Fire and Rescue Authorities will assess whether you are taking reasonable steps toward compliance. A building that missed the deadline but can show active progress — letters sent, assessments booked, plans being drafted — is in a far stronger position than one that has done nothing.
Prosecution is not the first step. Fire and Rescue Authorities typically begin with an enforcement notice, which gives you a set timeframe to take specific actions. Prosecution under Articles 30 and 32 of the Fire Safety Order follows only if you ignore the enforcement notice.
Keep dated copies of every resident letter, response log, refusal record, completed person-centred fire risk assessment, and PEEP document. Record who conducted each assessment and when. If the Fire and Rescue Authority inspects, this evidence trail demonstrates active management.
The regulations require you to use "reasonable endeavours" to identify residents who need assistance. Send a follow-up letter, try alternative contact methods, and record every attempt. You are not penalised for residents who choose not to engage — but you must show you tried.
These figures come from two primary sources: Companies House Advanced Search and LEASE (Leasehold Advisory Service) enquiry data.
Companies House data was collected on 22 March 2026 using the Advanced Company Search with company name filters and active status. The standard naming convention under the Commonhold and Leasehold Reform Act 2002 (CLRA 2002) means most RTM companies include "RTM Company Limited" in their name, making name-based search a reliable proxy. LEASE data covers 136,721 RTM-related enquiry records from 2020-21 to 2025-26 (partial year). LEASE is the government-funded Leasehold Advisory Service, and its enquiry data provides the most comprehensive view of RTM demand patterns, geographic distribution, and co-occurring concerns.No government body -- not DLUHC, MHCLG, or the Building Safety Regulator -- publishes an official count of RTM companies or a breakdown of buildings by management type. The figures in this article represent the best available data from public registries and official advisory services.Caveats to note:
We update this research quarterly using Companies House data and the latest available LEASE figures. Last updated: March 2026.
| Search Term | Status | Result Count | |---|---|---| | "RTM company" | Active only | 12,338 | | "right to manage" | Active only | 210 | | "resident management company" | Active only | 147 |
The 210 companies containing "right to manage" use a non-standard naming convention. The 147 "resident management company" results are a separate category entirely -- RMCs are formed at the development stage by the original freeholder, while RTM companies are formed by leaseholders exercising their statutory right under CLRA 2002, Part 2, Chapter 1.
There are 12,338 active RTM companies on Companies House as of April 2026 -- but no government body publishes an official count, and Companies House does not track whether these companies have successfully claimed the right to manage.
The FPRA (Federation of Private Residents' Associations), the primary membership body for this sector, has approximately 500 members -- representing just 4% of the 12,338 total. This low penetration rate highlights how fragmented and underserved the RTM sector is.
The English Housing Survey 2021-22 found that only 8% of leaseholders had requested the right to manage. 50% had never claimed, and 41% did not know how they came to manage their building (Annex Table 3.7). Against a total of 4.77 million leasehold dwellings in England, RTM remains a small but growing fraction of the market.
LEASE enquiry data shows sustained and growing demand for RTM advice over the past five years.
| Financial Year | RTM Enquiries | Year-on-Year Change | |---|---|---| | 2020-21 | 6,643 | Partial year (COVID impact) | | 2021-22 | 28,034 | +322% | | 2022-23 | 27,213 | -3% | | 2023-24 | 33,377 | +23% (peak) | | 2024-25 | 26,608 | -20% | | 2025-26 | 14,846 | Partial year (~9 months) |
The peak in 2023-24 coincided with the higher-risk building registration deadline (October 2023) and rising anxiety about Building Assessment Certificate applications. The 2024-25 decline partly reflects LEASE's own transition year with reduced staffing and service reform.
Three legislative reforms under the Leasehold and Freehold Reform Act 2024 (LFRA 2024), in force since 3 March 2025, are expected to accelerate RTM formation further:
The Leasehold and Freehold Reform Act 2024 removed the three biggest barriers to RTM claims: building eligibility restrictions, landlord cost exposure, and expensive County Court proceedings.
Industry commentators have predicted a "dramatic rise" in RTM claims from 2026 onwards as these reforms take effect.
LEASE data reveals London's overwhelming dominance in RTM demand.
| Region | RTM Enquiries | Share | |---|---|---| | London | 55,801 | 40.8% | | Southern England | 26,986 | 19.7% | | Northern England | 14,498 | 10.6% | | Eastern England | 13,974 | 10.2% | | Midlands | 7,160 | 5.2% | | Wales | 2,045 | 1.5% | | Scotland | 236 | 0.2% | | Unknown | 12,802 | 9.4% |
The top three local authorities are all London boroughs with dense, high-rise housing:
| Local Authority | Enquiries | |---|---| | Lambeth | 3,225 | | Croydon | 2,878 | | Westminster | 2,876 |
This geographic concentration maps closely to higher-risk building density. London contains the highest proportion of leasehold dwellings (36.1% of housing stock, per DLUHC leasehold statistics) and the greatest concentration of buildings 7+ storeys or 18m+.
Check if your building qualifies as higher-risk ->LEASE data provides a detailed profile of who is enquiring about RTM.
| Client Type | Share | |---|---| | Leaseholder (flat/house owner) | 66.1% | | Unknown | 27.5% | | Purchaser | 2.4% | | Landlord/freeholder | 1.4% |
| Landlord Type | Share | |---|---| | Private company or individual | 58.6% | | Leaseholders (share of freehold) | 13.7% | | Housing Association | 7.6% | | Local Authority | 7.3% |
A critical finding: only 12% of RTM enquirers already have an RTM company. The remaining 88% are in the research or formation phase.
| RTM Company Status | Count | Share | |---|---|---| | No existing RTM company | 52,310 | 38.3% | | Already has RTM company | 16,457 | 12.0% | | Unknown | 67,225 | 49.2% |
This means the vast majority of people seeking RTM advice have not yet incorporated a company. They are at the decision point -- weighing whether to take control of their building's management.
| Property Type | Share | |---|---| | Flat -- purpose built | 57.1% | | Flat -- converted house | 27.5% | | Leasehold house | 5.7% | | Shared ownership flat | 2.0% | | Mixed use | 1.9% | | Retirement flat | 1.6% |
85% are flats (purpose-built and converted combined). Purpose-built flats at 57% represent the core Building Safety Act demographic -- these are the buildings most likely to meet the higher-risk building criteria of 7+ storeys or 18m+ with two or more residential units.When someone contacts LEASE about RTM, what else are they asking about? The co-occurring topics reveal the daily reality of running an RTM company.
| Co-Occurring Topic | Share of RTM Enquiries | Brocade Coverage | |---|---|---| | Service charges | 26.9% | Core feature | | Repair | 12.3% | Issue tracking + contractors | | Management | 11.7% | Core platform | | Breaches of covenants | 8.5% | Audit trail | | Lease extension | 8.3% | -- | | S20 consultation | 7.1% | S20 workflow | | Freehold purchase | 6.8% | -- | | Fire safety | 5.0% | FRA tracking | | Insurance | 4.9% | Document storage | | Interpreting lease | 4.8% | -- |
The top three co-occurring topics -- service charges (27%), repair (12%), and management (12%) -- account for 51% of all RTM enquiries. These are operational concerns, not regulatory ones. Fire safety accounts for just 5% of enquiries, despite carrying the highest regulatory consequence under the Building Safety Act 2022.
Service charges dominate RTM enquiries at 27% -- more than five times the rate of fire safety enquiries. RTM directors are more worried about money and operations than regulation, even as the Building Safety Act creates new compliance obligations.
-- LEASE enquiry data, 2020-2026
This pattern confirms a fundamental tension for RTM directors: the daily work is financial and operational, but the legal risk is regulatory. A platform that handles both is not a luxury -- it is how volunteer directors manage the gap between what they spend time on and what can result in prosecution.
RTM companies managing higher-risk buildings have exactly the same Building Safety Act obligations as professional managing agents. They must maintain the Golden Thread, prepare safety case reports, manage fire risk assessment actions, report mandatory occurrences, and submit to BSR assessment.
The difference is who is doing this work. Professional managing agents have compliance teams, legal advisers, and established processes. RTM directors are volunteers -- accountants, teachers, retirees -- who took on management because they were unhappy with the previous arrangement.
Some numbers that illustrate the gap:
88% of people seeking RTM advice haven't incorporated yet. But for the 12% who have -- and the thousands more who will -- the real work begins after formation.
Incorporating an RTM company is a legal milestone, not an operational one. The Companies House filing takes a few hours. What follows takes years.
The Compliance Gap section above sets out the numbers: 12,338 active RTM companies, ~500 in the FPRA, no formal support mechanism yet (Building Safety Director regulations remain in consultation). The Building Safety Act does not distinguish between a FTSE 100 housing association and three volunteers managing a 40-flat tower block. The obligations are identical. The resources are not.
Non-compliance is not an abstract risk. Section 73 of the Building Safety Act creates criminal liability for failing to comply with the Accountable Person duties. For RTM companies, the directors are the accountable persons.
There are 12,338 active RTM companies registered on Companies House as of April 2026. This figure is based on searching company names containing "RTM company" with an active status filter. An additional 210 companies contain "right to manage" in their name using a non-standard convention. No government body publishes an official count.
No official figure exists. The 12,338 incorporations do not confirm successful RTM claims -- Companies House does not track whether a company has actually acquired the right to manage. The BSR register does not publish aggregate statistics or a breakdown by management type. An FOI request to the BSR would be the most reliable route to obtain this data.
Yes. LEASE received 136,721 RTM-related enquiries between 2020 and 2026, with a peak of 33,377 in 2023-24. The Leasehold and Freehold Reform Act 2024 removed three key barriers to RTM claims -- building eligibility restrictions, landlord cost recovery, and expensive County Court proceedings -- and is expected to drive further acceleration from 2026 onwards.
London accounts for 41% of all LEASE RTM enquiries, followed by Southern England at 20% and Northern England at 11%. The top local authorities are Lambeth, Croydon, and Westminster -- all dense London boroughs with significant high-rise housing. This geographic concentration maps closely to higher-risk building density and the proportion of leasehold housing stock.
Service charges dominate co-occurring LEASE enquiries at 27%, followed by repair issues (12%) and general management questions (12%). Together, these operational concerns account for 51% of all RTM enquiries. Fire safety accounts for 5%, but carries the highest regulatory consequence under the Building Safety Act -- including criminal liability for non-compliance.
RTM companies managing higher-risk buildings have identical Building Safety Act obligations to professional managing agents -- safety case reports, golden thread records, mandatory occurrence reporting, and BSR assessment readiness. Most RTM directors are volunteers without compliance expertise. The FPRA has just 500 members against 12,338 active RTM companies. Structured software replaces the guesswork that puts volunteer directors at risk.
This guide is for informational purposes. For building-specific advice, consult a qualified fire safety professional. Get regulatory updates delivered monthly ->]]>A Building Assessment Certificate is confirmation from the BSR that the principal accountable person for a higher-risk building is complying with their duties under Part 4 of the Building Safety Act 2022. It is issued under section 79 of the Act after the BSR reviews your application and is satisfied that your building is being managed safely.
A Building Assessment Certificate confirms that the Building Safety Regulator has assessed a higher-risk building and is satisfied that the Accountable Person is managing building safety risks effectively.>
— Building Safety Act 2022, s.91
The BAC is not an optional certification or a nice-to-have accreditation. Every higher-risk building on the BSR's register (section 78) will be called in for a BAC application. The question is not whether your building will be assessed, but when. For a detailed look at how the assessment process itself works and how to prepare your building before the call-in letter arrives, see our guide to the BSR assessment process.
The BAC process serves a dual purpose: it gives the BSR evidence that buildings are being managed safely, and it gives building managers a structured framework for demonstrating compliance. If your records are organised and your safety management is genuine, the application process will confirm what you already know. If there are gaps, the process will expose them -- better discovered during an application than during an emergency.
The BSR began calling buildings in for BAC applications in April 2024 and is working through the registered building stock in priority order. As of early 2026, the BSR is prioritising:
The Principal Accountable Person must apply for a Building Assessment Certificate within 28 days of receiving a call-in notice from the Building Safety Regulator.>
— Building Safety Act 2022, s.91
| Priority group | Criteria | |---------------|----------| | Group 1 (first wave) | Buildings over 30m with 11 or more residential units | | Group 2 | Buildings between 18m and 30m with 378 or more residential units | | Group 3 | Buildings clad with aluminium composite material (ACM) | | Group 4 | Buildings with a large panel system (LPS) construction and gas supply | | Subsequent groups | Expanding to all registered higher-risk buildings over time |
If your building falls into Groups 1-4, you may have already received a call-in notice or should expect one soon. If your building is a registered higher-risk building outside these groups, your call-in is coming -- use the time to prepare.
Important: These priority criteria reflect the BSR's published approach as of early 2026. The BSR may adjust its priorities based on emerging intelligence about building safety risks. Monitor BSR communications and check the GOV.UK BAC guidance for the latest information.Understanding your accountable person duties is essential preparation -- the BAC application tests whether you are fulfilling those duties in practice.
When the BSR calls your building in, you have 28 days to submit a complete application. This is not enough time to build a compliance programme from scratch. The application requires evidence that you have been managing building safety effectively on an ongoing basis.
Here is what you need:
Your Safety Case Report is the centrepiece of your BAC application. It must demonstrate that you have:
For detailed guidance on preparing your Safety Case Report, see the Safety Case Report guide.
For an overview of what a building safety case involves and why it matters, see our guide to building safety cases.
Your Golden Thread -- the Key Building Information required under section 88 of the Act -- must be accessible, accurate, and current. The BSR will expect to see:
Under section 91 of the Act, you must have a residents' engagement strategy. For your BAC application, the BSR will want evidence that the strategy is not just a document but a functioning process:
Your mandatory occurrence reporting record demonstrates whether you have a functioning system for identifying and reporting safety incidents. The BSR will review:
Your current fire risk assessment and a complete record of actions arising from it:
Evidence that the people managing your building are competent to do so:
Your BAC application is primarily about safety management, but the BSR may review whether you have adequate financial provision for safety-related works. Having your service charge records, planned maintenance budgets, and reserve fund documentation organised alongside your safety records demonstrates a building that is managed holistically.
See how Brocade helps you prepare for BSR assessment -->You manage a 15-storey residential building with 48 flats. It was registered with the BSR in September 2023. In February 2026, you receive a letter from the BSR informing you that your building has been called in for a Building Assessment Certificate application. You have 28 days.
If you have been managing building safety proactively, this is a documentation exercise, not a crisis:
If you have not been managing proactively, 28 days is not enough time. This is why preparation matters.
The BSR has signalled that rejection rates for BAC applications are significant. Based on BSR communications and published guidance, common reasons include:
The BSR issues your Building Assessment Certificate. This is valid for 5 years, after which a reassessment is required. However, reassessment can be triggered earlier by:
If the BSR is not satisfied with your application, you will receive a refusal notice with reasons. The BSR may:
A Building Assessment Certificate (BAC) is issued by the Building Safety Regulator under section 79 of the Building Safety Act 2022 when it is satisfied that the principal accountable person is complying with their safety duties for a higher-risk building. The BSR calls buildings in for assessment in priority order, and the principal accountable person has 28 days from the call-in notice to submit their application.
The BSR began calling buildings in for Building Assessment Certificate applications in April 2024. As of early 2026, priority buildings include those over 30 metres with 11 or more residential units, buildings between 18 and 30 metres with 378 or more units, ACM-clad buildings, and buildings with a large panel system and gas supply. The BSR is expanding to additional buildings over time.
A Building Assessment Certificate application requires your Safety Case Report, evidence of your Golden Thread records, your residents' engagement strategy, details of mandatory occurrence reports, fire risk assessment and action tracking, and evidence of competent personnel managing building safety. The BSR conducts a substantive review, not a rubber-stamp exercise.
If the BSR refuses your Building Assessment Certificate application, you will receive reasons for refusal and may need to address the identified issues before reapplying. The BSR can also issue compliance notices under section 97 requiring specific improvements. Operating a higher-risk building without a valid BAC means ongoing regulatory scrutiny and potential enforcement action.
Building Assessment Certificates must be reassessed every 5 years. However, a reassessment can be triggered earlier if there is a significant change to the building, a major safety incident, or the BSR has concerns about ongoing compliance. The principal accountable person should treat the BAC as a living obligation, not a one-off exercise.
Service charges are the financial engine of every RTM company. Unlike a managing agent who sends invoices and moves on, RTM directors live in the building. You pay the same service charges you set. You answer questions from neighbours in the corridor, not through a complaints department.
This creates a unique dynamic: every pound you budget needs to be defensible to people who know where you live.
LEASE data shows that 27% of all RTM-related enquiries over the past five years concern service charges -- more than any other single topic, including the RTM claim process itself. The Building Safety Act has added a new layer of costs that many RTM companies have never budgeted for. Getting this right is both a legal obligation and a practical necessity for maintaining trust within your building community.
The BSA creates several categories of cost that are legitimate service charge items under the Landlord and Tenant Act 1985. As the Accountable Person for your higher-risk building, your RTM company is legally required to carry out these activities -- and the costs of doing so are recoverable through the service charge.
Before you commit to major safety works, you need to understand the Section 20 consultation requirements. The BSA does not override Section 20. If the cost of qualifying works exceeds 250 pounds per leaseholder, you must follow the three-stage consultation process under the Landlord and Tenant Act 1985 and the Service Charges (Consultation Requirements) Regulations 2003.
| Scenario | Typical cost per leaseholder | Section 20 required? | |:--|:--|:--| | Fire door replacement (full building) | 800-2,000 pounds | Yes | | Cladding remediation | 5,000-50,000 pounds | Yes | | Fire alarm system upgrade | 300-1,500 pounds | Yes | | Annual FRA review | 50-150 pounds | Usually no | | PEEPs survey programme | 30-100 pounds | Usually no | | Safety case preparation | 100-300 pounds | Depends on building size |
If you carry out qualifying works without proper Section 20 consultation, you can only recover 250 pounds per leaseholder through the service charge -- regardless of the actual cost. For a 30-flat building where fire door replacement costs 60,000 pounds, skipping consultation means recovering 7,500 pounds instead of 60,000. The RTM company -- and by extension its leaseholder-directors -- absorbs the difference.
You can apply for dispensation from the First-tier Tribunal under section 20ZA, but this is not guaranteed. For BSA-related works, urgency and safety risk are factors the tribunal considers, but you must still demonstrate that leaseholders were not materially prejudiced by the lack of consultation.
Most RTM companies budget annually. The BSA requires you to think in two timeframes: annual recurring costs and a multi-year reserve for capital safety works.
| Budget line | Typical range (per annum) | Notes | |:--|:--|:--| | Fire risk assessment | 1,500-4,000 pounds | Annual for HRBs | | Safety case maintenance | 1,000-3,000 pounds | Software + consultant time | | Golden thread record-keeping | 500-2,000 pounds | Software subscription | | MOR systems and processes | 200-500 pounds | Reporting infrastructure | | Building safety insurance | 1,000-5,000 pounds | Varies by building risk profile | | Contractor competence checks | 300-800 pounds | Per contractor engagement | | PEEPs review | 500-1,500 pounds | Depends on resident needs | | Total annual compliance | 5,000-17,000 pounds | Before any capital works |
For a 30-flat building, that annual compliance cost works out to roughly 170-570 pounds per leaseholder per year -- before any major remediation. This is new money that was not in your budget before the BSA.
Capital safety works -- cladding, fire doors, alarm systems, compartmentation -- can cost tens or hundreds of thousands of pounds. Start building a reserve fund now, even if no immediate works are planned.
Under the Landlord and Tenant Act 1985 (section 19), service charges must be "reasonable". Building a reserve over several years to avoid a single large demand is both reasonable and prudent. Include a named "Building Safety Reserve" line in your annual budget.
A practical approach: estimate the total cost of safety works likely to arise over the next five years, divide by five, and add that annual contribution to your service charge budget. Review and adjust each year as costs become clearer.
The Building Safety Levy is a separate charge on developers -- not on building managers or leaseholders. It is established under Part 4 of the Building Safety Act 2022 and is expected to launch in October 2026.
While RTM companies do not pay the levy directly, it funds the Building Safety Fund, which finances remediation of historical fire safety defects. If your building has outstanding cladding or fire safety remediation needs, the levy's impact on remediation funding timelines may affect your planning.
The key point for RTM directors: the levy does not create a new service charge liability for your leaseholders, but remediation works funded by the Building Safety Fund may still require Section 20 consultation when costs flow through your service charge.
This is where RTM companies have a structural advantage -- and a structural risk. You are leaseholders too. You pay the same charges. That shared interest is your strongest argument for transparency.
The most common objection: "Why should we pay for this?"
Your answer has three parts:
The BSA has changed the insurance landscape for higher-risk buildings. RTM companies need to verify several things:
If you are an RTM treasurer or director responsible for finances, start here:
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.
Not every RTM company has BSA obligations. The Act applies to higher-risk buildings in England:
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-riskSome 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.
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.
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:
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.
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.
This does not require complex governance. It requires clarity and documentation.
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.
Document what the Building Safety Director is authorised to do:
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.
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.
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.
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:
The Principal Accountable Person must report safety occurrences to the Building Safety Regulator within 10 working days of becoming aware of the occurrence.>
— Building Safety Act 2022, s.78
The BSR has signalled that underreporting is a significant concern. Many building managers are not recognising reportable occurrences when they happen, or are treating them as routine maintenance issues rather than regulatory events. The consequence is a gap between what is actually happening in buildings and what the regulator knows about.
For you as a building manager, the practical risk is straightforward: if something goes wrong and the BSR discovers you failed to report a known safety issue, you face criminal liability under section 101 of the Act. The good news is that establishing a reliable reporting system is manageable -- and this guide shows you how.
Under section 87 of the Building Safety Act 2022, the accountable person must report occurrences that relate to the structural integrity or fire safety of the building and pose a risk of significant harm to people in or around it.
A safety occurrence is any event that causes a risk to the safety of people in or about the building, relates to the spread of fire or structural failure, and is caused by the design, construction, or ongoing management of the building.
In practical terms, reportable occurrences include:
| Category | Examples | |----------|----------| | Structural defects | Cracks in load-bearing walls, foundation settlement, concrete spalling exposing reinforcement, balcony structural concerns | | Fire door failures | Doors that fail to self-close, damaged intumescent strips, missing cold smoke seals, failed overhead closers | | Compartmentation breaches | Missing or degraded fire stopping around service penetrations, gaps in cavity barriers, holes in fire-separating walls | | Active fire system failures | Sprinkler system faults, smoke ventilation malfunctions, dry riser failures, fire alarm system defects | | External wall concerns | Cladding defects, missing cavity barriers in external walls, combustible insulation discovered during works |
The threshold is not "something went wrong." It is "something went wrong that creates a risk of significant harm." A fire door that sticks slightly is a maintenance issue. A fire door that fails to close at all on a corridor serving 20 flats is a reportable occurrence because it compromises the compartmentation strategy that protects residents.
The accountable person for the building is legally responsible for establishing this system. Here is the step-by-step process for handling a reportable occurrence.
Failure to report a mandatory occurrence to the Building Safety Regulator is a criminal offence under the Building Safety Act 2022, carrying an unlimited fine.
The first challenge is recognising that something is reportable. This requires staff and contractors who interact with the building to understand what constitutes a safety occurrence. A concierge noticing a fire door propped open is different from a maintenance contractor discovering that fire stopping has been removed during unauthorised works -- but both may be reportable depending on the circumstances.
Practical tip: Create a simple one-page reference card listing examples of reportable occurrences. Give it to every member of staff and contractor who works on site. Make it clear that they should escalate anything they are unsure about -- it is better to over-report internally than to miss a genuine occurrence.As soon as you become aware of a potential reportable occurrence, record:
Before submitting, assess whether the occurrence meets the reporting threshold: does it pose a risk of significant harm relating to the structural integrity or fire safety of the building?
If you are genuinely uncertain, submit the report. The BSR will determine whether it meets the threshold. Filing a report that does not qualify is not an offence; failing to file one that does qualify may be.
