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Gateway 2 is the Building Safety Regulator’s (BSR) pre-construction approval for covered higher-risk building work in England. Gateway 3 is the completion-certificate stage, based on the finished, as-built building. You must have Gateway 2 approval before starting work that falls within the higher-risk building (HRB) regime. After the work is complete, you apply at Gateway 3; for a qualifying residential HRB, the building must also be registered before people move in.
The gateways are separate stop/go decisions. Approval at Gateway 2 confirms that the proposed project and its management arrangements can satisfy building regulations; it does not certify the finished building. Gateway 3 tests completion evidence and the building as constructed.
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Which projects use Gateway 2 and Gateway 3?
This process applies in England. Under current Building Safety Regulator guidance (updated 1 October 2026), an HRB for this building-control process is a building that is at least 18 metres high or at least seven storeys and either has at least two residential units or is used as a hospital or care home.
For qualifying HRB work, the BSR is the building-control authority. Buildings outside that definition follow a different building-control route. Whether a particular alteration, conversion, remediation project or new build is within the regime depends on the building and the work, so the current guidance and the project facts must be checked together.
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What “higher-risk” means here
- The height test is at least 18 metres or at least seven storeys.
- The building must have at least two residential units, or be a hospital or care home.
- The description is for the higher-risk building building-control process in England, not a UK-wide rule.
- Some work has exceptions or transitional arrangements, including certain exempt work, competent-person-scheme work, fibre-optic work and emergency work. An exception is project-specific and should be confirmed before relying on it.
Gateway 2 and Gateway 3 compared
| Comparison | Gateway 2 | Gateway 3 |
|---|---|---|
| When it occurs | Before covered building work starts | When the work is complete |
| Application | Building-control approval application | Completion-certificate application |
| Main question | Can the proposed work comply with building regulations, and are the project controls and dutyholders arranged competently? | Does the completed, as-built building meet all relevant building-regulations requirements? |
| Information basis | Proposed design, compliance evidence, dutyholder arrangements and construction controls | Updated records describing what was actually built, declarations and mandatory-occurrence reporting information |
| Legal effect | Required before work starts; starting without required approval is a criminal offence | BSR may issue a completion certificate when satisfied; that certificate is needed to register a qualifying residential HRB before occupation |
| What it does not do | It does not approve the finished building | It does not replace the need for the earlier approval |
These are decision points, not two names for the same approval. A validated application is only an application that has passed an administrative completeness check. As the BSR’s GOV.UK guidance states: “A validated application does not mean that the application has been approved.”
Gateway 2: approval before construction starts
When Gateway 2 is required
The client must obtain BSR building-control approval before starting covered work on a higher-risk building. This is the legal stop point: design development, procurement or an appointment does not itself authorise construction. Work must not begin until the required approval has been granted.
If the project is divided into stages, approval is required for each stage before work on that stage begins. A staged strategy therefore needs a realistic sequence of applications and decisions rather than treating one approval as permission for every later package of work.
What the application is intended to prove
BSR uses the application to consider whether the proposed work is capable of complying with building regulations, whether the client will manage the project properly and whether the appointed people are competent for their roles. The application is about the proposed design and the controls that will govern construction; it is not a certificate that every detail will remain compliant after construction changes.
Prescribed Gateway 2 evidence for a new HRB
The statutory-regime impact assessment for the Building (Higher-Risk Buildings Procedures) (England) Regulations 2023 describes a set of plans and documents supporting a new-HRB application. The package includes:
- Competence declaration: evidence that the relevant organisations and individuals have the competence needed for their duties.
- Building-regulations compliance statement: an explanation of how the proposed work is intended to meet applicable requirements.
- Fire and emergency file: information addressing fire safety and emergency arrangements for the proposed building.
- Construction-control plan: the arrangements for controlling construction so the approved design and building-regulations requirements are delivered.
- Change-control plan: the process for identifying, assessing, approving and recording changes.
