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Compliance starts with identifying the building, the legal dutyholder and the stage of work involved. In England, an organisation connected with a higher-risk building may have to register the building, assess and control structural and fire risks, maintain a secure digital “golden thread” of information, involve residents, report safety occurrences and coordinate with other dutyholders. On a project, clients, principal designers and principal contractors have additional duties before anyone occupies the building.
The Building Safety Act 2022 does not create one checklist for every organisation. The steps below are a practical framework for establishing which regime applies and putting the required arrangements in place. They are general information, not a determination of legal responsibility for a particular property.
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1. Establish whether the building and activity are in scope
The Act’s building-safety regimes described here apply to England. Start by recording the building’s location, use, height, storeys, number of residential units and whether the work is design and construction or management of an occupied building. The Building Safety Regulator (BSR) guidance sets different boundaries for occupied buildings and projects.
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Occupied higher-risk residential buildings
For the occupied high-rise residential regime, the building is generally a higher-risk building when it is at least 7 storeys or 18 metres in height and contains at least 2 residential units. A qualifying residential higher-risk building must be registered with the BSR before people live in it. The official accountable-person guidance, updated 18 September 2024, explains the occupied-building scope and registration requirement.
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Higher-risk building projects
The design-and-construction regime is broader than the occupied residential rules. The BSR’s project guidance covers buildings meeting the height or storey and residential-unit criteria and also identifies hospitals and care homes in relevant circumstances. Do not assume that a project is outside the Act merely because it will not become a residential block.
| Question | Why it matters | Evidence to record |
|---|---|---|
| Where is the building? | The guidance and duties described here are for England. | Address, jurisdiction and ownership records. |
| Is it occupied or under design/construction? | Occupied-building accountable-person duties differ from client, principal-designer and principal-contractor duties on a project. | Programme, completion and occupation status. |
| Does it meet the height/storey and use criteria? | This determines whether higher-risk building controls and registration apply. | Measured height, storey count, use classification and residential-unit count. |
| Are hospitals or care homes involved? | They can fall within the project definition in relevant circumstances even though the occupied guidance is framed around residential buildings. | Use, layout and statutory classification information. |
2. Identify the organisation’s legal dutyholder
Responsibility follows the legal relationship with the common parts, not simply the organisation named in a service contract. An accountable person (AP) is generally an organisation or individual that owns the building’s common parts or has a legal obligation to repair them. Depending on the ownership and repairing arrangements, an AP can be a freeholder, estate owner, landlord, management company, resident management company, right-to-manage company or commonhold association.
Finding the principal accountable person
Every building has one principal accountable person (PAP). If there is only one AP, that organisation is the PAP. Where several APs exist, the AP responsible for the structure and exterior is generally the PAP. Confirm this from leases, title documents, repairing covenants and the physical areas each party controls; do not assign the role solely because a company manages the block.
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Random freezes, missing sound and display glitches usually trace back to one bad driver. Find and replace yours safely.Free scan · under a minuteA managing agent may perform inspections, record keeping or resident communications, but an agency agreement does not transfer the statutory role. APs and PAPs can appoint agents to carry out tasks, yet they retain responsibility and potential liability for making sure the duties are performed. Build explicit instructions, reporting lines, competence requirements and audit rights into any appointment.
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Resolving disagreement
If interested parties cannot agree who is an AP or PAP, an application can be made to the First-tier Tribunal for a decision. Preserve the documents and correspondence supporting the organisation’s position while the issue is resolved; uncertainty about the role should not be used as a reason to stop risk controls.
Separating the AP from the fire-safety Responsible Person
The AP/PAP role is distinct from the Responsible Person under the Regulatory Reform (Fire Safety) Order 2005. One organisation may hold both roles, but it is not automatic. Where they differ, establish a controlled exchange of relevant building-safety and fire-safety information, using appropriate data-protection safeguards. The BSR explains the relationship in its information requirements for accountable persons.
3. Operate a risk-management system for an occupied building
Each AP must manage the building-safety risks in the parts for which it is responsible. The relevant risks are structural failure and the spread of fire. The duty is not satisfied by commissioning a one-off survey: the organisation must understand the hazards, the controls already in place, how those controls are maintained and how their effectiveness is reviewed.