Submit your occurrence notice through the BSR's online submission portal. The GOV.UK guidance on submitting mandatory occurrence notices and reports details the process and required information.
Your notice must be submitted within 10 working days of becoming aware of the occurrence. Include:
After receiving your notice, the BSR may request a full occurrence report. This is a more detailed document covering:
A reliable mandatory occurrence reporting system includes:
1. Clear escalation routes. Every person working on or in the building -- staff, contractors, managing agents -- should know who to contact if they discover something that might be reportable. A single named contact or role works best. 2. Internal reporting form. A standardised form for capturing the details listed in Step 2 above. This can be digital or paper, but digital is preferable because it creates a timestamped, searchable record. 3. Assessment protocol. A documented process for deciding whether an internal report meets the BSR reporting threshold. This should specify who makes the decision and the timeframe for doing so (e.g., within 2 working days of internal report). 4. Tracking and follow-up. A register of all occurrences -- reported and not reported -- with the rationale for each decision. This is your evidence of due diligence if your reporting decisions are ever questioned. 5. Training records. Evidence that staff and contractors have been briefed on what constitutes a reportable occurrence and how to escalate. Annual refresher training is good practice.A resident in a 12-storey building reports a crack running across the ceiling of their hallway. Your building manager inspects and finds the crack extends through the plaster into the concrete soffit of the floor above. A structural engineer confirms the crack indicates differential settlement affecting a load-bearing element.
You have 10 working days from the point your building manager confirmed this was a structural concern to submit an occurrence notice to the BSR. The notice includes the engineer's preliminary assessment, photographs, and a description of the interim monitoring measures you have put in place (tell-tales on the crack, increased inspection frequency). The structural engineer's full report, due in three weeks, will form part of the full occurrence report if the BSR requests one.
This is mandatory occurrence reporting working as intended: a concern is identified, assessed, reported to the regulator, and managed -- all within a structured, documented process.
The consequences of failing to report are both regulatory and criminal.
Criminal liability: Under section 101 of the Building Safety Act 2022, failing to comply with your duties as an accountable person is a criminal offence if the failure involves a risk of death or serious injury. The offence carries an unlimited fine. There is no imprisonment provision for this specific offence, but the financial and reputational consequences are severe. Due diligence defence: Section 101(4) provides a defence if you can prove you took "all reasonable steps" to comply with your duties. This is precisely why having a documented reporting system matters -- it is your evidence that you took compliance seriously, even if a specific occurrence was missed. Enforcement action: The BSR can issue a compliance notice under section 97 requiring you to establish or improve your reporting system. Failure to comply with a compliance notice is itself a criminal offence. Impact on your Building Assessment Certificate: Your occurrence reporting record forms part of your Building Assessment Certificate application. The BSR reviews whether you have a functioning MOR system when assessing your building. Gaps in reporting -- or a complete absence of reports when incidents clearly occurred -- will raise questions about the quality of your safety management.Mandatory occurrence reporting is a legal duty under section 87 of the Building Safety Act 2022. Accountable persons for higher-risk buildings must establish a system to identify, record, and report safety occurrences that pose a risk of significant harm to the Building Safety Regulator. An initial occurrence notice must be submitted within 10 working days of becoming aware of the event.
A reportable occurrence is any event relating to the structural integrity or fire safety of a higher-risk building that poses a risk of significant harm to people. Examples include fire door failures, dry riser malfunctions, compromised compartmentation, structural defects in load-bearing elements, and failures in active fire safety systems such as sprinklers or smoke ventilation.
Failure to comply with mandatory occurrence reporting duties can constitute a criminal offence under section 101 of the Building Safety Act 2022. If the failure involves a risk of death or serious injury, the offence carries an unlimited fine. A due diligence defence is available under section 101(4) if you can show you took all reasonable steps to comply.
You submit mandatory occurrence reports through the Building Safety Regulator's online portal. An initial occurrence notice must be filed within 10 working days of becoming aware of the event. The BSR may then request a full occurrence report with detailed information about the incident, root cause analysis, and remedial actions taken or planned.
The accountable person for a higher-risk building is legally responsible for establishing and operating a mandatory occurrence reporting system under section 87 of the Building Safety Act 2022. In practice, this means the principal accountable person must ensure staff and contractors know how to identify reportable occurrences and that internal processes capture them.
There are 12,338 active RTM companies registered on Companies House. Every one that manages a higher-risk building carries the same legal obligations under the Building Safety Act 2022 as a professional managing agent with a team of compliance specialists.
The Accountable Person for a higher-risk building must take all reasonable steps to prevent the occurrence of a major incident. This duty applies regardless of whether the building is managed by a professional agent, a local authority, or an RTM company.>
— Building Safety Act 2022, s.72
The difference is that your directors are volunteers. You took on Right to Manage for control over your building and transparency over service charges — not because you wanted to navigate a regulatory regime designed for professional building managers. But the BSA does not distinguish between volunteers and professionals. Your obligations are identical.
This guide breaks down each obligation so you know exactly what your RTM company must do, and in what order.
The Building Safety Act's Part 4 obligations apply to higher-risk buildings. Your building qualifies if it meets both criteria:
If your building is below these thresholds, the full BSA regime does not apply — but the Regulatory Reform (Fire Safety) Order 2005 still requires you to manage fire risk in common areas. Many RTM companies voluntarily adopt BSA-standard practices even for non-qualifying buildings, which strengthens your position if the criteria change.
Every higher-risk building must be registered with the BSR (BSA 2022, s.89). The original registration deadline was 1 October 2023. If your building is not yet registered, act immediately — failure to register is a criminal offence.
Registration requires you to identify the Principal Accountable Person (PAP). For most RTM-managed buildings, the RTM company itself is the PAP because it holds management responsibility for the building's common parts (BSA 2022, s.74).
What you need to register:Registration is a one-time obligation, but you must notify the BSR of any changes to the building or accountable person within 28 days.
If multiple parties share accountability — for example, the freeholder retains responsibility for the structure while your RTM manages the common parts — each Accountable Person must be registered.
The safety case report is your primary compliance document (BSA 2022, s.77). It must demonstrate that you are actively managing building safety risks. The BSR can request it at any time, and you must produce it.
Your safety case report should include:
For an RTM company with volunteer directors, the challenge is maintaining institutional knowledge when directors change. A building where one director held all the safety information in their head fails the safety case test the moment they sell their flat.
Read the complete Safety Case Report guide →Your RTM company must:
When a safety occurrence happens in your building, you must report it to the BSR (BSA 2022, s.78). This covers structural failures and fire safety incidents that could cause a significant risk to life.
What counts as a reportable occurrence:For RTM directors, the key risk is not recognising when something is reportable. A fire alarm fault that lasts an afternoon might not feel like a major incident — but if it affected the means of escape for a mobility-impaired resident, it could be reportable. When in doubt, report. The BSR does not penalise over-reporting.
The golden thread requires you to create and maintain accurate, up-to-date digital records of your building's safety information throughout its lifecycle (BSR golden thread guidance).
The golden thread is not a single document — it is the entire chain of building safety information, from design through construction to occupation, maintained in a digital format that is accurate, up to date, and accessible.
What this means in practice for an RTM company:
If you are an RTM director of a higher-risk building, here is what to do — in order of priority:
Yes. If your building is 7+ storeys or 18m+ with 2+ residential units, the BSA applies regardless of management structure. Your RTM company has the same obligations as any other Accountable Person. The Act does not distinguish between professional managing agents and volunteer-led RTM companies — the duties under Part 4 apply equally.
The RTM company itself is typically the Accountable Person, as the entity holding management responsibility for the common parts (BSA 2022, s.72). Individual directors share operational responsibility for ensuring the company meets its obligations. If the freeholder retains responsibility for the building's structure, they may be a separate Accountable Person — in which case, both must be registered with the BSR.
The Building Safety Regulator can issue compliance notices, impose financial penalties, and prosecute (BSA 2022, s.73). Directors of non-compliant RTM companies may face personal liability. Penalties include unlimited fines and, for the most serious offences, up to two years' imprisonment. The BSR has stated it will take enforcement action where Accountable Persons fail to meet their duties.
You can appoint agents to carry out specific tasks — preparing PEEPs, conducting fire risk assessments, managing contractors — but the RTM company retains legal responsibility as the Accountable Person. You cannot delegate accountability. If a managing agent fails to complete work you delegated, the BSR will hold your RTM company responsible, not the agent. Make sure any appointments include clear service level agreements and reporting requirements.
This guide is for informational purposes. For building-specific advice, consult a qualified fire safety professional. Stay ahead of compliance deadlines →]]>The Building Safety Act 2022 establishes a range of criminal offences in sections 98 to 104. Understanding what each offence covers helps you focus your compliance efforts on what matters most.
The Building Safety Act 2022 creates criminal offences carrying unlimited fines and up to two years' imprisonment for the most serious breaches, including failure to comply with duties where there is a risk of death or serious injury.>
— Building Safety Act 2022, ss.98-104
| Offence | Section | Maximum Penalty | |---------|---------|----------------| | Failure to register a higher-risk building | s.98 | Unlimited fine | | Failure to apply for a Building Assessment Certificate | s.99 | Unlimited fine | | Contravention of a Building Assessment Certificate condition | s.100 | Unlimited fine | | Failure to comply with accountable person duties (risk of death/serious injury) | s.101 | Unlimited fine | | Failure to comply with a compliance notice | s.102 | Unlimited fine | | Providing false or misleading information | s.103 | Unlimited fine and/or up to 2 years' imprisonment | | Obstruction of the BSR | s.104 | Unlimited fine and/or up to 2 years' imprisonment |
Two things stand out. First, the fines are unlimited for every offence. There is no upper cap. Second, imprisonment is reserved for the most serious offences -- providing false information to the regulator and obstructing its work. The legislation draws a clear line between failing to comply (which carries fines) and actively deceiving or obstructing the regulator (which carries custodial sentences).
Criminal prosecution is not the only enforcement tool. The BSA also gives the BSR civil enforcement powers that can be applied before any criminal proceedings:
If you have been anxious about the penalties listed above, this section should reassure you. The BSR does not open with prosecution. It follows a graduated enforcement approach that gives building managers opportunities to correct problems before facing the most serious sanctions.
The Building Safety Regulator follows a graduated enforcement approach: engagement and guidance first, compliance notices second, remediation orders third, and prosecution only as a last resort.
The BSR's first step is always to engage with the accountable person. This includes publishing guidance, providing advice during assessments, and identifying areas where improvement is needed. Most compliance issues are resolved at this stage.
If engagement does not resolve the issue, the BSR can issue a compliance notice under section 97. A compliance notice is a formal document that:
If a compliance notice is ignored or inadequately addressed, the BSR can escalate to remediation orders, special measures, or prosecution. At this stage, the building manager has been told what is wrong, told how to fix it, given time to fix it, and chosen not to act. The escalation is proportionate.
The escalation approach means that if you are engaging with the BSR, responding to their feedback, and making genuine efforts to improve your building's safety management, you are extremely unlikely to face prosecution. The building managers at risk are those who ignore registration deadlines, refuse to engage with the BSR, or deliberately provide false information.
Understanding how the BSR conducts its assessments can help you prepare. Our guide to the BSR assessment process walks through what to expect and how to demonstrate compliance during a building assessment.
Read the complete Building Safety Act guide for building managers -->The BSR has been operational since April 2023 and has been progressively exercising its enforcement powers. Understanding how the regulator has acted in practice gives you a clearer picture of what to expect.
The BSR set an initial deadline for higher-risk building registration and has followed up with building owners who failed to register. The regulator has used its powers to identify unregistered buildings and contact responsible persons, issuing formal notifications requiring registration. The GOV.UK register of higher-risk buildings provides the current registration process and requirements.
The BSR has begun accepting Building Assessment Certificate (BAC) applications and conducting assessments of higher-risk buildings. During these assessments, the BSR reviews safety case reports, Golden Thread documentation, resident engagement strategies, and mandatory occurrence reporting systems. Where deficiencies are identified, the BSR works with accountable persons to address them before considering enforcement action.
The BSR has indicated it will use compliance notices as its primary enforcement tool for accountable persons who are not meeting their duties. The HSE's enforcement approach outlines the principles the BSR follows, which are consistent with the graduated approach described above.
The key pattern across all enforcement activity so far is consistency with the graduated approach: the BSR engages first, uses formal notices to drive compliance, and reserves prosecution for the most serious cases.
The government is also introducing a building safety levy on new higher-risk building developments to fund remediation of historical building safety defects -- a further indication of the regulatory direction of travel.
You receive a compliance notice from the BSR. It states that your building's mandatory occurrence reporting system does not meet the requirements of section 87 of the Building Safety Act 2022. Specifically, the BSR found during a routine assessment that your building has no documented process for identifying and reporting safety occurrences, no training records for staff, and no occurrence register.
The notice gives you 28 days to establish a compliant reporting system and provide evidence to the BSR.
Here is how you respond:
Week 1: Establish a written procedure for identifying, recording, and reporting mandatory occurrences. Create an internal reporting form. Designate a named contact for occurrence reports. Week 2: Brief all building staff and key contractors on the new procedure. Record attendance and content of the briefing. Issue the one-page reference card of reportable occurrence examples. Week 3: Set up an occurrence register (even if it currently has zero entries). Document your assessment protocol for deciding whether an internal report meets the BSR threshold. Test the system with a tabletop exercise. Week 4: Submit your evidence to the BSR: the written procedure, training records, reporting form, occurrence register, and confirmation of the named contact. Include a brief statement explaining how the system will operate going forward.This scenario illustrates the BSR's approach in action. The compliance notice identified a specific gap. You had time to address it. You addressed it. The matter is resolved without prosecution, without fines, and without a criminal record. The system worked as intended.
Section 101(4) of the Building Safety Act provides a statutory defence for Accountable Persons who can prove they took all reasonable steps to comply with their duties.>
— Building Safety Act 2022, s.101(4)
This is not a theoretical protection. It is a practical one -- but only if you have the evidence to prove it. "All reasonable steps" means:
Based on the offences in sections 98-104, here is what you need to have in place:
Registration and certification:The Building Safety Act 2022 creates criminal offences carrying unlimited fines and, for the most serious offences, up to two years' imprisonment. Sections 98 to 104 establish offences including failure to register a higher-risk building, failure to apply for or comply with a Building Assessment Certificate, failure to comply with accountable person duties where there is a risk of death or serious injury, and obstruction of the Building Safety Regulator.
Yes. The most serious offences under the Building Safety Act carry imprisonment of up to two years. These include providing false or misleading information to the BSR (section 103), obstructing the regulator (section 104), and certain failures to comply with duties where the failure involves a risk of death or serious injury. However, imprisonment is reserved for the most egregious cases -- the BSR's enforcement approach prioritises compliance over prosecution.
The BSR follows an escalation approach. It starts with engagement and guidance, then progresses to compliance notices under section 97 requiring specific actions within a set timeframe. If compliance notices are not followed, the BSR can issue remediation orders or take prosecution action. This graduated approach means building managers who are making genuine efforts to comply are unlikely to face the most severe sanctions.
A compliance notice is a formal enforcement tool under section 97 of the Building Safety Act 2022. The BSR issues a compliance notice when an accountable person is contravening, or is likely to contravene, their duties. The notice specifies what steps must be taken and the timeframe for compliance. Failure to comply with a compliance notice is a criminal offence carrying an unlimited fine.
Yes. Section 101(4) of the Building Safety Act provides a due diligence defence. If you can prove you took all reasonable steps to comply with your duties, this is a defence against prosecution. This means maintaining documented evidence of your safety management systems, inspection records, risk assessments, and remedial actions is critical -- it is your evidence that you took compliance seriously.
A fire door inspection without a record is an inspection that never happened. That sounds harsh, but it is how the BSR and fire and rescue authorities approach enforcement. If you cannot produce evidence that a door was checked, you cannot demonstrate compliance -- regardless of whether the check actually took place.
A fire door inspection without a documented record is treated by the Building Safety Regulator as an inspection that never happened. Evidence of systematic checking is what demonstrates compliance.>
— Fire Safety (England) Regulations 2022, Reg 10
This matters for three reasons:
1. Your Golden Thread requires it. The Building Safety Act 2022 requires you to maintain a Golden Thread of building safety information. Fire door inspection records are part of that thread. When the BSR assesses your building for a Building Assessment Certificate, they will expect to see a systematic, documented inspection programme -- not a verbal assurance that "we check them regularly." 2. Your safety case depends on it. Your safety case report must demonstrate that you are actively managing fire safety risks. Fire doors are a critical part of your compartmentation strategy. If your inspection records have gaps, your safety case has gaps. 3. It protects you legally. If a fire incident occurs and your fire door maintenance is questioned, your inspection records are your primary defence. They show that you had a systematic process, that you identified defects, and that you took action to resolve them.The Fire Safety (England) Regulations 2022 introduced specific inspection frequencies for fire doors in residential buildings containing two or more domestic premises:
Higher-risk buildings must have flat entrance fire doors inspected quarterly and common area fire doors inspected annually as a legal minimum under the Fire Safety (England) Regulations 2022.>
— Fire Safety (England) Regulations 2022, Reg 6
| Door Type | Inspection Frequency | Regulation | |-----------|---------------------|------------| | Flat entrance doors (in buildings with common parts) | Quarterly | Regulation 10 | | Fire doors in common parts | Annually | Regulation 10 |
These are minimum frequencies. Your fire risk assessment may recommend more frequent checks based on the condition of your doors, the age of the building, or the level of wear and tear from residents.
Not sure whether your building qualifies? Our guide to higher-risk building criteria explains the height and residential unit thresholds that determine which buildings fall under the enhanced fire door inspection regime.
The regulations require you to carry out "best endeavours" to check flat entrance doors, acknowledging that residents may not grant access. For common area fire doors, there is no access barrier -- these are under your direct control and must be checked without exception.
Each inspection should assess the complete door assembly, not just whether it closes:
Each fire door needs a unique identifier and a record that builds over time. Here is what a compliant inspection record looks like.
Each fire door should be assigned a unique identifier and have a cumulative inspection record that builds over time, showing the full lifecycle of checks, defects, and remediation.
A quarterly check of flat entrance doors on Level 3 of a 10-storey building finds three doors with defective closers. The doors close, but they do not latch fully -- when released from 30 degrees, they stop about 10mm short of the frame.
Your inspector records each door's reference number, photographs the gap between door and frame, and notes the closer model. The defect is rated as affecting fire performance because a door that does not fully close and latch cannot provide its rated fire resistance. The target completion date is set for 14 days -- your contractor can replace all three closers in a single visit.
Two weeks later, the contractor replaces the closers. Your building manager confirms each door now closes and latches fully from any angle, takes a photograph of each closed door, and records the closer model installed, the contractor's name, and the completion date. The inspection record for each door now shows: defect identified, action taken, defect resolved. That is a complete audit trail.
See how Brocade tracks fire risk assessment actions from identification to resolution -->The BSR does not prescribe a specific format for fire door records. What matters is that the information is accessible, complete, and traceable. Here is how to organise your records so they work for both day-to-day management and regulatory audit.
Maintain a central register of every fire door in your building. For a typical 10-storey residential building, this might be 150-250 fire doors across flat entrances, lobbies, stairwells, risers, and plant rooms. Each door should have:
Map your inspection frequencies to a calendar. Quarterly flat entrance door checks mean four inspection rounds per year. Annual common area checks mean one comprehensive round. Stagger these so your building manager is not trying to inspect every door in the building in one week.
For each defect found, the audit trail should be traceable from identification through to resolution:
Tracking inspection costs alongside compliance records also makes budgeting for fire door maintenance straightforward -- you can see spend per door, identify doors that need frequent repairs (which may indicate they should be replaced), and forecast your annual fire door maintenance budget based on actual data rather than guesswork.
When the BSR assesses your building for a Building Assessment Certificate, your fire door records will be part of the evidence reviewed. Our guide to the BSR assessment process explains what the regulator looks for and how to prepare your documentation.
The Fire Safety (England) Regulations 2022 require quarterly checks on flat entrance doors and annual checks on all fire doors in common parts of higher-risk buildings. These frequencies are minimums -- your fire risk assessment may recommend more frequent inspections based on the condition and usage of specific doors.
Each fire door inspection record should include the door location and unique identifier, the date and time of inspection, the name and qualification of the inspector, the condition of all components (leaf, frame, intumescent strips, cold smoke seals, closer, hinges, signage, glazing, and gaps), a pass or fail result for each component, photographs of any defects found, and a record of any remedial actions required with target completion dates.
The responsible person under the Regulatory Reform (Fire Safety) Order 2005 is responsible for fire doors in common parts. For higher-risk buildings, the accountable person under the Building Safety Act 2022 has additional duties. In most residential buildings, this is the freeholder, management company, or managing agent. Leaseholders are typically responsible for the flat side of their entrance door. RTM companies bear direct responsibility for fire door maintenance as the Accountable Person. See our RTM compliance guide for the full picture.
Undocumented fire door inspections are treated as if they did not happen. The Building Safety Regulator expects to see evidence of a systematic inspection programme as part of your safety case and Golden Thread records. Missing documentation can lead to compliance notices, and failure to maintain fire safety records can constitute a criminal offence under the Building Safety Act 2022.
The Fire Safety (England) Regulations 2022 do not specify a particular certification for fire door inspectors. However, the responsible person must ensure inspections are carried out by a competent person. Industry best practice is to use inspectors certified under schemes such as the BRE/LPCB fire door inspection scheme or the Fire Door Inspection Scheme (FDIS). Quarterly checks of flat entrance doors can be carried out by trained building staff.
Before examining how Section 20 interacts with the Building Safety Act, it is worth establishing what Section 20 requires in its own right.
Section 20 of the Landlord and Tenant Act 1985 requires landlords to consult leaseholders before carrying out qualifying works costing more than £250 per leaseholder, or entering into qualifying long-term agreements.>
— Landlord and Tenant Act 1985, s.20Section 20 of the Landlord and Tenant Act 1985 (as substituted by the Commonhold and Leasehold Reform Act 2002) limits a landlord's ability to pass costs to leaseholders through the service charge unless the landlord has first consulted those leaseholders. The detailed consultation process is set out in the Service Charges (Consultation Requirements) (England) Regulations 2003 (SI 2003/1987).
There are two types of cost that trigger consultation:
| Type | Definition | Threshold | |------|-----------|-----------| | Qualifying works | Works on a building or any other premises | Cost to any one leaseholder exceeds 250 pounds | | Qualifying long-term agreements | Agreements for services lasting more than 12 months | Cost to any one leaseholder exceeds 100 pounds per year |
If you plan to carry out works or enter into an agreement that exceeds these thresholds, you must follow the prescribed consultation process. If you do not, your ability to recover costs through the service charge is capped at the threshold amount.
This applies regardless of why the works are needed. Whether the work is routine maintenance, a major refurbishment, or safety remediation required by the Building Safety Act -- if it exceeds the threshold, you must consult.The full Section 20 consultation for qualifying works follows three stages, each with specific notice requirements and response periods.
You must serve a written notice on every leaseholder (and any recognised tenants' association):
After obtaining at least two estimates (including any from nominated contractors):
Within 21 days of entering into the contract:
This is where things get challenging for building managers. The Building Safety Act creates urgent safety obligations. Section 20 creates mandatory consultation timelines. The two can collide.
Building safety remediation works — fire door replacements, cladding remediation, compartmentation repairs — are qualifying works that trigger Section 20 consultation requirements if the cost exceeds £250 per leaseholder.
Your fire risk assessment reveals that your 14-storey building needs 200,000 pounds of remedial work: replacement of defective fire doors on six floors, fire stopping remediation in service risers, and upgrades to the smoke ventilation system. Under section 84 of the Building Safety Act, you must take "all reasonable steps" to address these risks. Under Section 20, you cannot simply commission the works and pass the cost to leaseholders. You must consult first.
With 50 leaseholders in the building, the per-leaseholder cost is 4,000 pounds -- well above the 250-pound threshold. The full consultation process will take 10-12 weeks. During those weeks, the building has defective fire doors and compromised fire stopping.
