The Regulatory Landscape

The industry has the obligation.
It does not yet have
the infrastructure.

"The duty holders who carry personal liability under the Building Safety Act are, in the majority of cases, operating without the systems needed to demonstrate they are meeting that liability."

The Building Safety Act 2022 created a new legal order for higher-risk buildings. It created duty holders, gateways, golden threads, and competence obligations. It did not create the tooling to meet them. That gap is where projects fail, where submissions are rejected, and where liability accrues.

01
The Competence Crisis
PAS 8671, 8672, 8673, and 8674 set out formal competence frameworks for principal designers, principal contractors, and building safety managers. The obligation to declare competence exists. The obligation to verify it exists. The obligation to maintain it throughout the project lifecycle exists.

Most projects have no structured mechanism for any of these. Declarations are made informally. Verification is not evidenced. Currency is not tracked. When a regulator asks for proof, there is none.
PAS 8671 · 8672 · 8673 · 8674 — Building Safety Act 2022 s.32–35
02
The Golden Thread Obligation
The golden thread is not a concept. It is a statutory requirement under the Building Safety Act 2022. It is the structured, digital record of everything that was known about a building, when it was known, and what was done as a result.

It must be created during design and construction. It must be handed over at completion. It must be maintained in occupation. Most projects producing a folder of PDFs and calling it a golden thread are not compliant. The BSR knows this.
Building Safety Act 2022 s.88 — Golden Thread
03
The Change Control Vacuum
Regulations 18–26 of the Building (Higher-Risk Buildings Procedures) Regulations 2023 require that every controlled change to a higher-risk building design is classified, recorded, and — for notifiable and major changes — reported to the Building Safety Regulator.

A major change affecting escape routes, structural elements, or external wall systems requires work to stop until the BSR approves it. Most projects have no mechanism to detect, classify, or escalate these changes. They happen in the drawing set. Nobody notices until it is too late.
HRB Procedures Regs 2023 — Regs 18–26
04
The Gateway Submission Gap
Gateway 2 applications are being rejected. The BSR has published its validation criteria. The Build UK guidance is explicit. The 14 mandatory checklist items are defined. The four prescribed documents are specified.

And still applications arrive incomplete, with stub documents, missing competence declarations, and drawing sets that cannot demonstrate regulatory compliance. The 8-week determination clock does not start until the application is valid. Invalid applications extend programmes, increase cost, and expose duty holders to enforcement action.
HRB Procedures Regs 2023 — Schedule 1 · Build UK Validation Guide Feb 2026
The Consequences of Getting It Wrong
Enforcement Action
The Building Safety Regulator has enforcement powers under the Building Safety Act. Stop notices, prohibition notices, and prosecution are available to it. Duty holders carry personal liability. This is not a corporate risk — it is an individual one.
Programme Collapse
A rejected Gateway 2 application adds months to a programme. A major change that stops work while BSR notification is awaited can cost weeks per occurrence. Projects without change control infrastructure are exposed to cascading delay.
Occupation Withheld
Gateway 3 — the completion certificate — requires the golden thread to be complete and the as-built position to be evidenced. Without it, occupation cannot begin. A building completed but not certified is a building generating no revenue and accruing cost.
The Legislative Timeline

A new legal order
for higher-risk buildings.

April 2022
Building Safety Act 2022 receives Royal Assent
The most significant reform of building safety regulation in a generation. New duty holders, new criminal offences, new liability framework. The direct legislative response to Grenfell.
October 2023
Higher-Risk Buildings Procedures Regulations 2023 in force
Regs 18–26 established the three-tier change control regime. Gateway applications became mandatory. The BSR opened for business. The 18-month transition period ended.
February 2026
BSR Validation Guide updated — Build UK / CLC
Tightened validation criteria for Gateway 2 applications. Explicit guidance on prescribed documents, competence declarations, and drawing set requirements. The bar has risen.
Forthcoming
Expanded HRB definition — more buildings in scope
The regulatory perimeter is expected to extend. Buildings currently outside the HRB regime are building safety compliance infrastructure now. The direction of travel is clear.

STRAND was built
for exactly this moment.

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