Assess the risks and set controls
- Define the exact structure, exterior, common parts and systems for which each AP is responsible.
- Identify credible scenarios involving structural failure or fire spread, including how a defect or change could affect residents and others.
- Document preventative and mitigative measures, their owners, inspection frequencies, acceptance criteria and escalation routes.
- Use competent people to inspect, test and maintain safety-critical features, and retain evidence of findings and remedial work.
The statutory test requires an AP to take all reasonable steps to prevent a building-safety risk materialising in its area of responsibility or to reduce the severity of an incident if it does. “Reasonable” should therefore be supported by a written rationale, evidence of competence, prioritisation of defects and records of decisions, rather than an undocumented assertion that a measure was too expensive or inconvenient. The duty is set out in Part 4 of the Building Safety Act 2022.
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Plan, monitor and review
Put arrangements in place to plan the controls, monitor delivery and review whether they remain suitable after alterations, incidents, inspection findings or changes in occupancy. The PAP coordinates building-wide functions where the Act assigns that responsibility and should maintain a view of risks that cross AP boundaries.
Use mandatory occurrence reporting
APs must report relevant safety occurrences to the BSR through the mandatory occurrence reporting system operated by the PAP. Define what residents, contractors, staff and other APs must report, who screens reports, how urgent hazards are escalated and how submissions to the BSR are evidenced. Keep the report, decision and follow-up action together in the building record.
4. Involve residents and provide usable safety information
The PAP must prepare and act in accordance with a residents’ engagement strategy. It must promote residents’ and owners’ participation in building-safety decisions, be reviewed and revised when appropriate and be provided as required. Treat the strategy as an operating process rather than a document produced once for compliance.
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- Explain the building’s principal safety risks and the controls that address them in language residents can understand.
- Provide practical routes to report hazards, suspected defects and safety occurrences, with confirmation that reports have been received.
- Set out how residents and residential-unit owners can contribute to decisions, receive updates and challenge information they believe is wrong.
- Record consultations, responses, decisions and changes made as a result.
APs must provide residents and owners with prescribed building information, including safety summaries, ways to report risks and relevant fire and evacuation information. Coordinate the content where more than one AP is involved so that residents do not receive contradictory instructions.
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5. Build and maintain the golden thread
The golden thread is the digital building record that allows dutyholders to understand the building, demonstrate compliance and manage it safely over time. The BSR’s golden-thread guidance, updated 18 September 2024, says information must be maintained, secure, available when needed, understandable, accessible and handled in accordance with data-protection requirements.
Contents for an occupied building
For an occupied higher-risk building, the record should include the health and safety file, safety case report, residents’ engagement strategy and mandatory occurrence reporting system, alongside the drawings, specifications, inspection results, maintenance evidence, risk assessments, decisions and change history needed to understand the building. Keep a clear link between each risk, control, responsible person, inspection and outstanding action.
Information-quality controls
- Use a defined naming, version and approval convention so the current record can be identified.
- Restrict editing rights, protect sensitive information and maintain an audit history of changes.
- Provide reliable access to authorised dutyholders, residents where information is prescribed, regulators and emergency or fire-safety partners.
- Test retrieval and readability; a file that exists but cannot be found or understood is not a useful safety record.
- Back up the information and document how it will be transferred if an AP, managing agent or contractor changes.
APs must share relevant information with other APs and transfer the information for which they were responsible when their role ends, subject to the applicable exceptions. Agree the format, timing, ownership and acceptance check for every handover instead of treating transfer as an informal email attachment.
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On a higher-risk building project, the client, principal designer and principal contractor each have legal duties. The BSR’s design and construction collection, updated 27 March 2025, sets out the project regime.
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Client responsibilities
The client must manage the project so the completed work matches what was approved, keep information about regulatory compliance and share relevant building information with designers and contractors. The client’s golden-thread record should describe the building, show how it complies with building regulations, document how dutyholders are meeting their responsibilities and explain the management arrangements used to control the work.