This is not a hypothetical edge case. It is the daily reality for building managers of higher-risk buildings across England.The Building Safety Act 2022 did not amend Section 20 of the Landlord and Tenant Act 1985. There is no exemption for works required by the Building Safety Regulator, no fast-track consultation process for safety remediation, and no override that allows costs to be recovered without consultation.
This means you must plan for the consultation timeline alongside your safety obligations. Treating them as sequential -- "first fix the safety issue, then worry about costs" -- puts you at risk of either:
{/ TODO: Phase 9 -- link to section-20b-demand-notices-guide when published /}
This is the reality that most building managers struggle with: building safety compliance generates costs, and those costs trigger financial compliance obligations. You cannot manage one without managing the other.
Under Section 20B of the Landlord and Tenant Act 1985, costs must be demanded from leaseholders within 18 months of being incurred, or the right to recover them may be lost entirely.>
— Landlord and Tenant Act 1985, s.20B
A building that completes all its safety works but cannot recover the costs because it failed to consult properly has a financial problem. A building that runs a perfect Section 20 consultation but delays safety works for months while it does so has a compliance problem. Neither is acceptable.
What effective management looks like:Dispensation under section 20ZA is not a shortcut. It is a formal application to the First-tier Tribunal (Property Chamber) asking to be relieved of some or all consultation requirements. Understanding when to apply -- and how to strengthen your application -- is important.
Dispensation relieves you from the consultation process. It does not mean leaseholders must pay unreasonable costs. Service charge costs must still be "reasonably incurred" under section 19 of the Landlord and Tenant Act 1985. Leaseholders can still challenge the reasonableness of costs at the tribunal even after dispensation is granted.
It does not. No matter how urgent the safety works, the Section 20 consultation requirement applies unless you obtain dispensation. Proceeding without consultation or dispensation caps your recovery at 250 pounds per leaseholder.
Leaseholders have genuine rights during the consultation process. Their observations must be considered. Their nominated contractors must be invited to tender (if suitable). Treating the process as a box-ticking exercise risks tribunal challenges and damages the trust that your resident engagement strategy is trying to build.
If your remediation programme includes multiple distinct work packages, consider whether they are genuinely separate qualifying works. Aggregating unrelated works into a single project can complicate the consultation and make dispensation for urgent elements harder to obtain.
Every notice, observation, estimate, and decision must be documented. If a leaseholder challenges the service charge at tribunal, your records are your defence. Keep copies of all notices served, proof of service, observations received, responses provided, estimates obtained, and the rationale for contractor selection. These records also form part of your Golden Thread.
Section 20 does not only cover one-off works. If you enter into a long-term agreement for building safety services -- such as a multi-year fire safety maintenance contract costing more than 100 pounds per leaseholder per year -- the qualifying long-term agreement consultation process applies separately.
Yes. If BSA-related works such as cladding remediation, fire stopping repairs, or fire door replacements will cost any leaseholder more than 250 pounds, the standard Section 20 consultation process under the Landlord and Tenant Act 1985 applies. The Building Safety Act does not create an exemption from Section 20.
Under section 20 of the Landlord and Tenant Act 1985 and the Service Charges (Consultation Requirements) Regulations 2003, you must consult leaseholders before carrying out qualifying works where the cost to any individual leaseholder exceeds 250 pounds. For qualifying long-term agreements, the threshold is 100 pounds per leaseholder per year.
If you carry out qualifying works without proper consultation, you can only recover up to 250 pounds per leaseholder through the service charge -- regardless of the actual cost. To recover the full amount, you would need to apply to the First-tier Tribunal for a dispensation order under section 20ZA. The tribunal considers whether leaseholders have been prejudiced by the lack of consultation.
Yes. Under section 20ZA of the Landlord and Tenant Act 1985, you can apply to the First-tier Tribunal for dispensation from some or all of the consultation requirements. Urgency and safety risk are relevant factors the tribunal considers. However, dispensation is not automatic -- you must demonstrate why consultation was impractical and that leaseholders were not materially prejudiced.
The full three-stage process typically takes 8 to 12 weeks minimum. Stage 1 requires a 30-day notice period for observations. Stage 2 requires obtaining at least two estimates and a further 30-day notice period. Stage 3 is the notification of the awarded contract. Rushed consultations risk being challenged at tribunal.
{/ snippet-target: definition | query: "what is the golden thread building safety" /}
The Golden Thread is a complete, accurate, and up-to-date digital record of building safety information that must be maintained throughout the building's lifecycle.>
— Building Safety Act 2022, s.88
The Golden Thread is the complete, accurate, and up-to-date digital record of building safety information that must be maintained throughout the lifecycle of a higher-risk building. Required under section 88 of the Building Safety Act 2022, it includes structural records, fire safety documentation, maintenance histories, and all evidence demonstrating how the building is being safely managed. RTM companies have the same Golden Thread obligations as any other Accountable Person. Our guide for RTM directors covers how to implement this as a volunteer board.
The Golden Thread of building safety information, introduced by Section 88 of the Building Safety Act 2022, requires you to create and maintain accurate, up-to-date information about your higher-risk building throughout its lifecycle. The Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2024 specify what this means in practice.
Three requirements matter most for building managers:
A Golden Thread audit trail must demonstrate five things to the BSR:
The Higher-Risk Buildings (Keeping and Provision of Information) Regulations 2024 require an electronic facility for storing Golden Thread information with version control, access management, and the ability to share with the BSR on request.>
— SI 2024/41
Start with a complete inventory of your building safety information. The regulations require you to maintain records across these categories:
Every modification to your building safety records must be attributable. When the BSR reviews your Golden Thread, they want to see:
Version control isn't optional. When you update a fire risk assessment, the previous version must be preserved — not overwritten. When a contractor uploads a completion certificate that replaces a preliminary report, both versions must exist in the record.
Why? Because the BSR may ask: "What was the state of this building's fire safety on 15 January?" If you've been overwriting records, you can't answer that question. With proper version control, you can reconstruct the building's compliance state at any point in time.
The accountable person is personally responsible for the accuracy of Golden Thread information. If records can be silently deleted, backdated, or altered without a trace, the entire audit trail is undermined.
A compliant system must make it impossible — or at least detectable — for records to be modified without leaving evidence. This means:
Under Section 89 of the Building Safety Act, the BSR can request your building safety information at any time. You need to provide it in a format that's:
Based on how the BSR approaches building assessments, here are the patterns that raise red flags:
A spreadsheet on a shared drive is not an electronic facility. The Building Safety Regulator expects a digital system that timestamps every change, controls access, and maintains an immutable audit trail.
A building with 35 completed FRA actions needs 35 evidence chains. Each chain links the original finding → the action taken → the evidence uploaded → the date completed → the person who verified it. A spreadsheet with "Complete" in column F doesn't provide any of this.
If you're currently using spreadsheets, shared drives, or email, here's how to transition to a compliant digital audit trail.
Before choosing a system, understand your current state:
Generic document management tools and property management platforms weren't designed for Golden Thread compliance. Look for a system that provides:
Don't try to migrate everything at once. Start with the records the BSR is most likely to request:
The Golden Thread is only compliant if it stays current. Set up processes for:
Ask yourself: if the BSR requested my Golden Thread tomorrow, could I produce it within 24 hours? Could I trace any individual record back to its source? Could I show who changed what and when?
If the answer to any of these is no, you have more work to do.
Book a demo to see how Brocade tracks this →The BSR became a standalone body in January 2026, separating from HSE with a mandate for more assertive enforcement. Gateway 2 data shows 108 decisions in 12 weeks, with remediation applications averaging 18 weeks.
The penalties for non-compliance are not theoretical. Under Section 99 of the Building Safety Act, failure to comply with a compliance notice is a criminal offence. The BSR has the power to issue these notices if your record-keeping doesn't meet Golden Thread requirements.
Building managers who start now — even with imperfect records — are in a far stronger position than those who wait for a compliance notice to force their hand.
The Golden Thread must include fire risk assessments, structural safety information, safety case reports, maintenance records, as-built drawings, contractor qualifications, mandatory occurrence reports, and resident engagement records. The Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2024 specify the categories of information that must be maintained digitally.
An audit trail requires every change to building safety information to be timestamped, attributed to a named individual, and preserved as a historical record. Use a system that automatically logs who changed what and when, stores previous versions of documents, and prevents records from being silently deleted or altered.
A shared drive alone does not meet Golden Thread requirements. The Building Safety Act requires an electronic facility with controlled access, version management, and the ability to demonstrate who accessed or changed information. Shared drives lack automatic audit trails, granular access controls, and tamper protection.
Under Section 88 of the Building Safety Act 2022, the Building Safety Regulator can request your building safety information at any time. You must be able to provide it in an accessible format. If your records are incomplete, disorganised, or cannot demonstrate an audit trail, the BSR can issue a compliance notice under Section 99.
Golden Thread information must be kept up to date as changes occur. Fire risk assessment actions should be updated as work completes. Maintenance records should be added within 24 hours. Document versions should be updated whenever information changes. The key principle is that the Golden Thread reflects the current state of the building at all times.
Before the Building Safety Act, resident engagement in building safety was largely informal. Building managers might send occasional newsletters or hold an annual general meeting. Residents who raised concerns about fire doors, cladding, or escape routes often felt ignored.
The Principal Accountable Person must prepare a residents' engagement strategy describing how building safety information will be shared with residents and how residents will be consulted on safety decisions.>
— Building Safety Act 2022, s.83
The Grenfell Tower tragedy and Dame Judith Hackitt's Independent Review changed this fundamentally. Hackitt found that residents' concerns had been systematically dismissed. Her review recommended that residents become active participants in building safety -- not passive recipients of management decisions.
The Building Safety Act 2022 turned that recommendation into statute. Section 91 places a specific duty on the Principal Accountable Person (PAP) to prepare a strategy for promoting resident participation in decisions about building safety risk management. This is not optional guidance. It is a legal requirement backed by enforcement powers.
The resident engagement framework sits across several sections of the Building Safety Act. Together, they create a comprehensive set of obligations.
Under section 91, the PAP must prepare a strategy that:
Sections 89 and 90 require that residents receive information about:
If a resident is not satisfied with how their safety concern has been handled, they can escalate to the BSR directly. A well-functioning complaints system reduces the likelihood of this happening -- but the resident's right to escalate exists regardless.
Read the PAP responsibilities guideThe statute tells you what you must do. This section covers how to do it. A good engagement strategy is specific to your building, proportionate to the risks, and practical enough that your team can actually deliver it.
Start by understanding who lives in your building:
A Residents' Panel is the most effective structure for ongoing engagement. While the Act does not prescribe the exact format, the BSR expects to see structured resident involvement -- and a panel is the most common way to deliver this.
How to set one up:Not every resident will join the panel. You need additional channels to reach all residents:
| Channel | Best for | Frequency | |---------|----------|-----------| | Notice board (physical + digital) | Evacuation strategy, AP contact details, emergency procedures | Updated whenever changes occur | | Email updates | Safety works progress, fire risk assessment outcomes, seasonal reminders | Quarterly minimum, plus ad-hoc for significant events | | Resident portal | Self-service access to building safety documents, reporting concerns, viewing action status | Always available | | In-person meetings | Major safety decisions, new works consultations, post-incident briefings | As needed | | Translated materials | Buildings with residents who have limited English proficiency | Match all key communications |
Brocade includes a resident portal that gives leaseholders direct access to building safety information -- fire risk assessment status, safety works progress, and a channel for raising concerns. This kind of transparency builds trust and reduces the volume of ad-hoc enquiries to your management team. Book a demo to see how it works.
Section 89 requires you to provide safety information proactively. Build this into your regular operations:
On an ongoing basis:The section 93 complaints system needs specific elements:
Imagine you are the PAP for a 10-storey residential building with 45 flats. You have just completed a fire risk assessment that identified 12 actions, including replacement of three fire doors on the eighth floor and remedial fire stopping work in two service risers.
Without an engagement strategy: You commission the works, contractors come and go, and residents on the eighth floor wonder why their fire doors are being replaced. A resident on the ninth floor notices a hole in the corridor ceiling from the fire stopping work and files a complaint with the BSR, believing the building is unsafe. With an engagement strategy: You email all residents summarising the fire risk assessment findings and the planned works. The Residents' Panel reviews the action plan at their quarterly meeting. You post updates in the resident portal showing progress on each action. The ninth-floor resident sees the ceiling work explained as "fire stopping remediation -- work in progress, completion expected 15 April" and understands it is a safety improvement, not a safety failure.The difference is not just compliance. It is the difference between a building where residents trust the management and one where residents escalate to the regulator.
When the BSR assesses your building for a Building Assessment Certificate, your resident engagement strategy is one of the things they review. Based on the BSR's published approach, they are looking for:
Residents of higher-risk buildings have a legal right to request building safety information from the Accountable Person. Failure to provide it within a reasonable timeframe is a breach of the Act.
Not sure whether your building qualifies as higher-risk? Our guide to higher-risk building criteria under the Building Safety Act explains the height and residential unit thresholds that determine which buildings require a resident engagement strategy.
See how Brocade helps you track resident engagementWriting a strategy document and filing it away is not compliance. The strategy must be a living document, reviewed regularly and updated when your building's circumstances change. The BSR will ask for evidence of ongoing engagement, not just a policy.
Your resident engagement strategy under section 91 is specifically about building safety. It is not your AGM agenda, your service charge consultation process, or your general complaints procedure (though it may overlap). Keep the building safety focus distinct.
All residents -- including assured shorthold tenants and sub-tenants -- have the right to be informed and consulted about building safety. Your engagement channels must reach everyone who lives in the building, not just those who attend AGMs or own the lease.
If you held a Residents' Panel meeting but did not take minutes, you cannot evidence that engagement happened. If you sent an email update but did not save a copy, you cannot demonstrate compliance. Document everything. Your engagement records are part of the Golden Thread and your evidence for the due diligence defence.
Section 93 requires a separate complaints system for building safety. If you are routing all complaints through a general property management inbox with no specific tracking for safety concerns, you are likely non-compliant. Safety complaints need their own process, their own timeline, and their own records.
A resident engagement strategy is a formal document that the Principal Accountable Person must prepare under section 91 of the Building Safety Act 2022. It sets out how residents of a higher-risk building will be informed about building safety, consulted on safety decisions, and given a mechanism to raise safety concerns.
If residents request one, you must facilitate it. Section 91 of the Building Safety Act requires the PAP to promote resident participation in building safety decisions. While the Act does not mandate a panel in every building, the BSR expects the engagement strategy to include provisions for structured resident involvement, and a Residents' Panel is the most common way to achieve this.
Under sections 89 and 90 of the Building Safety Act, residents must be provided with information about the building's safety measures, fire safety arrangements, and how to report concerns. This includes the current fire risk assessment status, evacuation strategy, and the names and contact details of the Accountable Persons responsible for the building.
Failure to prepare a resident engagement strategy is a breach of section 91. The Building Safety Regulator can issue compliance notices requiring you to prepare one, and continued non-compliance can lead to enforcement action. Beyond the legal risk, poor engagement increases the likelihood of resident complaints escalating to the BSR.
There is no prescribed review frequency in the Act, but annual review is considered good practice. You should also update the strategy after significant changes such as new safety works, a change in management arrangements, or feedback from residents indicating the current approach is not working.
The government consultation on the Single Construction Regulator is still open. You can submit your response on GOV.UK before 20 March 2026.} after={<>The government consultation on the Single Construction Regulator closed on 20 March 2026. A formal government response is expected in summer 2026.} />
See the full compliance calendar →The Single Construction Regulator is a proposed new government body that would bring together oversight of building safety, construction product safety, and professional competence under one roof. Instead of building managers, developers, and manufacturers dealing with multiple regulators with overlapping — and sometimes contradictory — responsibilities, there would be a single point of accountability for the entire construction regulatory system.
The UK government confirmed in late 2025 that it will create a single construction regulator to oversee building standards, replacing the current fragmented system of local authority building control and approved inspectors.
The proposal was set out in a government consultation document published on 17 December 2025, titled "Single Construction Regulator Prospectus." The consultation ran for 13 weeks and closed on 20 March 2026. It asked for views from the construction industry, building managers, residents, and other stakeholders on whether consolidating regulatory functions would improve building safety outcomes.
This is not a minor administrative reshuffle. If implemented, it would be the most significant change to how buildings are regulated in England since the Building Safety Act 2022 created the Building Safety Regulator — which has already taken its first step toward independence by leaving the HSE to become a standalone body in January 2026.
The short answer: the current system is fragmented, and that fragmentation has real consequences.
Today, building safety regulation in England is split across several bodies, each with different powers, reporting lines, and areas of responsibility:
The Building Safety Regulator (BSR), originally established within the Health and Safety Executive (HSE), became a standalone arm's-length body under MHCLG on 27 January 2026. It is responsible for the safety and standards of higher-risk buildings. It oversees building control for these buildings, manages the registration of higher-risk buildings, and enforces the duties of Accountable Persons and Principal Accountable Persons under the Building Safety Act 2022. The BSR also has a role in overseeing the competence of people working on higher-risk buildings and managing the mandatory occurrence reporting system. The Office for Product Safety and Standards (OPSS), part of the Department for Business and Trade, regulates construction products. This includes the safety and performance of products like cladding, insulation, fire doors, and structural components. OPSS enforces the Construction Products Regulations and has powers to investigate and remove unsafe products from the market. The Grenfell Tower Inquiry highlighted significant failures in construction product testing and certification — failures that fell partly within OPSS's predecessor's remit. Local authority building control (LABC) services inspect and approve building work for most buildings that fall below the higher-risk threshold. They enforce the Building Regulations 2010 at a local level. For higher-risk buildings, the BSR has taken over the building control function, but for the vast majority of construction work in England, local authority building control remains the primary regulator. The Ministry of Housing, Communities and Local Government (MHCLG) — formerly the Department for Levelling Up, Housing and Communities (DLUHC) — sets building standards policy, drafts building regulations, and publishes Approved Documents that provide technical guidance on how to comply with the Building Regulations. MHCLG does not directly regulate individual buildings, but it sets the rules that all other regulators enforce. Professional body oversight is distributed across multiple organisations. The BSR has a statutory role in overseeing building control professionals, but competence standards for other construction professionals — architects, engineers, fire safety assessors — sit with their respective professional bodies, with limited coordination between them.This structure creates real problems for everyone involved in building safety:
Regulatory gaps. When multiple bodies each own a piece of the regulatory picture, issues that fall between their mandates can go unaddressed. The Grenfell Tower Inquiry Phase 2 report documented how failures in product testing, building control, and fire safety assessment all contributed to the disaster — but no single body had visibility across all three areas. Inconsistent enforcement. Different regulators apply different standards, use different enforcement approaches, and have different levels of resource. A building manager dealing with the BSR on building safety obligations, OPSS on a product safety concern, and their local authority on building control matters may encounter three different interpretations of what "adequate" means. Duplication and confusion. Building managers, developers, and manufacturers sometimes receive conflicting guidance from different regulators, or find themselves reporting the same information to multiple bodies. For a building manager of a higher-risk building, the reporting burden is already significant under the Building Safety Act. Adding separate reporting requirements for product safety or professional competence issues multiplies the administrative load. Accountability diffusion. When things go wrong, fragmented regulation makes it harder to identify which body should have prevented the failure and which body should lead the response. The post-Grenfell landscape saw extensive debate about whether the then-Department for Communities and Local Government, the HSE, local building control, or product safety regulators bore primary responsibility for the regulatory failures.The government's consultation document argued that a Single Construction Regulator would address these issues by creating "a single point of accountability for the regulation of buildings, construction products, and the competence of those working on buildings."
The consultation document outlined several areas of consolidation. While the final shape of the regulator will depend on the government's response and subsequent legislation, the proposal covered the following areas.
The BSR's current functions — higher-risk building registration, building control for higher-risk buildings, Accountable Person oversight, mandatory occurrence reporting, and safety case management — would transfer into the new regulator. This is the most straightforward element, especially since the BSR has already taken the first step: it became a standalone body on 27 January 2026, leaving the HSE to operate as an arm's-length body under MHCLG. This move was explicitly described by the government as "paving the way for the creation of a single construction regulator."
For building managers, your primary regulatory relationship has already shifted from a division within HSE to an independent body. The next step — absorbing the BSR into the broader Single Construction Regulator — would expand its scope but not fundamentally change your existing relationship. The nature of your obligations — maintaining the golden thread, managing your building safety case, reporting occurrences, engaging with residents — would not change in substance.
OPSS's construction product safety functions would transfer to the new regulator. This is significant because it would bring product regulation and building regulation under the same roof for the first time. A regulator overseeing both the products that go into buildings and the buildings themselves would be better positioned to identify and act on product safety failures before they become building safety failures.
For building managers, this could simplify the process when you identify a potentially unsafe construction product in your building. Instead of navigating between the BSR (for building-level concerns) and OPSS (for product-level concerns), you would report to one body that could assess both the product risk and the building-level implications.
The consultation proposed bringing oversight of professional competence in construction under the new regulator. Currently, the BSR has a role in overseeing building control professionals and building inspectors, but competence standards for the wider construction workforce — designers, contractors, fire engineers, and other specialists — sit with individual professional bodies.
The proposal would not necessarily replace professional bodies, but it would create a single regulatory framework for construction competence. The new regulator would set minimum competence standards, oversee professional body compliance with those standards, and have powers to intervene where competence failures contribute to building safety risks.
The consultation also raised the possibility of bringing building standards policy — currently led by MHCLG — closer to the new regulator. This could mean the regulator has a formal role in advising on or drafting building regulations and Approved Documents, drawing on its frontline enforcement experience.
This is the most politically sensitive element. Building standards policy has traditionally been a ministerial function, and there is a tension between giving an independent regulator policy-setting powers and maintaining democratic accountability for regulatory decisions. The consultation asked for views on the appropriate boundary between the regulator's technical expertise and ministerial policy-making.
The relationship between the new regulator and local authority building control was one of the more complex areas in the consultation. The BSR already oversees building control for higher-risk buildings, but local authorities retain building control functions for the vast majority of construction work.
The consultation proposed several models: full absorption of local authority building control into the new regulator, a supervisory model where local authorities continue to deliver building control under the new regulator's oversight, or a mixed model where certain categories of building work transfer to the new regulator while local authorities retain others.
For building managers of higher-risk buildings, the practical impact depends on which model is adopted. You already deal with the BSR for building control matters; a transfer to a new standalone regulator would change the nameplate but not necessarily the process. For managers of buildings below the higher-risk threshold, a shift from local authority building control to a national regulator could be more significant — potentially bringing more consistent standards but also potentially losing local knowledge and responsiveness.
The government consultation is still open and closes on 20 March 2026. You can respond via GOV.UK.} after={<>The government consultation closed on 20 March 2026. Here is the expected timeline for what comes next.} />
The creation of a Single Construction Regulator is a multi-year process. Here is what the timeline looks like based on the consultation document and standard legislative procedure:
17 December 2025: Government publishes the Single Construction Regulator Prospectus consultation document, seeking views from the industry, building managers, residents, and other stakeholders. 27 January 2026: The BSR leaves the HSE and becomes a standalone arm's-length body under MHCLG — the first concrete step toward the single regulator. 20 March 2026: Consultation closes. The government will review all responses and develop its formal position. Summer 2026 (expected): Government publishes its consultation response, confirming which elements of the proposal it intends to proceed with, any modifications based on consultation feedback, and the planned legislative vehicle. 2027 (planned): Primary legislation introduced to Parliament. This would likely be a new Act or a significant amendment to the Building Safety Act 2022, creating the legal basis for the new regulator, defining its powers and functions, and setting out the transfer arrangements for existing regulatory bodies. 2028-2029 (estimated): Assuming legislation passes, the new regulator would begin a transition period — establishing its governance, recruiting leadership, transferring staff and functions from existing bodies, and building operational capability. Based on precedent (the BSR itself took approximately two years from the Building Safety Act receiving Royal Assent in April 2022 to becoming fully operational in April 2024), a transition period of 18-24 months is realistic. 2029-2030 (estimated): The Single Construction Regulator becomes fully operational, with all planned functions consolidated under the new body.These are estimates based on standard legislative timelines. Political events, parliamentary scheduling, and the complexity of institutional transfers could accelerate or delay the process. The key milestone to watch is the government's consultation response in summer 2026 — that will confirm whether the proposal is proceeding, in what form, and on what timeline.