- Mandatory-occurrence reporting framework description: how reportable safety occurrences will be identified and reported to the regulator.
- Partial-completion strategy, where relevant: arrangements for a proposal to occupy part of a building before all work is complete.
The exact information needed depends on the application and the project. The documents are not a substitute for coordinated design: drawings, specifications, fire information, structural information and management arrangements need to tell a consistent story.
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Who is responsible for securing approval?
The client remains legally responsible for securing Gateway 2 approval, even when another person is nominated to submit the application or manage the process. Delegating administration does not transfer the client’s legal responsibility. The client should therefore establish who owns each document, how design decisions are recorded and who will respond to BSR questions.
What happens after submission?
- Prepare the application: assemble the proposed design information, prescribed documents, dutyholder details and any stage or partial-completion strategy.
- Submit to BSR: the application enters the regulator’s validation and assessment process.
- Respond to validation issues: correct omissions or administrative defects identified during validation. Validation is not approval.
- Support the technical assessment: provide clear, coordinated answers to BSR’s questions about compliance, fire safety, construction controls, competence or changes.
- Wait for the decision: do not start the covered work while the application is under assessment.
- Record the approval and conditions: use the approved information and any conditions to control construction and later change decisions.
Under current guidance, the assessment period can be up to 12 weeks for applications for new HRBs and up to eight weeks for existing HRBs, absent an agreed extension. Those periods are assessment provisions, not a promise that an individual project will be decided within that time.
Gateway 3: completion and the as-built record
When to apply
The applicant must apply for a completion certificate when the work is complete. Gateway 3 is therefore based on the building that was actually constructed, not solely on the design that received Gateway 2 approval.
What the completion application contains
Documents prepared for Gateway 2 are maintained and updated during construction and form part of the Gateway 3 application. The completion package includes updated information reflecting the as-built building, together with:
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- Principal designer declaration addressing the completed design and the designer’s duties.
- Principal contractor declaration addressing the completed construction and the contractor’s duties.
- A list of written mandatory-occurrence reports submitted to the regulator.
In practical terms, the handover record needs to show what changed from the approved proposal, how those changes were controlled and what evidence demonstrates that the final installation meets the relevant requirements. A drawing marked “for construction” is not automatically an as-built record; the completion information must reflect the building delivered.
How the certificate is issued
BSR issues a completion certificate when it is satisfied that the work meets all relevant building regulations. Submission alone does not create a right to occupation or an automatic certificate. If information is incomplete, inconsistent or does not demonstrate compliance, the application may need clarification, further evidence or corrective work before BSR can be satisfied.
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Completion certificate and residential occupation
For a higher-risk building with at least two residential units, BSR registration is required before people live there. The completion certificate is needed for that registration. A project team should therefore plan the completion application, certificate decision and registration as linked pre-occupation activities, rather than leaving them until residents are due to move in.
Where partial occupation is proposed before all work is complete, the Gateway 2 package must include a partial-completion strategy. That strategy does not remove the need to meet the applicable completion and registration requirements for the occupied residential HRB.
How the two gateways work together on a real project
- Classify the building and work: confirm whether the building meets the HRB height, storey and use criteria in England and whether an exception or transitional arrangement could apply.
- Set up dutyholders and competence arrangements: identify the client, principal designer, principal contractor and other relevant roles, and assemble the competence declaration.
- Develop the Gateway 2 package: coordinate design information with the compliance statement, fire and emergency file, construction-control plan, change-control plan and reporting framework.
- Submit and obtain approval: resolve validation or assessment queries and wait for BSR approval before beginning the relevant stage of work.
- Control construction and changes: operate the approved controls, record decisions, update documents and report mandatory occurrences as required.
- Compile as-built evidence: update the Gateway 2 documents to reflect the completed building and gather the client, principal designer and principal contractor declarations.
- Apply at Gateway 3: submit the completion-certificate application and the list of written mandatory-occurrence reports.