Principal designer and principal contractor responsibilities
Appoint competent dutyholders and give them the information, time and resources needed to plan and execute compliant work. The principal designer coordinates design decisions and compliance information; the principal contractor coordinates construction, workmanship, sequencing and the information produced on site. Keep evidence of appointments, competence, instructions, design changes, inspections, tests, non-conformities and close-out decisions.
Completion and handover
When the work is complete, the client applies for the completion certificate and demonstrates that required information has been transferred to the AP and, where relevant, the fire-safety Responsible Person. Do not wait until the final day to assemble the handover: update the record as designs, products, installed conditions and approvals change, then carry out a formal completeness and acceptance check.
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7. A practical implementation sequence for an organisation
- Create a scope file. Record jurisdiction, use, height, storeys, residential units, occupation status, project stage and the reason the building is or is not treated as higher-risk.
- Map ownership and repairing obligations. Review titles, leases, transfer documents and contracts to identify every AP and the areas each controls.
- Nominate the PAP and document the decision. Confirm which AP is responsible for the structure and exterior, and establish how APs will coordinate.
- Check registration. For a qualifying residential higher-risk building, complete BSR registration before occupation and retain the confirmation in the golden thread.
- Set governance. Name accountable executives, operational leads, competent advisers and escalation contacts; define what an agent may do without implying that legal accountability has moved.
- Complete the safety case. Identify structural and fire-spread hazards, controls, gaps, actions, deadlines and review triggers for each AP’s area.
- Install reporting and engagement channels. Launch mandatory occurrence reporting, resident risk-reporting routes and the PAP’s residents’ engagement strategy.
- Populate and test the digital record. Assemble required files, apply access and version controls, test retrieval and record unresolved information gaps with owners and dates.
- Coordinate external interfaces. Agree information exchanges with other APs, Responsible Persons, contractors, residents, owners, the BSR and relevant fire and rescue authorities.
- Audit and improve. Review incidents, inspections, changes, complaints, engagement feedback and handovers; update controls and the record when circumstances change.
8. Select systems and advisers against the legal need
The Act does not approve a particular software product or consultancy. When evaluating an information-management system, check whether it supports the organisation’s role and building scope; preserves accuracy, security, availability, accessibility and transferability; records responsibility and audit history; and enables appropriate sharing with residents, regulators and other dutyholders.
When appointing a specialist adviser, define the building and statutory scope, required competence, deliverables, assumptions, site access, independence, reporting format and who owns the resulting information. An adviser can improve evidence and technical understanding, but cannot replace the AP’s or PAP’s legal accountability. These criteria are practical implications of the official duties, not a regulator-approved product checklist.
9. Common compliance failures and corrective action
| Failure | Why it creates risk | Corrective action |
|---|---|---|
| Assuming the managing agent is the AP | A service contract may not create the ownership or repairing obligation required for the legal role. | Review title and repairing documents; record the AP/PAP decision and delegate tasks explicitly. |
| Using one generic risk assessment for the whole block | Different APs may control different parts and hazards. | Map responsibilities and maintain coordinated, area-specific controls. |
| Treating the golden thread as a document archive | Uncontrolled, inaccessible or outdated files cannot support safe decisions. | Apply ownership, versioning, audit, access, backup and retrieval testing. |
| Leaving resident engagement until after an incident | Residents may not know how to report hazards or understand evacuation information. | Operate and review the strategy, provide prescribed information and evidence responses. |
| Assembling handover information at project completion | Late reconstruction can hide changes, defects and missing approvals. | Update the record throughout design and construction and formally accept the transfer. |
| Confusing AP and Responsible Person duties | Important information may not reach the party managing fire-safety arrangements. | Identify both roles and establish lawful, documented information sharing. |
10. Keep the organisation ready for scrutiny
A defensible compliance position is demonstrated through current records, not a policy statement alone. The organisation should be able to show who held each duty, what risks were identified, which reasonable steps were selected, when controls were checked, how reports were handled, what residents were told and how information moved between dutyholders. The BSR’s building-safety guides for accountable persons provide supporting material for setting up these arrangements.
Review the system after a material alteration, change of ownership or agent, new inspection evidence, a safety occurrence, a significant resident concern or a change in the building’s use. Update the golden thread and engagement strategy at the same time, and preserve the decision trail showing why the revised controls are reasonable.
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