If you manage a higher-risk building, the creation of a Single Construction Regulator would affect you — but not immediately, and probably not as dramatically as you might expect. Here is a realistic assessment of what changes and what does not.
The single construction regulator proposal follows the Building Safety Regulator's experience regulating higher-risk buildings, extending consistent regulatory oversight across all building types and construction phases.
The case for a Single Construction Regulator is inseparable from the lessons of the Grenfell Tower fire and its aftermath. The Grenfell Tower Inquiry Phase 2 report, published in September 2024, documented how regulatory fragmentation contributed to the conditions that allowed the fire to happen and to cause such devastating loss of life.
The inquiry found that multiple regulatory bodies each held a piece of the picture but none had the full view. The building control system approved the use of materials that the product safety system had not adequately tested. Professional competence standards failed to ensure that those designing, specifying, and installing cladding systems understood the fire risks. Government policy on building standards did not keep pace with the risks created by new materials and construction methods.
Dame Judith Hackitt's Independent Review of Building Regulations and Fire Safety, published in May 2018, had already identified regulatory fragmentation as a systemic weakness. Her review recommended a new regulatory framework with a "clear model of risk ownership" — a principle that the Building Safety Act 2022 partially implemented through the creation of the BSR, but that the Single Construction Regulator proposal would take further by consolidating all construction-related regulatory functions.
The government's consultation document explicitly positioned the Single Construction Regulator as the completion of the Grenfell reform programme. The Building Safety Act created new duties and new enforcement mechanisms; the Single Construction Regulator would create the institutional structure to deliver them effectively.
The proposal to consolidate construction regulation follows a pattern seen in other UK sectors where fragmented oversight led to regulatory failure:
Financial services. After the 2008 financial crisis, the Financial Services Authority was replaced by a two-body model — the Prudential Regulation Authority (within the Bank of England) and the Financial Conduct Authority. The reform was driven by the same diagnosis: a single crisis exposed failures across multiple regulatory functions that no single body was responsible for addressing. Aviation. The Civil Aviation Authority (CAA) regulates aircraft safety, airline operations, airport standards, and aerospace manufacturer oversight under one roof. The construction sector has historically lacked an equivalent single body. Nuclear. The Office for Nuclear Regulation (ONR) was created in 2014 by separating nuclear safety regulation from HSE into an independent statutory body — notably the same trajectory building safety regulation is now following. The BSR's move out of HSE in January 2026 mirrors the ONR's separation. The ONR precedent is directly relevant: it demonstrates that safety-critical regulatory functions can be successfully separated from HSE into an independent body with enhanced powers and accountability.The ONR precedent is worth watching closely. It took approximately three years from the Energy Act 2013 (which created the legal basis for ONR) to full operational independence. A similar timeline for the Single Construction Regulator would align with the estimated 2028-2029 operational date.
Nothing about this proposal requires immediate action. The consultation has closed, legislation is at least a year away, and the regulator itself is several years from becoming operational. But there are practical steps you can take now to ensure you are well-positioned when changes come.
This may sound obvious, but it is the single most important thing you can do. The Building Safety Act duties — building registration, golden thread maintenance, safety case management, resident engagement, mandatory occurrence reporting — are in force now and will remain in force regardless of which body enforces them.
A building manager who is fully compliant with current BSA requirements will be well-positioned for any regulatory transition. A building manager who has been hoping the system will change before they need to comply will be caught out. Building safety compliance software ensures your records, risk assessments, and evidence trails are structured and ready for whoever the regulator turns out to be.
Read the BSA compliance checklist →The golden thread — the digital record of your building's design, construction, and ongoing management — is exactly the kind of information a new regulator would want to see when it takes over regulatory oversight. If your golden thread is well-maintained and accessible, a change of regulator is a minor administrative adjustment. If your records are scattered across spreadsheets, email inboxes, and filing cabinets, a transition period is when gaps become visible.
The key milestone is the government's consultation response, expected in summer 2026. This will confirm:
If you are a member of a professional or industry body — The Property Institute (formerly IRPM and ARMA), RICS, or others — they will be monitoring the government's response and advocating for their members' interests during the legislative process. Staying connected to your industry body ensures you hear about changes early and have a channel to raise concerns about how the transition is managed.
Keep a record of which regulatory bodies you currently interact with, for what purpose, and how often. When the transition happens, this information will help you map your existing obligations to the new regulator's structure and identify any gaps or changes in the process.
The Single Construction Regulator is a proposed new body that would consolidate oversight of building safety, construction product safety, and professional standards into one organisation. It was proposed in a government consultation that closed on 20 March 2026, with legislation expected in 2027.
The proposal would consolidate functions currently spread across the Building Safety Regulator (now a standalone arm's-length body under MHCLG since January 2026), the Office for Product Safety and Standards (within the Department for Business and Trade), local authority building control, and elements of MHCLG's building standards division. These bodies would not necessarily be abolished but their construction-related functions would be unified.
The government consultation closed on 20 March 2026. A formal response is expected in summer 2026, with primary legislation anticipated in 2027. The BSR has already left the HSE as a first step. The full single regulator would likely not be operational until 2028 or 2029, given the time required for legislative passage and institutional setup.
Building managers would eventually report to one regulatory body instead of navigating multiple agencies. Day-to-day compliance obligations under the Building Safety Act 2022 are unlikely to change in substance, but enforcement, guidance, and reporting channels would be consolidated. The transition period will require monitoring.
No immediate changes are needed. Continue complying with existing Building Safety Act requirements, maintain your golden thread records, and monitor the government's response expected in summer 2026. The best preparation is strong compliance with current obligations.
{/ snippet-target: definition | query: "what is a building safety case" /}
A building safety case is the totality of your assessment and management of building safety risks. It is an ongoing process, not a one-off document, covering fire safety, structural integrity, and any other risks to people in or about the building.>
— Building Safety Act 2022, s.85
A building safety case is the structured, ongoing process of identifying, assessing, and managing fire and structural safety risks in a higher-risk building. It encompasses all risk assessments, safety measures, maintenance regimes, and evidence demonstrating that risks are being effectively managed under the Building Safety Act 2022.
The term can be confusing because it sounds like a single thing -- a document, a report, a file to produce. It is not.
Your building safety case is the totality of how you manage building safety risks. It includes every risk assessment you have conducted, every safety measure in place, every maintenance record, every contractor certification, every incident you have responded to, and every decision you have made about what risks to prioritise and how to manage them.
Think of it as the answer to this question: "How do you know your building is safe, and how can you prove it?"
The Building Safety Act 2022 formalised this concept. Under section 83, the Accountable Person must assess building safety risks. Under section 84, they must take all reasonable steps to prevent major incidents and reduce their severity. And under section 85, the Principal Accountable Person must prepare a Safety Case Report summarising this work.
Together, sections 83-85 create the safety case framework: assess, manage, document.
For an overview of Accountable Person duties -- including who qualifies and what the role involves -- see our Accountable Person duties explainer.
This distinction causes the most confusion, so it is worth being explicit.
The Safety Case Report is a formal summary document required under section 85. It is reviewed by the Building Safety Regulator as part of the Building Assessment Certificate application.>
— Building Safety Act 2022, s.85
| | Safety Case | Safety Case Report | |---|---|---| | What it is | Your ongoing approach to managing building safety | A formal document summarising the safety case | | When you maintain it | Continuously, throughout the building's life | Prepared at a point in time, updated as things change | | What it contains | All risk assessments, safety measures, maintenance records, evidence, decisions | A structured summary of risks, measures, and management approach | | Legal basis | Sections 83-84 (assessment and management duties) | Section 85 (report preparation duty) | | Analogy | Running a business | Writing the annual report |
The BSR assesses whether your ongoing safety management is adequate -- not just whether your paperwork looks professional. A well-formatted report describing a poor safety case will not pass assessment. A thorough safety case documented in a clear report will.
Imagine you manage a 15-storey residential tower built in 1985. Over the past two years, you have:
Now compare that with a building where the fire risk assessment was done three years ago, no one can say which actions were completed, the fire door programme was abandoned halfway through, and the records are scattered across email chains and a filing cabinet. That building has a safety case too -- it is just a poor one, and it would be very hard to write a credible report about it.
The Building Safety Act defines building safety risks as risks to people from the spread of fire or structural failure. Your safety case must address both categories across every part of your building.
Your safety case for fire should cover:
Your safety case for structural safety should cover:
Your safety case is only as strong as your evidence. For every risk identified and every measure taken, you need:
For guidance on maintaining your Golden Thread, see our Golden Thread guide.
The Building Safety Regulator does not assess your building against a fixed checklist. Assessment is proportionate and building-specific -- what the BSR expects depends on your building's type, age, height, construction, and the risks it presents.
The BSR assesses five key areas: expected safety measures for your building type, their effectiveness and maintenance, action on legacy issues, aspects not built to current standards, and evaluation of additional measures needed.
When the BSR calls your building in for a Building Assessment Certificate application, your safety case is at the centre of the assessment. The BSR considers five key areas:
For the full step-by-step process of preparing your Safety Case Report, see our Safety Case Report preparation guide.
If you have not started your safety case, the prospect can feel overwhelming. But the safety case is not something you create from scratch -- it is something you assemble from the building management activities you are already doing (or should be doing).
Here is a practical starting point:
Most building managers already hold relevant information, even if it is not organised as a "safety case." Gather:
With your existing information assembled, the gaps become visible. Common gaps include:
Address the most critical gaps first -- those relating to fire safety systems, compartmentation, and structural safety. Commission assessments where needed. Set up tracking for actions. Build the evidence base.
Your safety case evidence must be part of your Golden Thread -- kept in electronic format, version-controlled, and accessible. Purpose-built building safety case software is the most efficient approach, but at minimum you need a structured digital filing system with clear categories, dates, and access controls.
Once your safety case is assembled and gaps are being addressed, the Safety Case Report becomes a summarisation exercise -- not a creative writing project. You are describing what exists, what you have done, and what you plan to do next.
For the detailed report preparation process, including a template outline aligned with BSR assessment criteria, see our Safety Case Report guide.
Understanding how the BSR enforces compliance -- and the protections available through the due diligence defence -- can help you approach your safety case with confidence rather than anxiety. See our guide to Building Safety Act penalties and non-compliance for the full picture of enforcement, including the BSR's graduated approach.
A building safety case is the structured approach to managing building safety risks in a higher-risk building. It is the totality of your risk assessments, safety measures, maintenance regimes, and evidence that demonstrates you are managing fire and structural risks effectively. It is not a single document but an ongoing process required under the Building Safety Act 2022.
The safety case is your ongoing process of managing building safety risks -- all your assessments, measures, and evidence. The Safety Case Report is the formal document that summarises the safety case at a point in time, required under section 85 of the Building Safety Act 2022. The report documents the case; you maintain the case continuously.
The Principal Accountable Person (PAP) -- typically the freeholder -- has the primary legal duty to maintain the building safety case and prepare the Safety Case Report. All Accountable Persons must cooperate by providing information about risks and measures in their part of the building. For an overview of Accountable Person duties, see our explainer.
There is no single deadline. The Building Safety Act requires the Safety Case Report to be prepared "as soon as reasonably practicable." The practical trigger is when the BSR calls your building in for Building Assessment Certificate assessment, giving you 28 days to submit your application including the Safety Case Report.
Without a safety case, you cannot produce the Safety Case Report required under section 85, which will result in your Building Assessment Certificate application being refused. More seriously, non-compliance that gives rise to a risk of death or serious injury is a criminal offence under section 101, punishable by imprisonment, an unlimited fine, or both.
You know the one. It started as a quick tracker — maybe for fire risk assessment actions, maybe for fire door inspections. Someone added a tab for contractor details. Another tab for resident contact information. A few macros to calculate overdue items. It's grown into the thing your entire compliance operation depends on.
Section 88 of the Building Safety Act places a duty on Accountable Persons to create, maintain, and share building safety information in a prescribed digital format. A spreadsheet on a shared drive does not meet this standard.>
— Building Safety Act 2022, s.88
Here's the problem: that spreadsheet is doing a job it was never designed for, and the Building Safety Act 2022 has made that a legal issue, not just an operational one.
Section 88 of the Building Safety Act 2022 places a duty on Accountable Persons to create, maintain, and share building safety information in a prescribed format. The Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2024 spell out exactly what that means. And the Higher-Risk Buildings Procedures Regulations 2023 go further — requiring an "electronic facility" for storing and managing Golden Thread information with controlled access.
A spreadsheet on someone's laptop is not an electronic facility. A shared Excel file on OneDrive is not an electronic facility. Let's look at why.
The Higher-Risk Buildings Procedures Regulations 2023 require an "electronic facility" for storing Golden Thread information with controlled access — a standard that spreadsheets fundamentally cannot meet.>
— Higher-Risk Buildings Procedures Regulations 2023
The Golden Thread must be accurate and up to date. When three people edit the same spreadsheet, which version is current? When someone overwrites a formula or deletes a row, there's no record of what changed, when, or why.
A building with 40 fire risk assessment actions needs a clear history: when was each action raised, who was assigned, what evidence was uploaded, and when was it signed off? In a spreadsheet, that history lives in people's memories. In a compliance notice scenario, memories don't count.
The BSR can request your Golden Thread information at any time. When they do, they want to see not just the current state but how you got there. Every decision, every update, every piece of evidence — linked and traceable.
Spreadsheets don't log who changed cell B47 on Tuesday. They don't record that a contractor uploaded a fire stopping certificate on 14 March. They don't prove that you reviewed and actioned your fire risk assessment within the required timeframe. A purpose-built compliance system timestamps every change with the user's identity — creating a tamper-proof chain that holds up when the BSR asks "show me how you managed this." You can say you did all these things. A spreadsheet just can't prove it.
The Regulations require that Golden Thread information is accessible to those who need it — and only to those who need it. That means controlled access, not "anyone with the link can edit."
Think about what's in your compliance spreadsheet: resident names, contact details, flat-specific vulnerability information for PEEPs. Under GDPR, that data needs protection. Under the BSA, it needs to be shareable with the BSR on request. A spreadsheet gives you neither proper protection nor structured sharing.
A spreadsheet can say "Action 12: Replace fire door, Flat 4B — Complete." But where's the evidence? The contractor's completion photo is in an email. The invoice is in a shared drive. The sign-off is a text message. Nothing is linked. Nothing is findable under pressure.
The Golden Thread requires information to be stored "in a simple format that is easy to understand." A scavenger hunt across email, WhatsApp, and shared drives is not simple. In a compliant system, evidence is attached directly to the action it relates to — a contractor uploads a completion photo via a magic link, and it's automatically linked to the fire risk assessment action, timestamped, and visible in the audit trail. No chasing. No filing. When the BSR asks for evidence of how you're managing fire safety risks, it's one click away.
Your Safety Case Report needs to demonstrate that you're actively managing building safety risks. That means showing what's overdue, what's in progress, and what's been completed — with evidence.
Building that picture from a spreadsheet means hours of manual work: filtering, cross-referencing tabs, chasing people for updates, hoping the data is current. And the moment you export it, it's already out of date. A compliance platform with a live dashboard — showing overdue items, in-progress work, and completed actions with evidence — generates this view in real time. Some platforms can even auto-generate Safety Case Report PDFs from live compliance data, pulling together fire risk assessment actions, checks, issues, and documents into the structured format the BSR expects.
Compare Brocade to spreadsheet tracking ->Let's be specific about what the Golden Thread demands, because "keep good records" undersells it:
Information scope — The Higher-Risk Buildings Regulations 2024 require you to maintain summaries of fire risk assessments, safety case reports, structural information, maintenance records, and resident engagement strategies. This isn't one spreadsheet tab. It's a structured information system. Accessibility — Information must be "accessible" and "in a simple format that is easy to understand and written in plain English." This means anyone reviewing it — your co-Accountable Person, a BSR inspector, a new building manager taking over — should be able to find what they need without decoding your spreadsheet conventions. Digital storage — The Procedures Regulations 2023 explicitly require an "electronic facility" with procedures for access. This isn't optional. Paper records and local files don't meet the standard. Shareability — The Principal Accountable Person must be able to provide information to the BSR when requested. If your records are scattered across personal devices, you have a problem.This isn't a box-ticking exercise with a small penalty for non-compliance. Under Section 99 of the Building Safety Act, failure to comply with a compliance notice is a criminal offence. If the BSR inspects your building, finds your Golden Thread information inadequate, issues a compliance notice, and you can't fix it — that's a criminal matter.
Under Section 99 of the Building Safety Act, failure to comply with a compliance notice about inadequate record-keeping is a criminal offence. The BSR does not need to prove building damage — only that information was not kept as required.>
— Building Safety Act 2022, s.99
The BSR doesn't need to prove something went wrong with the building. They need to prove you weren't keeping information as required. A spreadsheet with broken formulas, missing version history, and no audit trail is evidence of exactly that.
A compliant Golden Thread system doesn't need to be complicated. It needs to be:
If you're currently running compliance on spreadsheets, the move to a proper system is less painful than you think:
No. The Building Safety Act 2022 and the Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2024 require an electronic facility that maintains accessible, up-to-date building safety information with controlled access. Spreadsheets lack version control, audit trails, and access management, so they do not satisfy these requirements.
The Golden Thread requires you to create and maintain accurate, up-to-date building safety information throughout the building's lifecycle. This includes fire risk assessments, safety case reports, structural information, and maintenance records. Information must be stored digitally, kept in plain English, and be accessible to those who need it.
An electronic facility is a digital system for storing and managing Golden Thread information, as required by the Higher-Risk Buildings Procedures Regulations 2023. It must support controlled access, version management, and the ability to share information with the Building Safety Regulator on request.
If the Building Safety Regulator determines that your record-keeping does not meet the requirements of Section 88 of the Building Safety Act, they can issue a compliance notice. Failure to comply with a compliance notice is a criminal offence under Section 99 of the Act.
Start by auditing what information you currently hold and where the gaps are. Then choose a purpose-built compliance platform that meets Golden Thread requirements — including version control, access management, and audit trails. Migrate your existing records, verify completeness, and establish processes for keeping information current.
The Building Safety Act 2022 created a clear chain of responsibility for every higher-risk building in England. At the centre of that chain is the Accountable Person -- the person or organisation legally answerable for building safety.
Every higher-risk building in England must have at least one Accountable Person who takes legal responsibility for assessing and managing building safety risks, including fire spread and structural failure.>
— Building Safety Act 2022, s.72
Under section 72 of the Act, you are an Accountable Person if you:
Where there is only one AP, that person is automatically the Principal Accountable Person (PAP) under section 73. Where there are multiple APs, the one who holds the legal estate in the structure and exterior becomes the PAP, with additional coordination duties.
For a detailed breakdown of the PAP role and how to determine whether you hold it, see our Principal Accountable Person responsibilities guide. For a side-by-side comparison of exactly which duties fall on APs versus the PAP, see Accountable Person vs Principal Accountable Person.
Imagine you manage a 12-storey residential tower with 60 flats. The freehold is held by a property company. The internal common areas -- lobbies, corridors, stairwells -- are maintained by a Resident Management Company (RMC) under the terms of the lease.
In this building, there are two Accountable Persons:
The Building Safety Act sets out specific obligations for every AP. These are legal requirements, not optional best practices. Here is what each one means in practice.
Non-compliance with Accountable Person duties that gives rise to a risk of death or serious injury is a criminal offence, punishable by up to two years' imprisonment or an unlimited fine.>
— Building Safety Act 2022, s.101
Under section 83, you must assess building safety risks in the parts of the building you are responsible for. A building safety risk is defined as a risk to people from the spread of fire or structural failure.
This is not a one-off assessment. You must review it regularly and update it whenever circumstances change -- after building works, safety incidents, or new information about construction materials.
What this looks like in practice: Commission a competent fire safety assessor. Document every finding. Track every action to completion with evidence. A building with 40 fire risk assessment actions where 35 are complete with photographic evidence tells a fundamentally different compliance story than a building with an assessment report filed in a cabinet and no record of what happened next.It does not require perfection. It requires proportionate, documented, ongoing effort. If a fire risk assessment identifies damaged fire stopping in service risers, "all reasonable steps" means commissioning a specialist contractor, setting a completion timeline, and implementing interim measures while the work is done. It does not mean waiting until the budget cycle allows for it.
Under section 88, you must contribute to the building's Golden Thread -- the complete, digital, up-to-date record of all building safety information. For the parts of the building you are responsible for, you must keep accurate records in electronic format.
This includes structural records, fire safety system documentation, maintenance logs, contractor certifications, and risk assessment findings. The records must be accessible to relevant persons -- including the PAP, other APs, and the BSR when requested.
For practical guidance on setting up and maintaining your Golden Thread, read our Golden Thread guide.
The Safety Case Report is a formal document demonstrating how building safety risks are identified, assessed, and managed. Under section 85, the PAP has the primary duty to prepare it, but every AP must cooperate by providing information about the risks and measures in their part of the building.
If you are the sole AP (and therefore the PAP), the Safety Case Report is entirely your responsibility. For an overview of what a building safety case involves and why it matters, see our guide to building safety cases. For the step-by-step preparation process, see the Safety Case Report guide.
Read the PAP responsibilities guideUnder section 87, you must report certain safety occurrences to the BSR. These include structural failures, fire spread beyond the room of origin, failure of fire safety systems, and any event creating a significant risk to life.
The reporting process has two stages:
For a detailed guide on what to report and how, see Mandatory Occurrence Reporting: What Building Managers Must Report and When.
If your building has multiple Accountable Persons, cooperation is a legal duty -- not a courtesy. You must share information, coordinate on risk management, and ensure there are no gaps in safety coverage between different parts of the building.
In practice, this means regular communication with the PAP, shared access to relevant Golden Thread records, and clear agreements about who is responsible for what. The BSR will not accept "I thought the other AP was handling that" as a defence.
Under section 91, you must contribute to the building's residents' engagement strategy. Residents have the right to be informed about building safety, consulted on safety decisions, and provided with a mechanism for raising concerns.
This is not about sending an annual newsletter. Effective engagement means residents know who is responsible for building safety, understand the measures in place, and have a clear path for reporting concerns. For practical guidance on building your engagement strategy -- including Residents' Panels, communication channels, and the section 93 complaints system -- see our resident engagement strategy guide.
The enforcement framework is designed to be proportionate but serious. Understanding it helps you prioritise your efforts.
A due diligence defence is available to Accountable Persons who can demonstrate they took all reasonable steps to comply with their duties under the Building Safety Act.>
— Building Safety Act 2022, s.101(4)
There is an important protection: it is a defence to show that you took all reasonable steps to comply. This is why documentation matters so much. Your Golden Thread records, risk assessments, maintenance logs, and contractor certifications are not just compliance obligations -- they are your evidence that you were acting responsibly.
A building that can show a structured approach to risk management, regular assessments, tracked actions, and evidenced maintenance is in a fundamentally different legal position from one that cannot.
The BSR has several enforcement powers short of criminal prosecution:
If you have just discovered you are an Accountable Person -- or you have known for a while but have not acted -- here is where to start. You do not need to do everything at once, but you do need to start.
{/ snippet-target: faq | query: "accountable person building safety act" /}
An Accountable Person (AP) is a person or organisation with legal responsibility for the safety of a higher-risk building in England. Under section 72 of the Building Safety Act 2022, you are an AP if you hold a legal estate in possession in any part of the building's common parts, or if you have a repairing obligation for those common parts.
Accountable Persons must assess building safety risks under section 83, take all reasonable steps to prevent major incidents under section 84, maintain the Golden Thread of building information under section 88, contribute to the Safety Case Report under section 85, report safety occurrences to the Building Safety Regulator, and cooperate with the Principal Accountable Person.