- Complete the occupation route: obtain the certificate and, for a qualifying residential HRB, register the building before people live there.
This sequence explains why a project can have an approved design but still be unable to obtain its completion certificate: construction evidence, changes, declarations or final compliance may not yet satisfy the Gateway 3 test.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Processing times: what the latest BSR data means
BSR’s report covering July to September 2026 says its data were correct as of 5 October 2026. It reported these median Gateway 2 approval times:
| Application type | Reported median approval time | Reporting qualification |
|---|---|---|
| New higher-risk buildings and conversions | 23 weeks | BSR July–September 2026 reporting period; data correct as of 5 October 2026 |
| External remediation | 32 weeks | BSR July–September 2026 reporting period; data correct as of 5 October 2026 |
The report also recorded 64 submissions in September, compared with 34 in August, 17 in July and 12 in June. BSR said applications rose ahead of the Building Safety Levy taking effect on 1 October 2026.
A median is a description of completed cases in that reporting period, not a statutory target and not a forecast for your application. Complexity, submission quality, design changes and the regulator’s questions can all affect an individual timetable. Programme managers should allow time for preparation, validation, assessment and responses instead of scheduling construction against the median alone.
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Common mistakes and how to avoid them
Starting work after validation
Validation only means the application has passed the regulator’s initial completeness check. It is not approval. Starting covered work without the required building-control approval is a criminal offence.
Treating Gateway 2 as a final compliance certificate
Gateway 2 assesses the proposed work and management arrangements. It cannot account for every site decision or change. Keep the change-control process active and preserve evidence for Gateway 3.
Leaving the as-built record until handover
If updates are postponed, the team may struggle to reconstruct what was installed, which changes were accepted and which mandatory occurrences were reported. Update the controlled documents during construction.
Assuming an agent carries the client’s legal responsibility
An agent can prepare or submit information, but the client remains responsible for securing the required approval. Define approvals, document ownership and escalation routes in the project-management arrangements.
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For a qualifying residential HRB, residents cannot move in before the building is registered, and the completion certificate is needed for that registration. Include BSR’s decision and the registration step in the occupation programme.
Applying a UK-wide assumption
The gateway process described here is the English HRB building-control process. Do not apply its requirements automatically to a project in Wales, Scotland or Northern Ireland; those jurisdictions have their own building-control frameworks.
Gateway 2 and Gateway 3 checklist
Before Gateway 2
- Confirm the building’s height, storey count and use.
- Check whether the proposed work is covered and whether any claimed exception or transitional arrangement is genuinely applicable.
- Identify the client and dutyholders and document competence arrangements.
- Coordinate the compliance statement, fire and emergency file, construction-control plan, change-control plan and mandatory-occurrence reporting framework.
- Add a partial-completion strategy if partial occupation is proposed.
- Allow for validation, technical assessment and responses; do not schedule the start of covered work before approval.
During construction
- Build to the approved information and operate the construction-control plan.
- Assess and record changes through the change-control plan.
- Maintain the fire, emergency, compliance and construction records so they describe the developing building.
- Submit written mandatory-occurrence reports where required and retain the list for Gateway 3.
- For staged work, secure approval before starting each approved stage.
Before Gateway 3 and occupation
- Confirm that the work is complete and that the documents describe the as-built building.
- Obtain the client, principal designer and principal contractor declarations.
- Compile the list of written mandatory-occurrence reports submitted to BSR.
- Submit the completion-certificate application and resolve any BSR queries.
- For a residential HRB with at least two units, obtain the certificate and register the building before people live there.
The practical difference in one sentence
Gateway 2 asks, “May this covered higher-risk building work start on the basis of this design and these controls?” Gateway 3 asks, “Has the completed building been shown to meet the relevant building regulations, and can the required completion and registration steps proceed?” Treating those questions as separate is the key to programming, documenting and handing over HRB work lawfully.
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