The BSR has made good progress in easing the logjam at gateway 2 of the approval process. Mark Brooks explains what comes next

With an increasing number of high-rise residential developments defined as “high risk” by the Building Safety Act (BSA) now passing through gateway 2, the building control approval application stage of the delivery process, things are looking up for 2026.
Next comes the challenge of getting these developments through gateway 3, the final and perhaps most rigorous of the three holding points established by the BSA to ensure that safety is considered at each stage of the building control process.
Failing at the last hurdle could mean projects face delays in occupation, increased costs and additional work to resolve non-compliance, and the risk of sanctions. So, what does gateway 3 require of those involved in a project, and what does passing it entail?
>> Also read: Is the BSR’s plan to tackle the backlog likely to succeed?
Gateway 3 covers completion certificates, introducing – in the words of the Building Safety Regulator – a “hold point” at the completion of a project before occupation can occur, one which puts the safety of future occupants front and centre. Gateway 3 is an essential part of the new regulatory framework which will ensure that the BSR has the required information to issue a completion certificate.
So this stage should be considered and planned for from the start of the building control process to ensure that a programme is in place to allow the collection of all necessary information from the outset, throughout the gateway 2 process and to project completion. Known as the”golden thread”, this is the evidence that the completed building complies with Building Regulations through a comprehensive, accurate, electronic record of the finished building.
Preparation from the outset is the key to successfully establishing and maintaining an effective golden thread
The main areas to be aware of regarding the golden thread include a formal responsibility to electronically create, maintain and share safety information relating to a building, while designated individuals will be required to ensure that the information is complete and accurate.
The golden thread is designed to be a single source of truth for a building’s safety data, with such information held securely, in a format which is both accessible and understandable to those who have to use it. Regular reviews and updates will be required to keep the golden thread accurate and reliable over time, when works are carried out or there are fire or structural risks identified.
Preparation from the outset is the key to successfully establishing and maintaining an effective golden thread. While digital and technological barriers can make this more challenging, having the right team in place – with awareness of the work required across areas such as digital readiness, collaborative workflows, quality control, procedures and effective communication – is essential.
Building Regulations require a principal designer for projects involving building works, a building regulation and multiple designers. This is separate from the CDM principal designer, although the same organisation can often fill both roles – as we often do. When we do, this allows us to ensure that the considerations of gateway 3 are implemented at the earliest stage.
This means making sure that processes and documentation are fully in place ahead of project completion, eliminating avoidable delays and issues when it comes time for the final assessment. For example, timely registration of the building with the BSR and ensuring there is adequate documentation to complete the building safety case report.
This approach has to be embedded from the outset – for us, it begins with ensuring that the client is aware of their duties, and meeting with the design team to prepare a responsibility matrix: Responsible, accountable, consulted and informed.
Compliance should be discussed and documented with each designer. Reports should be prepared at the end of each stage, showing the route to compliance and any outstanding issues.
When retained through the construction process, we will liaise with the contractor to define the design process and identify responsible parties, as well as meeting with the principal contractor and subcontractors to agree responsibilities.
In addition, we attend progress meetings to manage coordination and compliance with Building Regulations, hold regular workshops with the design team and contractors, and obtain supporting evidence from the principal contractor to demonstrate compliance. We will also share a completion report, detailing compliance throughout the process.
It is encouraging that the BSR, under chair and former firefighter Andy Roe, appears to have made decent headway with those schemes that were part of the recent logjam. The question is, will his magic work on gateway 3 applications?
With the input of professional firms, there is every reason to believe that the industry can create the conditions to deliver the secure, sustainable and – crucially – safe homes that the UK so badly needs.
Mark Brooks is a partner at Stace, an independent construction and property consultancy
















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