Non-compliance that gives rise to a risk of death or serious injury is a criminal offence under section 101 of the Building Safety Act. The Building Safety Regulator can issue compliance notices and contravention notices. However, a due diligence defence is available if you can demonstrate you took all reasonable steps to comply.
Not always. Every higher-risk building has at least one Accountable Person, and the AP who holds the legal estate in the building's structure and exterior is designated the Principal Accountable Person (PAP) under section 73. If there is only one AP, they are automatically the PAP. If there are multiple APs, the one who owns the structure and exterior is the PAP.
No. A managing agent acts on behalf of the building owner but does not hold a legal estate in the building or have a statutory repairing obligation. The freeholder or other entity holding the legal estate remains the Accountable Person. The agent carries out management tasks, but the legal responsibility stays with the AP.
That's the test. Not whether you had a fire risk assessment done — but whether you can show exactly what actions came out of it, who was responsible, what evidence proves completion, and when each step happened.
The Principal Accountable Person must demonstrate that building safety risks are being actively managed. Fire risk assessment action tracking is the primary evidence the Building Safety Regulator uses to evaluate this.>
— Building Safety Act 2022, s.85
Every fire risk assessment produces action items: fix the fire door on level 3, replace the emergency lighting in the stairwell, clear the combustible storage from the bin room. Each of those actions needs to be tracked from identification through to verified completion. Not in your head. Not in an email thread. In a documented, auditable system.
Under the Building Safety Act 2022, the Principal Accountable Person must demonstrate that building safety risks are being actively managed. Your fire risk assessment action tracking is the primary evidence for that. The BSR's guidance on safety case reports reinforces that you must show ongoing management of fire risk, not just a one-off assessment.
{/ snippet-target: step-list | query: "fire risk assessment tracking" /}
For each action item from your fire risk assessment, record:
Every fire risk assessment action must be traceable from the original assessment through to verified completion with evidence. Breaking this chain breaks the Golden Thread.
For contractor-assigned work, you need a way for them to confirm completion. Chasing contractors by email and then manually updating a spreadsheet is how things fall through the cracks.
If you're using spreadsheets, this is nearly impossible to maintain reliably. Every manual edit overwrites the previous state. There's no automatic timestamp, no record of who made the change, and no way to prove the history hasn't been altered.
Here's a concrete checklist. For every fire risk assessment action, you should be able to produce:
Your Safety Case Report is the document that proves your building is safely managed. Fire risk assessment action tracking is one of its most important inputs.
When the BSR requests your Safety Case Report — and they can do this at any time since October 2024 — they expect to see:
Since January 2023, the Fire Safety (England) Regulations 2022 require:
If your building has 50 flats, that's 200 flat-door checks per year plus common area doors. Tracking these on paper or in a spreadsheet becomes unmanageable quickly.
You have two realistic options for fire risk assessment action tracking at scale:
Option 1: Structured spreadsheet. Workable for a single building with fewer than 20 active actions. You'll need columns for every field listed above, disciplined version control, and a separate evidence filing system. The audit trail will be manual and fragile. Option 2: Purpose-built compliance platform. Designed for this exact workflow. Actions are created from the fire risk assessment, assigned to contractors who upload evidence directly via secure links, status changes are timestamped and attributed automatically, and the audit trail is tamper-evident. This is what the BSR expects from higher-risk buildings managing dozens or hundreds of actions.Brocade is built specifically for this. Every fire risk assessment action gets a complete lifecycle — creation, assignment, contractor evidence upload, status tracking with automatic audit events, and a checksum-verified record chain. Contractors receive a secure link and upload evidence directly against the specific action without needing a login.
But regardless of which approach you choose, the documentation requirements are the same. The BSR doesn't care about your tools. They care about your records.
Use this to audit your current system:
Review your action list at least monthly. Check for overdue items, chase outstanding contractor work, and verify that completed actions have proper evidence attached. A quick monthly review prevents small gaps from becoming BSR-visible problems.
The tracking requirements still apply. If you have an existing fire risk assessment with outstanding actions, get them into a tracked system now. The BSR won't accept "this predates the Act" as a reason for incomplete records.
The Building Safety Act's full requirements apply to higher-risk buildings (7+ storeys or 18m+). However, the Regulatory Reform (Fire Safety) Order 2005 applies to all buildings with common areas. Good fire risk assessment tracking is best practice regardless of height.
Never permanently delete action records. If an action is no longer relevant (for example, the building layout changed), mark it as cancelled with a dated reason. Your audit trail should show why it was cancelled and by whom. Deletion destroys your Golden Thread.
The Building Safety Act 2022 regime entered a new phase in 2026. The Building Safety Regulator (BSR) is now an independent body with its own governance and enforcement powers. The Building Safety Levy has come into force, creating a dedicated funding stream for cladding remediation. And Personal Emergency Evacuation Plans (PEEPs) became a legal requirement on 6 April 2026. If you manage a higher-risk building, here is what changed, what it means for you, and what you need to do.
Check if your building qualifies as higher-riskIf you want a comprehensive overview of the full Building Safety Act -- what it covers, who it applies to, key roles, requirements, and penalties -- read our Building Safety Act Complete Guide.
On 27 January 2026, the BSR formally separated from the Health and Safety Executive (HSE) to become a standalone body under the Ministry of Housing, Communities and Local Government (MHCLG).
Since January 2025, the Building Safety Regulator operates as a standalone statutory body with direct enforcement powers, no longer part of the Health and Safety Executive.
This is not a bureaucratic reshuffle. It means:
The BSR's independence does not create new legal duties for building managers. Your obligations under the Building Safety Act 2022 remain the same. However, the practical implication is clear: enforcement will become more frequent and more rigorous.
Action items:The Building Safety Levy was introduced under Part 3 of the Building Safety Act and came into force in 2026. It creates a dedicated funding mechanism for remediating unsafe cladding on existing buildings across England.
The Building Safety Levy does not apply to existing building managers or leaseholders directly. You will not receive a levy bill. However, it signals three important things:
Personal Emergency Evacuation Plans become a legal requirement for higher-risk buildings on 6 April 2026 under the Fire Safety (Residential Evacuation Plans) (England) Regulations 2025.
Under the Fire Safety (England) Regulations 2022 as amended, Responsible Persons for higher-risk buildings must:
PEEPs implementation requires more than paperwork. Here is what effective compliance looks like:
Beyond the three headline changes, several other developments in 2026 affect higher-risk building managers:
The BSR is now actively processing Building Assessment Certificate applications and has signalled that rejection rates are significant. The most common reasons for refusal include incomplete Golden Thread records, gaps in fire risk assessment action tracking, and missing evidence of resident engagement. Your application is not a formality --- treat it as an assessment of how well you manage building safety. See our Building Assessment Certificate guide for a full preparation checklist.
The Building Safety Act's service charge provisions continue to tighten transparency requirements. Leaseholders have enhanced rights to information about building safety costs. If you are recovering safety-related expenditure through service charges, ensure your demands are itemised, documented, and defensible.
Read the complete Building Safety Act guideIf you manage a higher-risk building, here is where you should be right now. Use this as a gap analysis:
The Building Safety Regulator began calling in higher-risk buildings for Building Assessment Certificate assessment in October 2024, starting with buildings it considers highest priority.>
— Building Safety Act 2022, s.91
The BSR has enforcement powers under Part 4 of the Building Safety Act. These powers are being used.
Compliance notices (section 99): The BSR can issue a formal notice requiring specific actions to remedy building safety failings. Ignoring a compliance notice without reasonable excuse is a criminal offence --- punishable by up to 2 years' imprisonment on indictment, an unlimited fine, or both. Daily fines apply for each day the breach continues after conviction. Building Assessment Certificate refusal: If the BSR is not satisfied that you are managing building safety effectively, it will refuse your certificate application. Operating without a certificate means ongoing regulatory scrutiny. Safety case requests: The BSR can request your safety case report at any time. If you cannot produce one, or if it reveals that you are not managing risks effectively, expect enforcement action.The buildings that demonstrate compliance --- with structured, traceable records showing active management --- pass assessments without escalation. The buildings that cannot produce evidence face compliance notices, certificate refusals, and potential criminal liability.
Three major changes took effect in 2026: the Building Safety Regulator became an independent body separate from HSE on 27 January 2026, the Building Safety Levy came into force requiring developers of new higher-risk buildings to pay a charge towards remediation costs, and Personal Emergency Evacuation Plans became a legal requirement from 6 April 2026.
The Building Safety Levy is a charge on developers seeking building control approval for new higher-risk residential buildings in England. It funds the remediation of unsafe cladding on existing buildings. The levy does not apply to building managers or leaseholders directly, but it signals the government's commitment to long-term building safety funding.
The Building Safety Regulator formally separated from the Health and Safety Executive on 27 January 2026, becoming a standalone body under the Ministry of Housing, Communities and Local Government. This gives the BSR its own governance, budget, and enforcement priorities.
Personal Emergency Evacuation Plans (PEEPs) became a legal requirement on 6 April 2026 for all higher-risk buildings in England. Building managers must identify every resident who needs assistance evacuating and create an individualised evacuation plan for each person.
The BSR can issue compliance notices under section 99 of the Act. Failing to comply without reasonable excuse is a criminal offence punishable by up to 2 years' imprisonment, an unlimited fine, or both. The BSR can also refuse Building Assessment Certificate applications and impose daily fines for continuing breaches.
The Building Safety Act 2022 is the most significant reform to building safety regulation in a generation. It received Royal Assent on 28 April 2022 and created a comprehensive framework for managing the safety of higher-risk residential buildings throughout their entire lifecycle -- from design and construction through occupation and refurbishment.
The Building Safety Act 2022 received Royal Assent on 28 April 2022 and created the most fundamental change to how residential building safety is regulated in England since the Building Act 1984.>
— Building Safety Act 2022
The Act was Parliament's legislative response to the Grenfell Tower fire on 14 June 2017, in which 72 people died. Dame Judith Hackitt's Independent Review of Building Regulations and Fire Safety (2018) identified systemic failures in how buildings were designed, constructed, and managed. Her review found that critical building safety information was routinely lost, fragmented across different organisations, or simply never recorded. The Building Safety Act addresses those failures with a new regulatory structure, clear accountability, and enforceable requirements.
For building managers, the Act's practical impact is concentrated in Part 4, which deals with higher-risk buildings that are already occupied. This is where the day-to-day obligations fall -- maintaining records, assessing risks, reporting incidents, and engaging with residents. The rest of this guide focuses on Part 4 and its associated secondary legislation.
Check if your building qualifies as higher-riskThe Building Safety Act 2022 is a large piece of legislation -- 170 sections across 5 Parts, plus 11 Schedules. Understanding its structure helps you navigate which obligations apply to you.
| Part | Sections | What it covers | |------|----------|----------------| | Part 1 | 1-2 | Establishes the Building Safety Regulator | | Part 2 | 3-56 | Reforms to building control and the building regulations system (design and construction phase) | | Part 3 | 57-71 | Building control profession and competence requirements | | Part 4 | 72-115 | Higher-risk buildings in occupation -- the core compliance regime for building managers | | Part 5 | 116-170 | Leaseholder protections, remediation contributions, building liability orders, and miscellaneous provisions |
Part 4 is where building managers spend most of their time. It defines who is responsible (accountable persons), what they must do (risk assessment, Golden Thread, Safety Case, occurrence reporting, resident engagement), and what happens if they fail (enforcement notices, criminal offences).The Act itself sets the framework. The operational detail is in secondary legislation (Statutory Instruments) made under the Act:
The Act did not come into force all at once. Key commencement dates:
| Date | What came into force | |------|---------------------| | 28 April 2022 | Royal Assent -- Act passed into law | | 1 October 2023 | Part 4 regime commenced -- registration, accountable person duties, Golden Thread, Safety Case obligations | | 6 April 2024 | Higher-Risk Buildings (Keeping and Provision of Information) Regulations 2024 | | 27 January 2026 | Building Safety Regulator became an independent body (separated from HSE) | | 6 April 2026 | PEEPs requirements enforceable under the Fire Safety (England) Regulations 2022 |
A building is classified as higher-risk under the Act if it is at least 18 metres or 7 storeys tall, contains at least two residential units, and is in England. Height is measured from ground level to the floor surface of the top storey.>
— Building Safety Act 2022, Part 4
The Building Safety Act's Part 4 regime applies to higher-risk buildings (HRBs) in England. A building is a higher-risk building if it meets all of the following criteria, as defined in section 65 and the Higher-Risk Buildings (Descriptions and Supplementary Provisions) Regulations 2023:
| Criterion | Requirement | Detail | |-----------|-------------|--------| | Height | At least 18 metres or at least 7 storeys | Height measured from ground level to the floor surface of the top storey (not the roof). Storeys include basements if they contain a dwelling | | Residential units | At least 2 residential units | Domestic premises where someone lives. Includes flats, maisonettes, and residential parts of mixed-use buildings | | Location | England | Different regimes apply in Wales, Scotland, and Northern Ireland |
Buildings excluded from the Part 4 regime even if they meet the height and residential criteria:
For a detailed breakdown of height measurement, exclusions, and borderline scenarios, see our guide to higher-risk building criteria under the Building Safety Act.
The Part 4 regime focuses on the common parts of the building -- the structure, exterior, and shared areas. Individual flats are within scope only to the extent that they affect building safety (for example, a resident interfering with fire doors or compartmentation). Residents have their own duties under sections 95-97 to cooperate, not interfere with safety measures, and comply with information requests.
The Building Safety Act creates specific legal roles. Getting these right is the foundation of compliance -- and getting them wrong creates serious liability exposure.
The Building Safety Regulator is the body that oversees the new regime. Established under Part 1 of the Act, the BSR's functions include:
The Principal Accountable Person is defined in section 73 of the Act. The PAP is the accountable person who holds the legal estate in possession in the structure and exterior of the building.
In practice, the PAP is typically:
For a detailed breakdown of PAP obligations, see our Principal Accountable Person responsibilities guide. To understand how the PAP role relates to the Accountable Person role and where the boundaries of each fall, see our comparison of Accountable Person vs Principal Accountable Person.
An Accountable Person is defined in section 72 of the Act. An AP is anyone who:
Residents are not passive participants in the new regime. Under sections 95-97 of the Act, residents must:
Maintaining a digital Golden Thread touches every aspect of building management. It requires structured, version-controlled storage with audit trails -- which is why purpose-built platforms like Brocade exist: to serve as the Golden Thread with built-in compliance tracking, document management, and information sharing.
Under sections 83-85 of the Act, the PAP must:
A Safety Case Report should include:
| Step | Timeframe | What to submit | |------|-----------|----------------| | Occurrence notice | Within 10 working days of becoming aware | Initial notification that a reportable occurrence has happened | | Full occurrence report | Within the timeframe specified by the BSR | Detailed report covering what happened, root cause analysis, and remedial actions taken or planned |
Staff and contractors need to know what constitutes a reportable occurrence. Many incidents that feel like "just maintenance issues" -- a fire door that fails to close, a dry riser found to be non-functional, a missing compartmentation seal -- may need to be reported if they create a risk of significant harm.
For a practical guide to setting up your reporting system and understanding what to report, see our mandatory occurrence reporting guide.
See the full BSA compliance checklistUnder section 91 of the Act, the PAP must prepare and give effect to a residents' engagement strategy. This must describe how you will:
This is not a tick-box exercise. The BSR assesses whether the engagement strategy is genuine and effective, not just whether a document exists. Buildings where residents are actively informed and consulted demonstrate stronger compliance than those with a strategy document that sits in a drawer.
For practical guidance on building an effective engagement strategy, including what the BSR looks for during assessment, see our resident engagement strategy guide.
While PEEPs are technically enforced under the Fire Safety (England) Regulations 2022 rather than the Building Safety Act directly, they are a practical obligation for all higher-risk building managers. Since 6 April 2026, building managers must identify every resident who needs assistance evacuating and create an individualised evacuation plan for each person.
For detailed guidance, see our PEEPs implementation guide.
The Building Safety Act creates several financial dimensions that building managers need to understand.
Under section 90 of the Act, costs incurred by the accountable person in performing their Part 4 duties can be recovered through service charges from leaseholders, subject to the normal rules on service charge reasonableness and consultation.
This means the costs of maintaining the Golden Thread, preparing the Safety Case Report, conducting risk assessments, and meeting other compliance obligations are legitimate service charge expenditure. However, these costs must be reasonable, and leaseholders retain the right to challenge unreasonable charges through the First-tier Tribunal.
Major building safety works -- such as replacing external cladding, upgrading fire safety systems, or carrying out significant remedial works identified in the Safety Case -- may trigger Section 20 consultation requirements under the Landlord and Tenant Act 1985. If the cost to any individual leaseholder exceeds £250 for works or £100 annually for a long-term agreement, the formal consultation procedure applies.
For a detailed walkthrough of how Section 20 interacts with BSA safety works, including the three-stage process, dispensation applications, and practical approaches to managing the tension between safety urgency and consultation timelines, see our guide to Section 20 consultation and the Building Safety Act.
Failing to follow the Section 20 consultation process caps the amount you can recover from leaseholders, regardless of the actual cost. For building safety works that are genuinely urgent (immediate risk to life), there are provisions to dispense with consultation, but this requires a Tribunal application.
Part 5 of the Act includes significant protections for leaseholders regarding the costs of historical building safety defects -- particularly cladding remediation. These protections limit what leaseholders can be charged for remediation of defects that existed when the Act came into force, with the extent of protection depending on factors including the building's height, the responsible developer, and the leaseholder's property value.
The interaction between building safety costs, leaseholder protections, and service charge compliance is one of the most complex areas of building management. Getting it wrong exposes the accountable person to both regulatory and legal risk.
The Building Safety Act gives the BSR significant enforcement powers. Understanding these is important not to create alarm, but because the regime has real consequences and building managers need to take compliance seriously.
Under section 99, the BSR can issue a compliance notice requiring the PAP or AP to take specific steps within a set timeframe. This might include:
Under section 100, the BSR can issue a contravention notice identifying a specific contravention of Part 4 duties and requiring the person to remedy it within a specified period. Failure to comply is an offence.
The Building Safety Act creates criminal offences carrying unlimited fines and up to two years' imprisonment, but a statutory due diligence defence is available to those who took all reasonable steps to comply.>
— Building Safety Act 2022, ss.98-104
The BSR is not the only enforcement body relevant to building safety:
| Body | Scope | Key powers | |------|-------|------------| | Building Safety Regulator | Building safety risks, Golden Thread, Safety Case, registration, BAC, MOR | Compliance notices, contravention notices, prosecution | | Fire and Rescue Authority | Fire safety in common parts, fire risk assessment, PEEPs | Enforcement under the Fire Safety Order 2005 | | First-tier Tribunal | Disputes over service charges, accountable person duties, resident complaints | Orders, cost determinations | | Local Authority | Building control (for new works), housing standards | Building regulations enforcement |
If you are managing a higher-risk building, here is a practical compliance roadmap. Some of these steps should already be complete; others are ongoing obligations.
These are the patterns we see most frequently from building managers who are trying to comply but getting tripped up.
The Part 4 regime is in force now. Registration was required by October 2023. The Golden Thread, Safety Case, and occurrence reporting obligations are active. Building managers who assume enforcement is years away are exposed to criminal liability today.
The PAP -- typically the freeholder -- carries the legal duty. A managing agent can carry out tasks on behalf of the PAP, but the legal responsibility does not transfer. If the managing agent fails to maintain the Golden Thread or report an occurrence, it is the PAP who faces enforcement action.
The Act explicitly requires the Golden Thread to be maintained in digital format. A filing cabinet of paper records does not meet the legal requirement, regardless of how well-organised it is. The records must be digitally stored, accessible, version-controlled, and secure.
Key Building Information is what you submit to the BSR at registration. The Golden Thread is the comprehensive, ongoing record of all building safety information. KBI is a small subset of the Golden Thread. Submitting KBI does not mean your Golden Thread obligations are met.
A residents' engagement strategy that exists only on paper is not compliance. The BSR expects to see evidence of genuine engagement -- communications sent, complaints handled, consultations conducted. A document that sits in a drawer does not satisfy section 91.
Not recognising reportable occurrences is a common gap. A fire door that fails to close, a dry riser found non-functional during testing, or a missing compartmentation seal may all be reportable if they create a risk of significant harm. Train staff and contractors to identify and escalate potential MOR events.
Where there are multiple accountable persons, each must cooperate with the PAP. Buildings with complex ownership structures -- separate freeholders, management companies with repairing obligations, RTM companies -- need formal cooperation agreements that set out responsibilities, information sharing, and escalation procedures.
Ashworth Tower is a fictional 14-storey residential building in Birmingham with 52 flats. The freeholder is a registered company, making it the PAP. A managing agent handles day-to-day management under a management agreement.
Registration: The building was registered with the BSR in September 2023. KBI was submitted including details of the external wall system (render-on-blockwork, no ACM cladding) and fire safety systems (Type 1 fire alarm, dry riser, emergency lighting, AOV smoke ventilation). Golden Thread: The managing agent maintains building safety records using a digital compliance platform. All fire risk assessment actions, contractor evidence, maintenance records, and safety case documentation are stored with version control and audit trails. The PAP has read-only access to monitor compliance. Safety Case Report: The PAP commissioned a building safety consultant to prepare the initial Safety Case Report. Key risks identified: ageing fire doors on floors 6-14 (replacement programme in progress), dry riser requiring pump replacement (works scheduled for Q2 2026), and balcony drainage system affecting structural elements (monitoring programme established). Each risk has documented mitigation measures and review dates. Occurrence report: During a routine inspection, the dry riser was found to have failed a pressure test. The managing agent submitted an occurrence notice to the BSR within 8 working days, well inside the 10-day requirement. The full occurrence report documented the failure, root cause (pump degradation), interim risk mitigation (portable equipment stationed on upper floors), and the planned permanent fix. Residents' engagement: The managing agent sends quarterly building safety updates to all residents via email and post. An annual residents' meeting covers building safety alongside general management matters. A dedicated email address handles safety complaints with a 5-working-day response target. The engagement strategy document is available on the building's resident portal. BAC readiness: At 14 storeys with 52 units, Ashworth Tower has not yet been called in for a BAC. The PAP is monitoring BSR communications and preparing materials in advance, expecting a call-in within the next 12-18 months.This scenario illustrates what proportionate compliance looks like for a mid-size higher-risk building. The obligations are real, but manageable with structured processes and digital record-keeping.
The Building Safety Act 2022 is UK primary legislation that created a new regulatory regime for higher-risk residential buildings in England. It established the Building Safety Regulator, introduced mandatory safety cases and the Golden Thread of building information, and created criminal offences for non-compliance that risks death or serious injury. It received Royal Assent on 28 April 2022.
The Building Safety Act's Part 4 regime applies to higher-risk buildings in England that are at least 18 metres tall or at least 7 storeys, contain at least 2 residential units, and are not exclusively used as care homes, hospitals, or secure institutions. The height is measured from ground level to the floor surface of the top storey.
The Principal Accountable Person (PAP) carries overall legal responsibility for building safety. This is the person or organisation that holds the legal estate in the building's structure and exterior -- typically the freeholder. Other accountable persons may include anyone with a repairing obligation for common parts. Legal liability cannot be delegated to managing agents.
Non-compliance that gives rise to a risk of death or serious injury is a criminal offence under section 101, punishable by up to 2 years' imprisonment, an unlimited fine, or both. The Building Safety Regulator can also issue compliance notices under section 99, and failure to comply with a compliance notice without reasonable excuse is a further criminal offence.
The Golden Thread is a complete, digital, up-to-date record of building safety information that must be maintained throughout a higher-risk building's lifecycle. It is required under section 88 of the Building Safety Act and the Higher-Risk Buildings (Keeping and Provision of Information) Regulations 2024. It must include structural information, fire safety records, maintenance logs, and the Safety Case Report.
A Safety Case Report is a formal document summarising the assessment of building safety risks and the steps taken to manage them, required under section 85 of the Building Safety Act. The Principal Accountable Person must prepare it as soon as reasonably practicable. It is reviewed by the Building Safety Regulator as part of the Building Assessment Certificate application.
All higher-risk buildings in occupation in England were required to be registered with the Building Safety Regulator by 1 October 2023. If a building has not yet been registered, the PAP should treat this as an urgent priority and register immediately, as operating an unregistered higher-risk building is a criminal offence.
Book a demo to see how Brocade manages Building Safety Act compliance]]>The Golden Thread is a metaphor for something very practical: a continuous, traceable record of all the information needed to manage building safety throughout the life of a higher-risk building. It is the single source of truth about your building -- from its original design and construction through every change, inspection, assessment, and safety decision made during its occupation.
The Golden Thread is a complete, accurate, and up-to-date digital record of all building safety information for a higher-risk building, required under section 88 of the Building Safety Act 2022.>
— Building Safety Act 2022, s.88
The concept comes from Dame Judith Hackitt's Independent Review of Building Regulations and Fire Safety (2018), published in the wake of the Grenfell Tower tragedy. Hackitt found that critical building information was routinely lost, fragmented across different systems, or inaccessible to the people who needed it. Her review recommended a "golden thread" of information running through the life of every higher-risk building -- from initial design, through construction, into occupation, and across every change of ownership or management.
The Building Safety Act 2022 turned that recommendation into law. Section 88 places a duty on accountable persons to keep prescribed information about their higher-risk buildings. The Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2024 (SI 2024/41) fill in the detail -- specifying exactly what information must be kept, in what format, and how it must be provided to others.
In plain terms: if something is done to your building that affects safety, there should be a record of it in the Golden Thread. If someone needs to understand how the building was designed, what materials were used, what risks have been identified, or what maintenance has been carried out, they should be able to find that information in one place.
Check if your building qualifies as higher-risk →The Golden Thread requirement rests on two main pieces of legislation:
The Higher-Risk Buildings (Keeping and Provision of Information) Regulations 2024 prescribe two information categories: design and construction information, and occupation information including safety cases, fire risk assessments, and maintenance records.>
— SI 2024/41
The duty applies to all higher-risk buildings as defined by the Higher-Risk Buildings (Descriptions and Supplementary Provisions) Regulations 2023 (SI 2023/110) -- residential buildings in England that are at least 7 storeys tall or at least 18 metres in height and contain at least two residential units. If your building meets this threshold, the Golden Thread requirements apply.
The Building Safety Regulator (BSR), part of the Health and Safety Executive, enforces compliance. Under section 98 of the Building Safety Act, the BSR has powers to issue compliance notices requiring specific actions within set timescales. Failure to comply with section 88 is a criminal offence, and the BSR can pursue civil penalties and prosecution.
This is not a theoretical risk. The BSR has been building its enforcement capability since April 2024 and has publicly stated its intention to take action against non-compliant accountable persons. Having a well-maintained Golden Thread is not just a legal box to tick -- it is your primary evidence that you are managing building safety effectively.
Before going further, it helps to clarify two common confusions:
Golden Thread vs Key Building Information (KBI) Golden Thread vs Building Safety CaseYour building safety case report is one component of the Golden Thread, not the whole thing. The safety case demonstrates that you have identified the major risks in your building and are managing them. The Golden Thread is the broader information ecosystem that includes the safety case alongside design information, maintenance records, fire risk assessments, and everything else prescribed by SI 2024/41. For an overview of what a building safety case is and how it connects to the Golden Thread, see our explainer.
The Regulations 2024 (SI 2024/41) prescribe two broad categories of information in Schedule 1. Together, they form the complete picture of your building's safety throughout its life.
This covers the building's origins and any subsequent structural changes:
| Category | What to include | Examples | |----------|----------------|----------| | Original design | As-built drawings, architectural plans, structural designs | Floor plans, elevations, cross-sections, structural calculations | | Construction records | Materials used, methods, CDM documentation | Specifications for external wall systems, cladding details, fire stopping records | | Fire safety design | The fire strategy underpinning the building's design | Compartmentation strategy, means of escape design, fire detection and suppression system design | | Approvals and sign-offs | Building control approvals, planning consents | Completion certificates, approved inspector final certificates | | Refurbishment records | Any changes to original design or construction | Records of replacement cladding, window upgrades, structural alterations, service penetrations |
This covers the ongoing safety management of the occupied building:
| Category | What to include | Examples | |----------|----------------|----------| | Safety case report | Current assessment of major building safety risks and management measures | Risk register, mitigation strategies, residual risk assessment (see our Safety Case guide) | | Fire risk assessments | Current and historical FRAs, plus remediation tracking | Type 1-4 fire risk assessments, action plans, completion evidence, re-assessment records (tracking guidance) | | Mandatory occurrence reports | Reports of safety occurrences submitted to BSR | Structural failures, fire spread beyond compartment of origin, water ingress affecting common parts | | Resident engagement strategy | How you involve residents in building safety decisions (see our engagement strategy guide) | Communication plans, consultation records, resident panel minutes | | Maintenance records | Scheduled and reactive maintenance history | Lift servicing, fire alarm testing, sprinkler maintenance, electrical inspections, gas safety certificates | | Inspection reports | Professional inspections and surveys | EWS1 forms, intrusive wall surveys, electrical condition reports, lift LOLER inspections | | Building fabric changes | Any modifications during occupation | Internal layout changes, fire door replacements, service penetrations, external wall repairs | | Emergency planning | Evacuation strategies and emergency procedures | Evacuation plans, Personal Emergency Evacuation Plans (PEEPs), assembly point designations | | Complaints register | Safety-related complaints and concerns from residents | Reports of fire door damage, blocked escape routes, faulty alarms, suspected asbestos |
Read the complete BSA compliance checklist →The regulations are specific about how Golden Thread information must be stored. Paper records alone will not satisfy the requirement -- the Act explicitly requires electronic format.
The Golden Thread must be kept in electronic format with version control, controlled access, and the ability to share information with the Building Safety Regulator on request. Paper records alone do not comply.>
— Higher-Risk Buildings Procedures Regulations 2023
| Requirement | What it means | Compliant | Non-compliant | |-------------|--------------|-----------|---------------| | Electronic format | All information must be stored digitally | Cloud platform, structured database, digital document management system | Paper-only files, filing cabinets without digital backup | | Single accessible location | One authoritative source, not scattered across systems | Centralised platform with all records, or a master index linking to sub-systems | Information split across personal laptops, email inboxes, and shared drives with no index | | Kept up to date | Information reflects current state of the building | Version-controlled records updated after every change, inspection, or assessment | Static documents last updated at handover, no revision history | | Accessible to relevant persons | Those who need the information can find and use it | Role-based access for managers, accountable persons, BSR, and residents (as appropriate) | Records locked in one person's account with no delegation or sharing | | Understandable | Written so readers can act on it | Plain English summaries alongside technical documents, defined abbreviations | Technical jargon with no context, abbreviations without definitions | | Secure | Protected from unauthorised access, loss, or damage | Encrypted storage, access logging, regular backups, disaster recovery plan | Shared folder with no password, no backup strategy, single point of failure | | GDPR compliant | Personal data handled lawfully | Personal data (resident details, PEEPs) stored with appropriate legal basis and access controls | Resident personal data shared openly without consent or lawful basis |
A common question building managers ask is whether a spreadsheet can serve as a Golden Thread. The short answer: a spreadsheet can be part of your system -- perhaps as a gap analysis tracker or document index -- but it should not be the whole system.
Here is why. A spreadsheet does not natively provide version control (who changed what and when), role-based access controls (different people seeing different things), document storage (the actual plans, reports, and certificates), audit trails (proof of who accessed or updated records), or automated alerts when information becomes stale. These are all requirements, not nice-to-haves.
For a detailed look at why spreadsheet-based compliance tracking creates risk, see our analysis: Spreadsheets Are Not a Golden Thread.
Understanding which buildings fall under these requirements is the first step. For a detailed breakdown of the height, storey, and residential unit thresholds, see our guide to higher-risk building criteria under the Building Safety Act.
The Principal Accountable Person (PAP) has the primary legal duty under section 88 to ensure that prescribed information is kept and maintained. In most cases, the PAP is the person or organisation that holds the building lease or freehold and has responsibility for the structure and exterior of the building. For a full breakdown of PAP obligations, see our PAP Responsibilities guide.
The Principal Accountable Person has the primary legal duty to establish and maintain the Golden Thread. This responsibility cannot be delegated — though management tasks can be outsourced, legal accountability remains with the PAP.Accountable Persons (APs) -- which may include managing agents, Right to Manage (RTM) companies, or other parties responsible for specific common parts -- have duties for the information relating to their areas of responsibility.
Setting up a Golden Thread from scratch can feel daunting, especially if you are managing a building with incomplete historical records. This section breaks it into five practical steps.
Start by gathering everything you already have. You may be surprised how much information exists -- it is just scattered.
Your system needs to meet the format requirements from SI 2024/41 Regulation 6. At minimum, you need:
The key decision factor is sustainability: can you realistically maintain the system over years, through staff changes and contractor rotations, without the information becoming stale or disorganised? A sophisticated system that nobody uses is worse than a simple system that everyone keeps current.
Structure your records following the categories in SI 2024/41 Schedule 1:
For each category, you should be able to answer four questions: what documents do we have? Are they current? Who last reviewed them? Where are the gaps?
A Golden Thread is only useful if it stays current. A building with 300 documents that were last updated at handover is not compliant -- it is a snapshot, not a living record.
Assign clear responsibility for each information category. The maintenance contractor updates maintenance records after each visit. The fire risk assessor uploads the new fire risk assessment within a defined timeframe. The building manager logs complaints and concerns. When everyone knows their role, records stay current without a single person becoming a bottleneck. Set review schedules. Fire risk assessments are typically reviewed annually or after any significant change to the building. Maintenance records should be updated after each service visit. The safety case should be reviewed at least annually. Set calendar reminders so reviews do not slip. Define trigger events. Certain events should prompt immediate Golden Thread updates:Different people need different levels of access to your Golden Thread:
| Role | Access level | Why | |------|-------------|-----| | PAP and building managers | Full read/write access to all information | Primary duty holders -- need complete visibility | | Accountable Persons (APs) | Read/write for their areas, read access to shared information | Responsible for specific common parts | | Fire risk assessors and contractors | Upload access for their reports, limited read access | Need to submit records without seeing unrelated information | | BSR inspectors | Ability to provide requested information promptly | Section 89 compliance -- prompt response to regulatory requests | | Residents | Access to relevant safety information | Required by the Act -- residents have a right to certain building safety information |
Ensure your access controls are GDPR compliant. PEEPs contain sensitive personal data (disability information, mobility limitations) and require careful handling with restricted access and a clear lawful basis for processing.
See how Brocade maintains your Golden Thread digitally →These are the pitfalls we see most frequently. Avoiding them will save you time, reduce risk, and make BSR interactions smoother.
Some buildings still rely primarily on paper files. Even if those files are comprehensive and well-organised, they do not meet the electronic format requirement in section 88. You need a digitisation plan: scan existing paper records, set up digital processes for new information, and establish a clear transition date after which all records are digital-first. A building with 15 years of paper maintenance logs needs those logs scanned and indexed, not just filed in a better cabinet.
Completing your Key Building Information registration with the BSR is an important step, but it covers only a fraction of the information you need to maintain. The Golden Thread is the complete evidence base behind the KBI summary. If a BSR inspector asks to see your maintenance records, resident engagement documentation, or historical fire risk assessments, your KBI submission alone will not satisfy them.
Saving over the same file repeatedly means you lose the history of changes. If the BSR asks when your fire risk assessment was last updated and what changed, you need to show the revision history. A fire risk assessment dated 2024 with no record of what was different in the 2023 version cannot demonstrate that your records are genuinely "kept up to date" as required.
Having PDFs in a OneDrive folder, a maintenance spreadsheet on a shared drive, fire risk assessments in an email attachment, and complaints in a WhatsApp group technically has some digital elements. But it fails the "single accessible location" requirement and makes the "kept up to date" obligation nearly impossible to sustain. When information lives in seven places, it lives in zero places -- because nobody knows which version is current.
Both extremes create problems. Locking all information under a single account means the Golden Thread becomes inaccessible when that person is on holiday, off sick, or leaves the organisation. But giving everyone full access to everything exposes PEEPs data (which is GDPR-sensitive), commercially sensitive structural surveys, and security-critical access information. Role-based access -- where people see what they need to see and nothing more -- is the correct approach.
Setting up a Golden Thread is the easy part. Keeping it current over months and years, through staff changes, contractor rotations, and management company transitions, is the real challenge. Without clear processes and assigned responsibilities (Step 4 above), records gradually fall behind reality. After two years of neglect, your Golden Thread becomes a historical snapshot rather than a living compliance tool -- and a BSR inspector will see the difference.
These hypothetical examples illustrate how different buildings approach Golden Thread compliance in practice.
A newly converted 9-storey residential block has been handed over to a small management company. The original developer went into administration, leaving no as-built drawings, no fire strategy document, and only a basic completion certificate from building control.
How they approach it:A 12-storey building has been managed by the same company for 15 years. Records exist, but they are scattered: fire risk assessments in the assessor's portal, maintenance records in a contractor's system, complaints in an email folder, structural surveys in a solicitor's file, and resident engagement notes in a Word document on the building manager's laptop.
How they consolidate:An 8-storey building is managed by leaseholders who have exercised the Right to Manage. The RTM directors are volunteers with no property management background, currently using WhatsApp groups, shared Google Drive folders, and a spreadsheet tracker.
How they formalise their Golden Thread:The Golden Thread is a complete, accurate, and up-to-date digital record of all building safety information for a higher-risk building. It is a legal requirement under section 88 of the Building Safety Act 2022, maintained by the Principal Accountable Person throughout the building's life. It covers everything from original design and construction records through to ongoing maintenance, fire risk assessments, safety cases, and emergency planning documents.
The Golden Thread requirement applies to higher-risk buildings in England -- residential buildings at least 7 storeys or 18 metres tall containing at least 2 residential units, as defined by the Higher-Risk Buildings (Descriptions and Supplementary Provisions) Regulations 2023. If your building meets this description, the duty under section 88 of the Building Safety Act applies to the accountable persons for that building.
Failure to comply with section 88 is a criminal offence. The Building Safety Regulator has enforcement powers under section 98 of the Act, which can include compliance notices, civil penalties, and prosecution. Beyond the legal risk, an incomplete Golden Thread makes it harder to demonstrate that you are managing building safety effectively -- which could have serious consequences in the event of an incident.
A spreadsheet alone is unlikely to satisfy the requirements. While it might serve as an index or tracker, the Golden Thread needs to include the actual documents (plans, reports, certificates), not just references to them. You also need version control, access management, and security -- capabilities that spreadsheets typically lack. A spreadsheet could be part of your system (for example, as a gap analysis tracker), but it should not be the complete system. See why spreadsheets are not a Golden Thread for a detailed analysis.
The Golden Thread is the complete set of building safety information maintained throughout the building's life under section 88. Key Building Information (KBI) is a defined subset that the Principal Accountable Person must register and provide to the Building Safety Regulator under section 89. Think of KBI as the summary you submit to the regulator, and the Golden Thread as everything behind that summary. Maintaining KBI alone does not satisfy the Golden Thread requirement.
The Higher-Risk Buildings (Keeping and Provision of Information) Regulations 2024 prescribe two categories in Schedule 1: design and construction information (as-built plans, fire strategy, materials used, building control approvals) and information during occupation (safety case, fire risk assessments, maintenance records, mandatory occurrence reports, emergency plans, resident engagement strategy, and complaints register).
There is no single prescribed review frequency -- it depends on the type of information. Fire risk assessments are typically reviewed annually or after significant changes. Maintenance records should be updated after each service visit. The safety case should be reviewed at least annually. As a general rule, update the Golden Thread whenever something changes in the building that affects safety, and conduct a comprehensive review at least once a year to check for gaps and staleness.
Get regulatory updates delivered monthly →]]>Fire and Rescue Authorities enforce PEEPs requirements under the Fire Safety Order. Non-compliance can result in:
The good news: if you can show you've made reasonable efforts — letters sent, assessments conducted, plans created — you demonstrate active management even if not every resident has responded. The regulations acknowledge that resident participation is voluntary.
{/ snippet-target: faq | query: "peeps deadline 2026" /}
Fire and Rescue Authorities enforce PEEPs under the Regulatory Reform (Fire Safety) Order 2005. Non-compliance can result in enforcement notices, and ignoring an enforcement notice is a criminal offence under Articles 30 and 32 of the Fire Safety Order.
Yes. Participation in a person-centred fire risk assessment is voluntary. You cannot compel a resident to take part. If they decline, record the offer, the date, and their refusal. You still have a duty to consider general evacuation provisions for that resident.
The regulations apply to buildings with two or more domestic premises that are either 18 metres or 7 storeys tall, or 11 metres or more with a simultaneous evacuation strategy. Buildings below these thresholds are not currently in scope, though PEEPs remain good practice.
Review PEEPs whenever a resident's circumstances change, after a fire-related incident, or at least annually as part of your fire risk assessment review cycle. Keep dated records of every review.
The Responsible Person — typically the building manager or managing agent — is legally responsible. You may involve your fire risk assessor in the process, but the duty sits with you. You cannot delegate the legal responsibility.
{/ reviewBy: 2026-08-15 /}
TL;DR: The Building Safety Act 2022 regime tightened significantly through 2025, with the Building Safety Regulator (BSR) now operating as an independent body and actively enforcing compliance. If you manage a higher-risk building, you should have already registered, started your Building Assessment Certificate application, and be maintaining your Golden Thread. The PEEPs deadline on 6 April 2026 is next. Check if your building qualifies as higher-risk →The Building Safety Act received Royal Assent in April 2022, but the regulatory regime has been phased in over several years. Here is what shifted during 2025 that directly affects your obligations as a building manager:
The Building Safety Regulator became a standalone statutory body on 6 January 2025, separating from the Health and Safety Executive and gaining direct enforcement powers over higher-risk buildings.The BSR gained teeth. Throughout 2025, the BSR moved from guidance-issuing to active enforcement. It began requesting safety case reports from Principal Accountable Persons and assessing Building Assessment Certificate applications — not as a formality, but as substantive reviews of how you manage building safety risks. Key Building Information duties became enforceable. Since April 2024, you must maintain and share Key Building Information (KBI) under section 89 of the Act. This is the operational backbone of your Golden Thread — the BSR can request it at any time, and an incomplete or outdated KBI signals that you are not managing your building effectively. The BSR became independent. On 27 January 2026, the BSR formally separated from the Health and Safety Executive to become a standalone body under the Ministry of Housing, Communities and Local Government. This is not cosmetic — it signals that building safety regulation is a permanent, expanding function of government, not a temporary post-Grenfell initiative.
Under section 65 of the Building Safety Act 2022, a higher-risk building is a residential building in England that is:
All higher-risk buildings in England were required to be registered with the Building Safety Regulator by 1 October 2023. Buildings that remain unregistered are operating in breach of the Act.>
— Building Safety Act 2022, s.89
Here is a concrete example of what "full weight" looks like. Imagine you manage a 9-storey residential block with 45 flats. You need to have registered with the BSR by October 2023. You need a named Accountable Person (or multiple, if different parties control different parts of the building). You need to maintain a structured record of every fire safety system — from the FD30S fire doors on each level to the dry riser inlet, the emergency lighting circuits, and the compartmentation survey. You need to be able to produce this information, organised and current, if the BSR requests your safety case report. And by April 2026, you need individualised evacuation plans for any resident who cannot self-evacuate.
That is the standard. Not "best practice" — the legal minimum.
If you have not started, here is the priority order. If you are already partway through, use this as a gap-check.
The BSR has enforcement powers under Part 4 of the Building Safety Act. These are not theoretical.
Compliance notices (section 99): The BSR can issue a formal notice requiring you to take specific actions to fix building safety failings. Ignoring a compliance notice without reasonable excuse is a criminal offence — punishable by up to 2 years' imprisonment on indictment, an unlimited fine, or both. Daily fines apply for each day the breach continues after conviction. Safety case requests: The BSR can request your safety case report at any time. If you cannot produce one — or if it reveals that you are not managing risks — expect further enforcement action. Building Assessment Certificate refusal: If the BSR is not satisfied that you are managing building safety effectively, it will refuse your certificate application. A building without a certificate is a building the regulator is actively scrutinising.Consider what this looks like in practice. A building manager receives a BSR inspection request and discovers their fire door inspection records are six months out of date, three contractor certificates have expired, and their compartmentation survey was never digitised — it is sitting in a filing cabinet in the managing agent's office. The BSR does not see a manager who is "mostly compliant." They see a building with gaps in its Golden Thread, and they issue a compliance notice with a deadline.
The buildings that demonstrate compliance — with structured, traceable records showing active management — are the ones that pass assessments without escalation. A building with 40 fire risk assessment actions where 35 are complete with evidence, 3 are in progress with contractors assigned, and 2 are overdue with escalation records tells a fundamentally different story from a building with a spreadsheet of actions and no evidence trail. A building safety compliance platform gives you exactly this structured, traceable record.
A higher-risk building (HRB) is a residential building in England that is at least 18 metres tall or has at least 7 storeys, and contains at least 2 residential units. This is defined in section 65 of the Building Safety Act 2022.
The Golden Thread is the requirement under sections 88-89 of the Building Safety Act to maintain accurate, up-to-date building safety information throughout a building's lifecycle. This includes structural data, fire safety systems, maintenance records, and evacuation procedures. If you cannot demonstrate your Golden Thread, you cannot demonstrate compliance.
The Building Safety Regulator can issue compliance notices under section 99 of the Act. Failing to comply with a compliance notice without reasonable excuse is a criminal offence, punishable by up to 2 years' imprisonment on indictment, an unlimited fine, or both. Daily fines can also apply for continuing breaches.
Yes. The deadline for registering existing higher-risk buildings with the BSR was 1 October 2023. If your building is not yet registered, act immediately — operating an unregistered higher-risk building is an offence.
Personal Emergency Evacuation Plans (PEEPs) become a legal requirement on 6 April 2026. You must identify residents who need assistance evacuating and create individualised evacuation plans for each one before that date.
The Building Safety Act 2022 (BSA) is the most significant reform to building safety regulation in a generation. Enacted following the Grenfell Tower tragedy, it creates a comprehensive framework for managing the safety of higher-risk residential buildings throughout their lifecycle.
The Building Safety Act 2022 is the most significant reform to building safety regulation in a generation, creating a comprehensive framework for managing the safety of higher-risk residential buildings throughout their lifecycle.>
— Building Safety Act 2022
Part 4 of the Act deals specifically with higher-risk buildings in occupation -- the day-to-day safety obligations that fall on building managers, freeholders, and management companies. This checklist covers those obligations.
For comprehensive context on the Building Safety Act -- what it covers, who it applies to, and why it matters -- read our Building Safety Act Complete Guide.
A higher-risk building must be at least 18 metres in height or at least 7 storeys tall, contain at least two residential units, and be located in England to fall within the Building Safety Act Part 4 regime.>
— Building Safety Act 2022, Part 4
The Building Safety Act's Part 4 regime applies to higher-risk buildings (HRBs) in England. Your building is a higher-risk building if it meets all of the following criteria:
| Criterion | Requirement | |-----------|-------------| | Height | At least 18 metres or at least 7 storeys | | Residential units | Contains at least 2 residential units (domestic premises) | | Location | England (different regimes apply in Wales, Scotland, and Northern Ireland) |
For detailed criteria and edge cases (measuring height, counting storeys, mixed-use buildings), see the GOV.UK guidance on HRB criteria.
The BSA introduces specific legal roles for building safety. Understanding who fills each role in your building is the foundation of compliance.
The Principal Accountable Person is defined in section 73 of the BSA. The PAP is the person who holds the legal estate in the building's structure and exterior (the common parts that form the building's envelope).
In practice, the PAP is typically:
An Accountable Person is defined in section 72 of the BSA. An AP is anyone who holds a legal estate or is under a repairing obligation for the common parts of the building.
There can be multiple APs in a single building. For example, if the freeholder owns the structure and a management company has a repairing obligation for the internal common areas, both are APs. The freeholder would typically also be the PAP.
Each AP must cooperate with the PAP and take reasonable steps to manage building safety risks in the parts they are responsible for.
The Building Safety Regulator is the body that oversees the new regime. As of 27 January 2026, the BSR operates as a standalone body under MHCLG (the Ministry of Housing, Communities and Local Government). Previously, the BSR sat within the Health and Safety Executive (HSE).
The BSR's role includes:
All higher-risk buildings in England were required to be registered with the Building Safety Regulator by 1 October 2023. Operating an unregistered higher-risk building is a criminal offence under section 89 of the Act.>
— Building Safety Act 2022, s.89
All higher-risk buildings in occupation in England were required to be registered with the BSR by 1 October 2023. If your building is not yet registered, this should be treated as an urgent priority.
Registration requires submitting Key Building Information (KBI) to the BSR, as defined in the Key Building Information Regulations 2023 (SI 2023/963). KBI includes basic information about the building's structure, height, materials, fire safety systems, and occupancy.
A Building Assessment Certificate is the BSR's confirmation that your building meets the requirements of the new regime. The BSR is calling in buildings for BAC applications in priority order:
| Priority group | Criteria | |----------------|----------| | Group 1 | Buildings 30m+ with 11 or more residential units | | Group 2 | Buildings 18-29.99m with 378+ residential units | | Group 3 | Buildings clad with ACM (aluminium composite material) | | Subsequent groups | Expanding to all registered HRBs over time |
When the BSR calls your building in, the PAP has 28 days to submit the BAC application (per the Higher-Risk Buildings Procedures Regulations 2023 (SI 2023/909)).
The Golden Thread is one of the most significant new requirements. Under section 88 of the BSA and the Higher-Risk Buildings (Keeping and Provision of Information) Regulations 2024 (SI 2024/41), the PAP must maintain a complete, digital, up-to-date record of building safety information.
The Golden Thread must be maintained as an electronic (digital), accessible, and up-to-date record of all building safety information throughout the building's lifecycle.>
— Building Safety Act 2022, s.88
The Golden Thread must be:
| Requirement | What this means | |-------------|----------------| | Digital | Paper-only records do not satisfy the requirement | | Accessible | Authorised persons can access the information they need | | Up to date | Reflects the current state of the building, not a historical snapshot | | Secure | Protected against unauthorised access, loss, or corruption | | Plain English | Non-technical users can understand the key information | | GDPR compliant | Personal data is handled in accordance with data protection law | | Single source of truth | One authoritative record, not scattered across multiple systems | | Version controlled | Changes are tracked with history |
For a detailed guide to setting up and maintaining your Golden Thread, see our complete Golden Thread guide.
Maintaining a digital Golden Thread is one of the most operationally demanding requirements of the BSA. It touches every aspect of building management -- from fire risk assessments to contractor works to resident communications. Platforms like Brocade are designed to serve as the Golden Thread, providing a single digital record with audit trails, version control, and structured information management.
Under sections 83-85 of the BSA, the PAP must:
A Safety Case Report should include:
Safety occurrences that pose a risk of significant harm to people in or around the building, including:
| Step | Timeframe | Detail | |------|-----------|--------| | Occurrence notice | Within 10 working days | Initial notice to BSR that a reportable occurrence has happened | | Full occurrence report | Within the timeframe specified by BSR | Detailed report covering what happened, root cause, and remedial actions |
See the GOV.UK guidance on submitting mandatory occurrence notices and reports for the submission process.
Under section 91 of the BSA, the PAP must prepare and give effect to a residents' engagement strategy. This strategy must describe how the PAP will:
Residents also have duties under sections 95-97 of the BSA:
While the BSA does not have a specific "contractor competence" section, the PAP's duties under sections 83-84 (risk assessment and management) require ensuring that contractors working on the building are competent and accountable.
Tracking fire risk assessment actions through to completion -- including which contractor was assigned, what evidence they provided, and whether the work was verified -- is a core compliance workflow. See how Brocade simplifies this -->
Regular maintenance and inspections are essential to maintaining building safety. While the BSA does not prescribe a specific maintenance schedule, the PAP's duty to manage building safety risks (section 84) implicitly requires a structured approach to maintenance.
These are fictional examples designed to show how the BSA obligations work in practice.
Oakwood House is a purpose-built residential block in Manchester. The RTM company holds the right to manage and is the PAP (as the party responsible for the structure and exterior). The original freeholder retains the freehold but has no repairing obligation -- so the RTM company is the sole AP and PAP.
Registration: The building was registered with the BSR in September 2023. KBI was submitted including details of the external wall system (brick cavity construction, no cladding concerns). Golden Thread: The RTM company uses a digital building management platform to store fire risk assessments, maintenance records, and building safety documents. Version control is maintained through the platform's audit trail. Safety Case: A Safety Case Report was prepared with input from the building's fire risk assessor. Key risks identified: ageing fire doors on floors 3-8, communal ventilation system needing upgrade. Actions tracked and progressing. Resident engagement: The RTM sends a quarterly building safety newsletter and holds an annual residents' meeting. A dedicated email address handles safety complaints with a 5-working-day response target. BAC readiness: Oakwood House is in the 18-29.99m category with fewer than 378 units, so it has not yet been called in for a BAC. The RTM is preparing materials in advance.Meridian Tower is a large residential tower in London. The PAP is the corporate freeholder. The freeholder has appointed a managing agent to handle day-to-day management. The managing agent assists with building safety duties, but the legal responsibility remains with the freeholder.
Key roles: The freeholder is the PAP and sole AP. The managing agent acts on behalf of the PAP but is not itself an AP (it does not hold a legal estate or repairing obligation -- it operates under a management contract). Registration and BAC: At 22 storeys with 180 units, Meridian Tower falls into the BSR's early priority group. The PAP was called in for BAC application in 2025 and submitted within the 28-day window. Golden Thread: The managing agent maintains the Golden Thread using Brocade's compliance platform, which provides structured information storage, audit trails, and document management. The freeholder has oversight access. MOR incident: A fire suppression system failed on floor 14 during routine testing. The managing agent submitted an occurrence notice to the BSR within 10 working days. The full report was submitted within the BSR's specified timeframe, documenting the failure, root cause (valve degradation), and remedial action (full system inspection and valve replacement).Riverside Court has a complex ownership structure. The freeholder owns the structure and exterior. A separate company has a repairing obligation for the internal common areas (lobbies, corridors, stairwells) under a long lease. Both are Accountable Persons. The freeholder is the PAP.
Cooperation duty: Both APs must cooperate with each other. The PAP coordinates the Safety Case Report, but the AP responsible for internal common areas must provide information about their areas and manage risks within their control. Practical challenge: Fire door maintenance falls to the internal AP (they have the repairing obligation for corridors). But the fire strategy and compartmentation integrity are the PAP's concern. A formal cooperation agreement sets out responsibilities, information sharing, and escalation procedures. Resident engagement: The PAP leads the residents' engagement strategy, but the internal AP participates in responding to complaints about common area maintenance. Both APs share relevant information with each other and with the BSR as required.The BSA gives the Building Safety Regulator significant enforcement powers.
Under section 99, the BSR can issue a compliance notice requiring the PAP or AP to take specific steps within a set timeframe. Failure to comply with a compliance notice is itself a further ground for enforcement action.
For fire safety matters specifically (as opposed to structural or building safety risks), Fire and Rescue Authorities (FRAs) retain enforcement powers under the Regulatory Reform (Fire Safety) Order 2005. This includes enforcement of PEEPs requirements once those come into force on 6 April 2026.
| Enforcement body | Scope | |-------------------|-------| | Building Safety Regulator | Building safety risks, Golden Thread, Safety Case, registration, BAC, MOR | | Fire and Rescue Authority | Fire safety in common parts, fire risk assessment, PEEPs |
The BSA regime is being implemented in phases. Key dates and developments:
| Date | Event | |------|-------| | October 2023 | Registration deadline for all in-occupation HRBs | | January 2026 | BSR becomes standalone body (separated from HSE) | | April 2026 | PEEPs enforcement begins (see our PEEPs guide) | | 2026 onwards | BAC applications expanding to more building categories | | October 2026 | BSR cost-benefit analysis on electrical installation inspection requirements due |
A higher-risk building is at least 18 metres in height or at least 7 storeys tall, contains at least two residential units, and is located in England. Height is measured from ground level to the floor surface of the top storey, not to the roof (Building Safety Act 2022, Part 4).
The Principal Accountable Person (PAP) is the person who holds the legal estate in the building's structure and exterior (Building Safety Act 2022, s.73). They have overall responsibility for building safety and must apply for a Building Assessment Certificate. In most buildings, this is the freeholder.
No. The Building Safety Manager role was removed from the Building Safety Act before it received Royal Assent. PAPs may still appoint someone to assist with building safety duties, but the legal responsibility remains with the PAP.
The Golden Thread is a complete, digital, up-to-date record of building safety information that must be maintained throughout the building's lifecycle (Building Safety Act 2022, s.88). It must be kept digitally, be accessible, and serve as a single source of truth for all building safety information.
The Building Safety Regulator can issue compliance notices requiring specific corrective actions within a set timeframe. Non-compliance that gives rise to a risk of death or serious injury is a criminal offence under section 101 of the Act, carrying unlimited fines and up to two years' imprisonment.
All higher-risk buildings in England were required to be registered with the Building Safety Regulator by 1 October 2023 (Building Safety Act 2022, s.89). If your building has not yet been registered, treat this as an urgent priority — operating an unregistered higher-risk building is a criminal offence.
No. A managing agent acts on behalf of the building owner but does not hold the legal estate in the building. The freeholder or other entity holding the legal estate in the structure and exterior remains the PAP regardless of management arrangements. The PAP can outsource management functions but cannot delegate legal liability.
A Safety Case Report is a formal document summarising the assessment of building safety risks and the steps taken to manage them, required under section 85 of the Building Safety Act. The PAP must prepare it as soon as reasonably practicable, and it is reviewed by the BSR as part of the Building Assessment Certificate application.
The Building Safety Act 2022 created a clear chain of accountability for higher-risk buildings in England -- residential buildings of at least 7 storeys or 18 metres in height with at least two residential units. At the top of that chain sits the Principal Accountable Person (PAP).
The Principal Accountable Person is the person or organisation that holds the legal estate in the structure and exterior of a higher-risk building, carrying ultimate legal responsibility for building safety.>
— Building Safety Act 2022, s.73
Before the Act, responsibility for building safety was often diffuse. Ownership structures, management agreements, and long lease chains meant that when something went wrong, it was unclear who was ultimately answerable. The Grenfell Tower tragedy and Dame Judith Hackitt's Independent Review made the consequences of this ambiguity devastatingly clear.
The PAP role exists to end that ambiguity. One person or organisation is legally responsible for the safety of each higher-risk building. Understanding whether you hold that role -- and what it requires of you -- is the first step in meeting your obligations.
This guide covers:
For a comprehensive overview of the full Building Safety Act regime -- including all Part 4 obligations, enforcement powers, and the compliance timeline -- see our Building Safety Act Complete Guide.
This is the question we hear most often from building managers, freeholders, and management company directors. The answer depends on the legal structure of your building's ownership and management -- but for most higher-risk buildings, the designation is more straightforward than you might expect.
In most higher-risk buildings, the freeholder is the Principal Accountable Person — even where a managing agent or Right to Manage company handles day-to-day management. Legal liability cannot be delegated through management arrangements.
The Building Safety Act defines two key roles:
Where there is only one accountable person, that person is automatically the PAP. Where there are multiple APs, the one who holds the legal estate in the structure and exterior takes on the PAP role.
Work through the scenarios below to identify who holds the PAP role for your building.
If one entity -- a person, company, or trust -- owns the freehold of the entire building, they are almost certainly the PAP. The freeholder holds the legal estate in the structure and exterior, which is the defining criterion under section 73.
This is the most common arrangement. If you are the sole freeholder of a higher-risk building, you are the PAP.If leaseholders have exercised their Right to Manage under the Commonhold and Leasehold Reform Act 2002, the RTM company acquires management functions -- but not the legal estate in the building.
The freeholder remains the PAP. The RTM company acquires the right to manage the building's services, maintenance, and insurance, but the freehold (and therefore the legal estate in the structure and exterior) stays with the original freeholder.
This creates a practical challenge: the PAP (freeholder) has legal accountability, but the RTM company controls day-to-day management. Close cooperation between freeholder and RTM company is essential. The RTM company may separately be an accountable person if it holds a repairing obligation over common parts, but it is not the PAP.
A managing agent -- whether a professional property management company or an individual -- acts on behalf of the freeholder. Appointing a managing agent does not change who the PAP is.
The freeholder remains the PAP. The managing agent carries out functions delegated to them, but the legal estate in the structure and exterior has not changed hands. If the managing agent fails to perform their duties, the PAP remains answerable to the Building Safety Regulator (BSR).
Some buildings are structured so that a Resident Management Company -- a company formed by the leaseholders -- has purchased the freehold. If the RMC holds the legal estate in the structure and exterior, the RMC entity is the PAP.
This means the company itself (not individual directors) bears the legal responsibility. The RMC must designate a named individual as the point of contact for the BSR under section 74, but that designated individual is not personally the PAP.
RMC directors should understand that their company's obligations as PAP are significant and ongoing. Consider whether your RMC has the resources and expertise to fulfil the role, or whether professional support is needed.
Larger or more complex buildings may have multiple accountable persons. For example, a building might have a freeholder who owns the structure and exterior, plus a head leaseholder who holds the legal estate in certain common parts (such as a commercial ground floor).
In this case, the AP who holds the legal estate in the structure and exterior is the PAP. The other APs still have obligations under section 72, but the PAP has additional duties including coordinating with the other APs and ensuring overall building safety.
If your building has an unusual ownership structure -- perhaps involving a trust, a chain of head leases, joint freeholders, or an ongoing dispute about the legal estate -- the PAP designation may not be immediately obvious.
Seek legal advice from a solicitor experienced in building safety law. Getting the PAP designation wrong does not exempt anyone from liability; it simply means the correct PAP may have been operating without fulfilling their duties.Once you have established that you (or your organisation) are the PAP, the Building Safety Act sets out a clear and demanding set of obligations. These are not optional best practices -- they are legal requirements backed by enforcement powers.
The PAP must register the building, apply for a Building Assessment Certificate when called, maintain the Golden Thread, prepare a Safety Case Report, establish mandatory occurrence reporting, and create a residents' engagement strategy.>
— Building Safety Act 2022, ss.72-89
This section covers each obligation with its statutory basis and practical implications. For a building-level compliance checklist covering all these obligations, see our BSA Compliance Checklist.
All higher-risk buildings must be registered with the Building Safety Regulator. Registration is the PAP's responsibility under section 77. The initial registration deadline has passed (the BSR required registration by 1 October 2023), but any newly qualifying building must be registered promptly.
Registration requires providing the BSR with Key Building Information (KBI) about the building's structure, safety systems, and management arrangements. Failure to register is itself a compliance failure.
The BSR will call in higher-risk buildings for assessment over time. When your building is called, the PAP has 28 days to submit an application for a Building Assessment Certificate (BAC) under section 78.
The BAC application requires the PAP to demonstrate that the building is being managed safely. The BSR assesses proportionately -- there is no one-size-fits-all checklist, but they will consider:
Under section 83, the PAP must assess building safety risks and do so at regular intervals. A building safety risk is defined as a risk to the safety of people in or about the building arising from the spread of fire or structural failure.
This is not a one-off exercise. The assessment must be kept up to date, reviewed regularly, and updated whenever circumstances change -- for example, after building works, a safety incident, or new information about construction materials.
Under section 87, the PAP must establish and operate a system for reporting safety occurrences -- events that could indicate a building safety risk, such as a fire alarm activation, structural defect, or near-miss incident.
The system must be accessible to residents, staff, and contractors. Reports must be investigated, and the PAP must take appropriate action in response.
The PAP has the primary legal duty to establish and maintain the Golden Thread -- a complete, accurate, up-to-date digital record of all building safety information, as required by section 88 and the Higher-Risk Buildings (Keeping and Provision of Information) Regulations 2024.
This is one of the most resource-intensive obligations. The Golden Thread must be maintained in electronic format, kept current, and be accessible to relevant persons. Our complete Golden Thread guide covers what information must be kept, digital storage standards, and how to organise it.
Under section 85, the PAP must prepare a Safety Case Report as soon as reasonably practicable. The report must contain:
The engagement strategy must cover how residents will be kept informed, how their views will be sought, and how they can raise concerns about safety. For a practical guide to building your engagement strategy -- including setting up a Residents' Panel, establishing communication channels, and implementing the section 93 complaints system -- see our resident engagement strategy guide. Our PEEPs guide covers the related Personal Emergency Evacuation Plans obligations that intersect with resident engagement.
Under section 93, the PAP must establish a system for handling complaints about the management of building safety. The system must be accessible and transparent, and the PAP must act on complaints in a timely and proportionate manner.
The obligations above can feel overwhelming. This section distils them into a scannable reference framed as your personal duties -- what you, as the PAP, must ensure is happening for your building.
Your registration duties:One of the most misunderstood aspects of the PAP role is delegation. Many building owners and management companies assume that appointing a managing agent or building safety professional transfers their responsibilities under the Act. It does not.
If you are the PAP and your managing agent fails to maintain the fire safety systems, you are the one who faces enforcement action -- not the agent. You may have a contractual claim against the agent, but your statutory liability is unaffected.
When the PAP is an organisation -- a company, RMC, trust, or other entity -- section 74 requires the designation of a named individual as the single point of contact for the BSR.
This person is the human being the BSR communicates with. They are not the PAP; the organisation is. But they must be sufficiently senior and knowledgeable to fulfil the role effectively. Choose someone who understands the building's safety arrangements, has authority to make decisions, and can respond promptly to BSR communications.
This section covers the enforcement framework and what it means for you personally. It is framed around protection -- understanding the risks so you can take the steps that shield you from them.
Non-compliance that gives rise to a risk of death or serious injury is a criminal offence under section 101 of the Building Safety Act, but a due diligence defence is available where the PAP took all reasonable steps.>
— Building Safety Act 2022, s.101
The threshold is significant. Not every compliance failure is a criminal offence. The failure must give rise to a risk of death or serious injury. But the point is clear: building safety is not an administrative exercise. The consequences of neglect can be severe.
Section 101(4) provides an important protection: it is a defence to show that you took all reasonable steps to comply with the relevant requirement. This is the due diligence defence, and it is the single most important reason to take your PAP obligations seriously and document your efforts.
"All reasonable steps" does not mean perfection. It means proportionate, documented, ongoing effort to manage building safety. If something goes wrong despite your genuine and demonstrable efforts to comply, the due diligence defence is available to you.
The Golden Thread is not just a regulatory requirement -- it is your primary evidence in any enforcement scenario. If the BSR investigates your building, or if an incident occurs, your records demonstrate:
A building with thorough records that experiences an incident is in a fundamentally different legal position from a building with poor records and the same incident.
The BSR has a range of enforcement tools short of criminal prosecution:
The liability framework exists to ensure building safety is taken seriously. For a PAP who is actively fulfilling their obligations -- maintaining records, assessing risks, engaging with residents, working with competent professionals -- the Act provides a clear framework and a defence against disproportionate enforcement.
The greatest risk is inaction. A PAP who is aware of their obligations but has not started to address them is in the most exposed position. Starting -- even imperfectly -- is better than waiting. Book a demo to see how Brocade helps PAPs track their obligations.
The following scenarios are hypothetical but based on common building management structures. They illustrate how PAP responsibilities play out in practice.
Riverside House is a 12-storey residential tower with 48 flats. The leaseholders exercised their Right to Manage three years ago, and the RTM company is run by four volunteer directors.
Who is the PAP? The freeholder -- a property investment company that retained the freehold when the RTM was exercised. The RTM company manages the building day to day, but the freeholder holds the legal estate in the structure and exterior. The challenge: The freeholder has minimal involvement in the building. The RTM directors make all the practical decisions. But when the BSR calls the building in for BAC assessment, it is the freeholder who must submit the application and demonstrate compliance. What should happen: The freeholder and RTM company need a formal agreement clarifying who does what. The RTM company may handle the practical work -- commissioning fire risk assessments, maintaining records, engaging residents -- but the freeholder must oversee that work and satisfy themselves it meets the required standard. The freeholder should appoint a designated individual (under section 74) and ensure the RTM company provides regular reports on building safety matters.The freeholder cannot simply assume the RTM is handling everything. If the RTM company's volunteer directors lack the expertise to manage building safety effectively, the freeholder's liability is not reduced -- it may be increased, because they have not ensured competent management arrangements are in place.
Highpoint Apartments is a 20-storey block with 120 flats owned by a private freeholder. The freeholder has appointed Apex Property Management as their managing agent under a comprehensive management agreement.
Who is the PAP? The private freeholder. The managing agent handles all day-to-day operations, but the freeholder holds the legal estate. The challenge: The freeholder trusts the agent to "deal with everything" and has not been closely involved. The management agreement predates the Building Safety Act and does not specifically cover building safety obligations. What should happen: The freeholder should review and update the management agreement to explicitly cover Building Safety Act obligations -- risk assessment, Golden Thread maintenance, occurrence reporting, resident engagement. The agreement should specify standards, reporting requirements, and the freeholder's right to audit compliance.The freeholder should receive regular (at minimum quarterly) building safety reports from the agent. They should not simply delegate and forget. If the agent fails to maintain proper records or conduct risk assessments, the freeholder will be answerable to the BSR.
The freeholder should also consider whether the agent has sufficient expertise and resources to fulfil building safety duties. A management agreement that says "the agent will comply with the Building Safety Act" is insufficient if the agent lacks the capability to do so.
Hartfield Estates Ltd is a Resident Management Company that owns the freehold of three higher-risk buildings (8, 10, and 14 storeys) on a connected estate. The RMC has appointed a professional company secretary and uses a specialist building safety consultancy.
Who is the PAP? Hartfield Estates Ltd (the RMC) for each of its three buildings. As the freeholder holding the legal estate, the company itself is the PAP. The challenge: The RMC has multiple buildings, each with different construction types, risk profiles, and resident populations. The directors are leaseholders with day jobs. They rely on the professional company secretary and the building safety consultancy for compliance. What should happen: The RMC should designate a named individual (likely the company secretary or a senior director) as the section 74 point of contact for each building. Building safety compliance should be a standing agenda item at board meetings, with reports from the consultancy.Each building needs its own risk assessment, Safety Case Report, Golden Thread, and residents' engagement strategy -- the obligations are per-building, not per-organisation. The RMC should ensure its building safety consultancy provides clear deliverables and timelines, and that the board reviews and approves key safety documents rather than simply delegating to the consultancy.
Having professional support is a significant advantage. But the RMC's directors must understand their collective responsibility. "We left it to the consultants" is not a due diligence defence if the directors never reviewed what the consultants produced.
The questions below address the most common queries we receive about PAP responsibilities. Each answer is a summary -- refer to the relevant section of this guide for full details and statutory references.
The PAP is the accountable person who holds the legal estate in possession in the structure and exterior of the building, as defined in section 73 of the Building Safety Act 2022. In most cases, this is the freeholder. Where there is only one accountable person, that person is automatically the PAP. See Am I the Principal Accountable Person? above for detailed scenarios.
No. A managing agent acts on behalf of the building owner but does not hold the legal estate in the building. The freeholder or other entity holding the legal estate in the structure and exterior remains the PAP regardless of management arrangements. The PAP can outsource management functions but cannot delegate legal liability.
The PAP cannot delegate their legal liability under the Building Safety Act. They can outsource management tasks to managing agents, building safety professionals, and specialist contractors, but accountability remains with the PAP. See Delegating responsibilities for details on what can and cannot be delegated.
Non-compliance that gives rise to a risk of death or serious injury is a criminal offence under section 101. The BSR can also issue compliance notices and contravention notices. However, a due diligence defence is available if the PAP can demonstrate they took all reasonable steps. See Understanding your legal position.
No. An RTM company acquires the right to manage the building but does not acquire the legal estate in the structure and exterior. The freeholder remains the PAP even when an RTM company is in place. The RTM company may be a separate accountable person if it holds a repairing obligation, but it is not the PAP.
The PAP must register the building with the BSR, apply for a BAC when called, assess building safety risks regularly, take all reasonable steps to prevent major incidents, maintain the Golden Thread, prepare a Safety Case Report, establish an occurrence reporting system, prepare a residents' engagement strategy, and operate a complaints system. See Core responsibilities and PAP Obligations Quick Reference for the full list.
Yes. When the PAP is an organisation (such as a company or RMC), they must designate a named individual as the single point of contact for the BSR under section 74. This designated individual is not the PAP -- the organisation retains that role and the legal responsibilities that come with it.
Residential Personal Emergency Evacuation Plans (PEEPs) are a new legal requirement under the Fire Safety (Residential Evacuation Plans) (England) Regulations 2025. They require the Responsible Person (RP) for certain residential buildings to identify residents who may have difficulty evacuating in an emergency and to put practical plans in place to help them.
Residential PEEPs are a legal requirement under the Fire Safety (Residential Evacuation Plans) (England) Regulations 2025, requiring person-centred fire risk assessments and individualised evacuation plans for residents who may need assistance.>
— Fire Safety (Residential Evacuation Plans) Regulations 2025
The regulations introduce the concept of a person-centred fire risk assessment (PCFRA) -- an individual assessment of a resident's specific needs and circumstances that feeds into a tailored evacuation plan. This is not a one-size-fits-all exercise. Each PCFRA considers the individual resident: their mobility, any sensory or cognitive impairments, the layout of their flat, and the building's evacuation routes.
PEEPs sit alongside your existing fire risk assessment obligations under the Regulatory Reform (Fire Safety) Order 2005. They do not replace your general fire risk assessment -- they add a person-centred layer for residents who need additional support.
The regulations apply to the Responsible Person for buildings that meet specific criteria. In most cases, the Responsible Person is the building manager, managing agent, or the person who controls the common parts of the building.
The PEEPs regulations apply to the Responsible Person for buildings with two or more domestic premises that are either 18 metres or 7 storeys tall, or 11 metres or more with a simultaneous evacuation strategy.
Your building is in scope if it meets all of the following:
If your building is a higher-risk building (HRB) under the Building Safety Act 2022 -- that is, 18 metres / 7 storeys with 2 or more residential units -- it is almost certainly in scope for PEEPs.
Buildings below 18 metres that use a simultaneous evacuation strategy (where all residents evacuate at once when the alarm sounds, rather than a "stay put" approach) are also captured if they are 11 metres or more.
The Responsible Person (RP) is defined in the Fire Safety Order 2005. For residential buildings, this is typically:
This is not a "soft launch" with a grace period. From 6 April 2026, your duties under these regulations are legally enforceable. Fire and Rescue Authorities (FRAs) have the power to inspect and take enforcement action from day one.
If you are reading this before the deadline: You have time to get this right. Work through the implementation steps below methodically. The process is straightforward for most buildings -- the key is starting early enough to give residents time to respond. If you are reading this after the deadline: You should implement these steps as quickly as possible. Begin with Step 1 (identifying relevant residents) and work through the process. Being late but demonstrating active progress is better than doing nothing. Document your actions and timeline in case of an FRA inspection.The regulations create a clear sequence of duties. Here is what you need to do, in order.
Each person-centred fire risk assessment must consider the individual resident's specific needs, their flat's location relative to escape routes, available equipment, and the building's evacuation strategy. Generic assessments are not compliant.
Your first duty is to take reasonable steps to identify residents who may need assistance evacuating the building in an emergency. The regulations call these "relevant residents."
A relevant resident is someone whose primary residence is in your building and who has a compromised evacuation ability. This includes residents with:
For each identified relevant resident, you must offer a person-centred fire risk assessment (PCFRA). This is a one-to-one assessment that considers the individual's specific needs, the layout of their flat, and the building's evacuation routes.
A PCFRA should cover:
If a resident declines, you still need to consider them in your general emergency evacuation planning for the building. You just will not have the detailed person-centred assessment to work from.
You must prepare emergency evacuation statements for the common areas of your building. These are distinct from the individual PCFRAs -- they cover the building as a whole and describe how people with different types of impairments would be evacuated through the common parts.
Emergency evacuation statements should include:
Based on the PCFRAs and your emergency evacuation statements, you must put in place reasonable and proportionate mitigations to improve evacuation safety for relevant residents.
"Reasonable and proportionate" is a key phrase. You are not required to make unlimited physical alterations to the building. The mitigations should be proportionate to the risk and the needs identified.
Examples of mitigations include:
| Mitigation | When appropriate | |------------|-----------------| | Evacuation chair at stairwell | Residents with mobility impairments on upper floors | | Vibrating pillow alarm / visual alarm beacon | Residents with hearing impairments | | Refuge intercom system | Buildings with designated refuge areas | | Buddy system with consenting neighbours | Where a trusted neighbour is available and willing | | Priority notification to fire service | When specific residents are known to need assistance | | Clear signage and tactile indicators | Residents with visual impairments | | Regular evacuation drills including relevant residents | All buildings |
You must share relevant information about your PEEPs arrangements with the local Fire and Rescue Authority (FRA). This helps firefighters prepare for incidents at your building and understand which residents may need assistance.
Consent is required. You must obtain explicit consent from the relevant resident before sharing their personal information with the FRA. If a resident does not consent, you cannot share their individual details -- but you should still share anonymised or aggregated information (for example, "there are three residents on floors 8-12 who may need evacuation assistance").Information to share with the FRA:
PEEPs are not a one-off exercise. You must review your plans:
Scheduling annual reviews is one of the recurring compliance tasks that building managers often struggle to track across multiple obligations. Tools like Brocade provide scheduled check reminders and escalation workflows to ensure nothing falls through the cracks.
Here is a summary of everything you need to do, in a format you can use to track your progress. For a printable version, download the PDF using the button in the sidebar.
These are fictional examples designed to show how the regulations work in practice.
Meridian Tower is a large residential tower managed by a professional managing agent. The building uses a stay-put evacuation strategy.
Step 1: The managing agent writes to all 180 households. 142 respond. Of those, 7 residents identify as potentially needing assistance: 3 wheelchair users, 2 residents with significant mobility impairments, 1 resident with dementia, and 1 resident who is profoundly deaf. A follow-up letter is sent to the 38 non-respondents, and door knocks are attempted. 12 more respond (none identifying as relevant). 26 remain unresponsive -- this is documented. Step 2: PCFRAs are offered to all 7 identified residents. 6 accept. 1 resident (a wheelchair user on the 4th floor) declines. The decline is recorded with the date and method of offer. Step 3: Emergency evacuation statements are prepared for the common areas, noting that the building has protected lobbies on every other floor and an evacuation intercom system. Step 4: Mitigations include: an evacuation chair stored at the protected lobby on each even-numbered floor, a vibrating pillow alarm unit provided to the deaf resident, and a buddy system arrangement with a consenting neighbour for the resident with dementia. Step 5: 5 of the 6 PCFRA participants consent to information sharing with the FRA. The managing agent shares detailed plans for those 5, plus anonymised data noting "approximately 7 residents across floors 2-19 may need evacuation assistance." Step 6: Annual review is scheduled for February each year, timed to align with the building's fire risk assessment review.Oakwood House is managed by an RTM (Right to Manage) company run by resident directors. The building uses a stay-put strategy.
Step 1: The RTM directors know most residents personally. They combine a formal letter with informal conversations at the next residents' meeting. 2 residents are identified: an elderly resident with a walking frame on the 6th floor, and a resident recovering from hip surgery on the 3rd floor (temporary condition). Step 2: Both residents accept the offer of a PCFRA. The assessments are conducted by the building's fire risk assessor during their next visit. Step 3: Emergency evacuation statements note that the building has a single staircase and no refuge areas. This is flagged as a risk factor. Step 4: The RTM company purchases an evacuation chair for the stairwell and arranges training for two volunteer residents on its use. For the resident recovering from surgery, a buddy system with a neighbour is agreed as a temporary measure, to be reviewed when the resident recovers. Step 5: Both residents consent to FRA information sharing. The RTM company contacts the local fire station to share the information and arranges a familiarisation visit. Step 6: The RTM company adds PEEPs review to their annual fire safety review, conducted each March.Riverside Court is a purpose-built block that uses a simultaneous evacuation strategy (all residents evacuate when the alarm sounds). At 12 storeys, it is above the 11-metre threshold and uses simultaneous evacuation, so it is in scope.
Step 1: 4 relevant residents are identified across the building. Step 2: All 4 accept PCFRAs. The assessments highlight that simultaneous evacuation creates particular challenges: all residents must leave at the same time, so relevant residents cannot "wait for assistance" in the same way they might under a stay-put strategy. Step 4: The mitigations focus on speed of evacuation: a designated assembly point with a register check, pre-arranged assistance from trained staff during evacuations, and enhanced alarm systems (visual beacons in the flats of residents with hearing impairments). The building also installs evacuation chairs at stairwell access points on every floor. Step 5 and 6: Information is shared with the FRA. Given the simultaneous evacuation strategy, the FRA is particularly interested in the building's arrangements and requests a copy of the evacuation procedures. Annual reviews are scheduled.PEEPs requirements are enforced by Fire and Rescue Authorities (FRAs) under the Regulatory Reform (Fire Safety) Order 2005. The enforcement powers available to FRAs include:
| Action | What it means | |--------|---------------| | Informal advice | FRA officers may provide guidance during routine inspections | | Enforcement notice | A formal notice requiring you to take specific steps by a set deadline | | Prohibition notice | In serious cases, a notice restricting the use of the building until safety issues are resolved | | Prosecution | For serious or persistent non-compliance, criminal proceedings can be brought |
In practice, FRAs are likely to take a proportionate approach in the early months after enforcement begins. A Responsible Person who is actively implementing PEEPs but has not yet completed every step is in a very different position from one who has done nothing.
Resident participation in a person-centred fire risk assessment is entirely voluntary. The Responsible Person cannot compel a resident to take part, but must record the offer and any refusal.
That said, this is not an area where you want to be relying on FRA goodwill. The regulations are clear, the deadline is fixed, and the duties are specific. Get it done. PEEP management software can streamline the entire process -- from resident identification through to FRA sharing.
Residential Personal Emergency Evacuation Plans (PEEPs) are person-centred fire risk assessments and evacuation plans for residents who may need assistance evacuating a higher-risk building in an emergency. They are a legal requirement under the Fire Safety (Residential Evacuation Plans) (England) Regulations 2025.
The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 come into force on 6 April 2026. From that date, the Responsible Person for in-scope buildings must have processes in place for identifying residents who need assistance and creating individualised evacuation plans.
Buildings with two or more domestic premises that are either 18 metres or 7 storeys in height, or 11 metres or more with a simultaneous evacuation strategy. Buildings below these thresholds are not currently in scope, though PEEPs remain best practice.
Yes. Resident participation in a person-centred fire risk assessment is entirely voluntary. The Responsible Person cannot compel a resident to take part. If they decline, record the offer, the date, and their refusal. You still have a duty to consider general evacuation provisions for that resident.
Fire and Rescue Authorities enforce PEEPs requirements under the Regulatory Reform (Fire Safety) Order 2005. Enforcement follows a graduated approach: informal advice, enforcement notices, prohibition notices, and prosecution for serious or persistent non-compliance.
The Responsible Person is typically the building manager, managing agent, or freeholder — the person who has control of the building's common parts. For higher-risk buildings, this often aligns with the Accountable Person role under the Building Safety Act 2022.
A person-centred fire risk assessment (PCFRA) is an individual assessment of a specific resident's needs, capabilities, flat location, and the building's evacuation routes and equipment. It must be tailored to the individual — generic assessments applied to multiple residents are not compliant.
Review PEEPs whenever a resident's circumstances change, when new residents move in, after any fire-related incident in the building, or at least annually as part of your fire risk assessment review cycle. Keep dated records of every review.
A Safety Case Report is a formal document that summarises how you manage building safety risks in your higher-risk building. It is required under section 85 of the Building Safety Act 2022, which was commenced on 16 January 2024. For a high-level overview of what a building safety case is and why you need one, see our companion guide.
The Safety Case Report is a formal document required under section 85 of the Building Safety Act 2022, summarising the assessment of building safety risks and the steps taken to manage them.>
— Building Safety Act 2022, s.85
The report serves a specific purpose: it demonstrates to the Building Safety Regulator (BSR) that you understand the safety risks in your building, have taken reasonable steps to manage them, and have plans to reduce the severity of any incidents that do occur.
Every Principal Accountable Person for a higher-risk building in England must prepare a Safety Case Report as soon as reasonably practicable. The report becomes a key part of your Building Assessment Certificate (BAC) application when the BSR calls your building in for assessment.
If you are not sure whether you are the Principal Accountable Person, our PAP Responsibilities guide explains who qualifies and what the role involves. For a comprehensive overview of the full Building Safety Act regime, see our Building Safety Act Complete Guide.
Before diving into preparation, it helps to understand an important distinction that causes confusion.
The Principal Accountable Person must prepare the Safety Case Report as soon as reasonably practicable. The practical trigger is when the BSR calls your building in for Building Assessment Certificate assessment.Your safety case is the overall approach to managing building safety risks. It is not a single document -- it is the totality of your risk assessments, management activities, safety measures, maintenance regimes, and evidence that your building is safe. Your safety case is an ongoing, evolving process. Your Safety Case Report is the formal document that summarises your safety case at a point in time. Think of it as a snapshot: it captures what risks exist, what you have done about them, and what you plan to do next.
The report documents the case. You maintain the safety case continuously; you write the report to demonstrate it.
This distinction matters because the BSR is assessing whether your ongoing safety management is adequate, not just whether your paperwork is in order. A well-written report that describes a poor safety case will not pass assessment. A thorough safety case documented in a clear report will.
Understanding how the BSR assesses your Safety Case Report helps you prepare one that meets their expectations. The BSR has stated that their assessment is proportionate -- there is no one-size-fits-all standard. What they look for depends on your building's type, age, height, construction, and the specific risks it presents.
The BSR assesses five key areas in your Safety Case Report: expected safety measures for your building type, their effectiveness and maintenance, action on legacy issues, aspects not built to current standards, and evaluation of additional measures.>
— BSR Safety Case Toolkit
The BSR considers five key areas during assessment:
The BSR will check whether your building has the safety measures that would be expected for its type. A 1970s concrete tower block has different expectations from a 2020 timber-framed building. The assessor considers what is reasonable for the building as it exists today.
What to document: List all safety measures currently in place -- fire doors, compartmentation, smoke ventilation, structural fire protection, alarm systems, sprinklers, dry risers, and any other relevant systems. Describe each system's purpose and coverage.Having safety measures is not enough -- the BSR wants to know they work and are maintained. A fire door that does not close properly or a ventilation system that has not been tested in years will raise concerns.
What to document: For each safety measure, describe the maintenance regime, testing schedule, most recent inspection results, and any remedial work undertaken. Reference your Golden Thread records where applicable.Many higher-risk buildings have known issues from their original construction or from previous management. The BSR wants to see that you are aware of these issues and have taken steps to address them.
What to document: Identify known defects, describe remediation programmes (completed or in progress), and explain how you manage any residual risk from issues that cannot be fully resolved. This includes cladding remediation, compartmentation breaches, and any defects identified during fire risk assessments.Older buildings were built to the standards of their time. The BSR does not expect every building to meet current Building Regulations, but they do expect you to have considered where your building falls short and what that means for safety.
What to document: Identify where the building does not meet current standards, assess the risk this creates, and describe any measures taken to compensate. For example, a building without sprinklers that would be required in a new build should document the additional fire safety measures in place.Finally, the BSR wants to see that you have considered whether more could be done. This is not about spending unlimited money -- it is about demonstrating a thoughtful evaluation of residual risk and whether additional measures would be proportionate.
What to document: Describe any additional measures you have considered, the reasoning for implementing or not implementing them, and any cost-benefit analysis undertaken. The BSR expects proportionate decision-making, not perfection.Preparing a Safety Case Report is a structured process. Work through these steps methodically, and you will build a comprehensive report that addresses the BSR's assessment criteria.
Your Safety Case Report draws on information you should already be maintaining as part of your Golden Thread obligations. Before you start writing, assemble:
Conduct a systematic risk assessment covering all building safety risks. This goes beyond fire risk -- the Building Safety Act covers structural safety, fire safety, and any risk arising from the spread of fire or structural failure.
For each risk, document:
For each identified risk, describe the steps you have taken to prevent it materialising and to reduce its severity if it does. This is the core of your Safety Case Report and directly addresses section 85(2)(b) and (c) of the Act.
Be specific. Rather than "fire doors are maintained," write "all 147 fire doors are inspected quarterly by [contractor name] under contract [reference]. Last full inspection: [date]. Defects remediated within [timeframe]."
If your building has known legacy issues -- whether from original construction, cladding concerns, or previous management failings -- document them honestly. The BSR will view a frank acknowledgement of issues with a credible remediation plan far more favourably than an attempt to minimise or overlook them.
For each legacy issue, describe:
Using the template outline below, assemble your findings into a structured document. The report should be clear enough that someone unfamiliar with your building could understand the safety risks and how you manage them.
Your Safety Case Report is a living document. Establish a review cycle and update it when:
[Building name] is a [number]-storey residential building located at [full address], comprising [number] residential units and [number] commercial units.>
The building was constructed in [year] and is of [construction type, e.g. reinforced concrete frame with brick cladding] construction. It is [height in metres] metres tall and falls within the higher-risk building definition under the Building Safety Act 2022.>
The building is registered with the Building Safety Regulator under reference [BSR registration number]. The Principal Accountable Person is [name/organisation].
The most recent fire risk assessment was carried out by [assessor name and qualifications] on [date]. The assessment identified [number] significant findings, of which [number] have been remediated and [number] remain open with target completion dates.>
Key fire risks identified include:
- [Risk 1, e.g. compromised compartmentation between floors 3-5] -- remediated on [date] by [contractor]
- [Risk 2, e.g. inadequate fire door maintenance in east stairwell] -- remediation in progress, target completion [date]
- [Risk 3] -- [status and timeline]
The building's structural integrity was last assessed by [structural engineer name and qualifications] on [date]. The assessment concluded that [summary of findings, e.g. the reinforced concrete frame is in satisfactory condition with no significant structural concerns].>
Known structural considerations include:
- [Item, e.g. concrete spalling to balcony soffits on floors 8-12] -- repair programme completed [date]
- [Item] -- [status]
The building is equipped with the following fire safety systems:>
| System | Coverage | Last tested | Next due | Contractor |
|--------|----------|-------------|----------|------------|
| [e.g. Fire alarm] | [e.g. All common areas] | [date] | [date] | [name] |
| [e.g. Dry riser] | [e.g. All floors] | [date] | [date] | [name] |
| [e.g. Emergency lighting] | [e.g. All escape routes] | [date] | [date] | [name] |
| [e.g. Smoke ventilation] | [e.g. Stairwells A and B] | [date] | [date] | [name] |>
Maintenance is carried out under a planned preventive maintenance schedule. All fire safety systems are tested at the intervals recommended by the relevant British Standard.
The building's Residents' Engagement Strategy was established on [date] in accordance with section 91 of the Building Safety Act 2022.>
[Number] residents have been identified as requiring a Personal Emergency Evacuation Plan (PEEP) under the Fire Safety (Residential Evacuation Plans) Regulations 2025. PEEPs have been prepared for [number] residents, with [number] pending completion.>
The building operates a [stay put / simultaneous evacuation] strategy. Residents have been informed of the evacuation strategy via [method, e.g. welcome packs, annual letters, notice boards].
The building's Mandatory Occurrence Reporting system was established on [date] in accordance with section 87 of the Building Safety Act 2022.>
In the reporting period [date range], [number] safety occurrences were reported. Of these:
- [Number] were reported to the BSR as required
- [Number] were resolved through internal management
- [Number] led to changes in safety measures or procedures>
The most significant occurrence was [brief description], which resulted in [action taken].
This Safety Case Report is reviewed [frequency, e.g. annually or when triggered by significant changes]. The next scheduled review is [date].>
The Principal Accountable Person maintains oversight of building safety through:
- [e.g. Monthly safety committee meetings]
- [e.g. Quarterly fire safety inspections]
- [e.g. Annual review of the safety case]
- [e.g. Continuous Golden Thread updates via digital platform]>
All building safety information is maintained digitally in accordance with the Golden Thread requirements under section 88 of the Act.
Understanding the assessment process helps you prepare with confidence rather than anxiety. The BSR has been clear that their approach is proportionate and building-specific.
When the BSR calls your building in for assessment, you have 28 days to submit your Building Assessment Certificate (BAC) application. Your Safety Case Report is a core part of this application, alongside other required documentation.
The BSR assessor reviews your submission against the five assessment criteria described above. They are looking for evidence that you understand your building's risks, have taken reasonable steps to manage them, and have a credible plan for ongoing safety management.
The Act requires the PAP to take "all reasonable steps" to manage building safety risks. This does not mean eliminating all risk -- that is impossible. It means taking proportionate action based on the severity and likelihood of each risk.
The BSR Safety Case Toolkit provides examples of reasonable steps for common risk categories. These examples are helpful guidance, not a prescriptive checklist. What is reasonable depends on your building's specific circumstances.
If the BSR is not satisfied with your Safety Case Report, the process is typically iterative rather than immediately punitive:
For a comprehensive overview of your compliance obligations, see our Building Safety Act Compliance Checklist.
The following scenarios illustrate how different buildings might approach their Safety Case Report. These are fictional examples for educational purposes.
The building manager, working with a fire safety consultant, identifies the following key risks:
The building manager's Safety Case Report is relatively straightforward because the building was constructed to modern standards. Key elements include:
This building presents unique challenges because of its mixed construction:
The questions below address the most common concerns building managers have about Safety Case Reports. For a fuller explanation of each answer, see the detailed sections above.
What is a Safety Case Report?A Safety Case Report is the formal document required under section 85 of the Building Safety Act 2022. It summarises your assessment of building safety risks, the steps taken to prevent those risks materialising, and the steps to reduce their severity if they do. It is reviewed by the BSR as part of your Building Assessment Certificate application.
Who must prepare the Safety Case Report?The Principal Accountable Person (PAP) is legally responsible. This is typically the freeholder or the person who holds the legal estate in the building's structure and exterior. You can commission professionals to help, but the legal responsibility remains with you.
Is there a deadline for the Safety Case Report?There is no single deadline. The Act requires preparation "as soon as reasonably practicable." The practical trigger is when the BSR calls your building in for BAC assessment -- you then have 28 days to submit your application, which includes the Safety Case Report.
What is the difference between a safety case and a safety case report?Your safety case is the ongoing process of managing building safety risks -- the totality of your assessment, management, and evidence. Your Safety Case Report is the document that summarises the safety case at a point in time. The report documents the case.
What does the BSR look for during assessment?The BSR considers five areas: expected safety measures for your building type, their effectiveness and maintenance, action on legacy issues, consideration of aspects not built to current standards, and evaluation of additional measures. See the detailed section above.
Do I need a specific template?The BSR has not mandated a specific format. The template outline in this guide provides a suggested structure aligned with BSR assessment criteria and the Safety Case Toolkit. Adapt it to your building's circumstances.
How often should I update the report?Treat it as a living document. Update when significant changes occur (major works, new risk information, incidents) and at regular intervals appropriate for your building. Annually at minimum is a reasonable baseline.
Your safety case must demonstrate that fire safety systems are not only present but actively maintained and evidenced. Fire doors are a critical component of your compartmentation strategy, and the BSR expects to see a documented inspection programme showing quarterly checks on flat entrance doors and annual checks on common area doors. For detailed guidance on what to document and how to build an evidence trail for fire door inspections, see our fire door inspection requirements guide.
A Safety Case Report is a living document. It must be reviewed and updated whenever there are significant changes to the building, new risk information, safety incidents, or changes to maintenance regimes.