05 Aug Building Safety Act and Golden Thread: A Practical Guide to Gateways and Digital Compliance
Building safety compliance: understanding the Building Safety Act and the golden thread
The Building Safety Act changed how construction projects operate in England. It gives clients, designers, contractors and building owners more responsibility for safety.
They must explain their safety decisions and keep clear records. They must also show who made each decision. This responsibility often sits with an accountable person.
For construction firms and civil engineering companies, compliance now means more than producing drawings or passing inspections. Teams must:
- Identify who made key decisions
- Explain why they made them
- Record all changes
- Show building owners how to manage the building safely
This is where the golden thread of information is important. It provides an accurate record of a building’s design, construction and safety information. It supports the building throughout its life.
What is the Building Safety Act?
The Building Safety Act 2022 created a stronger system for building safety. It aims to improve:
- Accountability
- Competence
- Safety management
- Information sharing
The Act creates a clear chain of responsibility. Everyone who commissions, designs or builds work has defined duties.
The rules focus mainly on higher-risk buildings. However, dutyholder and competence duties apply more widely to building work in England.
The Act applies in England. Wales, Scotland and Northern Ireland have their own building safety rules.
What is a higher-risk building?
For design and construction, a higher-risk building generally includes a building in England that:
- Is at least 18 metres high or has at least seven storeys
- Contains at least two homes
- Is used as a hospital or care home
- Does not fall under a legal exclusion
The exact definition depends on the building’s use, height, storeys and design. Some hotels, military buildings and secure residential buildings may be excluded.
Project teams should check the current legal definition for each project. They should not rely only on the building’s height. Read the government guidance on higher-risk buildings.
The Building Safety Regulator, or BSR, has extra powers over higher-risk building work. A higher-risk residential building must also be registered with the BSR before people move in.
Project teams should follow current BSR guidance. This includes guidance that refers to higher-risk buildings 79, higher-risk building 69 and higher-risk building 65, where relevant.
Understanding the three gateways
The gateway process creates key checks during the planning, design, construction and completion stages.
Gateway 1: Planning stage
Gateway 1 takes place during planning. It asks the project team to consider fire safety at an early stage.
The team should review:
- Emergency service access
- Fire appliance access
- The site layout
- Evacuation plans
- The building’s height and use
- Nearby buildings
- Any fire risks created by the design
Gateway 1 helps teams find major fire safety issues before planning permission is granted. Early action can reduce redesign, delays and extra costs.
Gateway 1 applies to developments that meet the definition of a relevant building under planning law. Teams should use it to test the design. They should not treat it as a simple form-filling exercise.
Gateway 2: Building control approval before construction
Gateway 2 applies to higher-risk building work under the Building Safety Act.
Teams must not start work until the Building Safety Regulator grants building control approval.
For relevant projects, the client must submit an application to the registered building control approver or the regulator responsible for the work. The application must contain enough information to show that the design meets building regulations.
The application may include:
- Detailed plans and specifications
- Structural and fire safety information
- The building layout
- Materials and construction methods
- The building’s planned use
- Information about risks to residents
- A construction control plan
- A change control plan
- Competence declarations
- Details of the client, principal designer and principal contractor
- Plans for managing compliance during construction
- Other documents required by law
The team should start work only after receiving approval. Starting without approval may lead to enforcement action, delays and extra costs.
The Gateway 2 design must contain enough detail. Teams should not submit a basic concept and plan to solve major safety issues later.
Project teams should also understand how building control authorities 33, approved inspectors functions and registered building inspectors may affect the approval route.
Gateway 3: Completion and occupation
Gateway 3 takes place when construction ends. The BSR must assess the completed work before people can occupy the building.
The team may need to submit:
- As-built drawings
- Final specifications
- Building regulations information
- Details of approved changes
- Testing and commissioning records
- Fire safety information
- Structural safety information
- A completion certificate application
- Dutyholder declarations
Gateway 3 checks whether the team built the project as approved. It also checks whether the building meets building regulations.
The team must not treat practical completion as permission to occupy. The physical work may be finished, but more regulatory steps may still be needed. This is especially true for an occupied building or an occupied higher-risk building.
Who holds accountability?
The Building Safety Act and building regulations give each project role clear duties. A contract cannot simply remove these legal duties.
The client
The client commissions the work. The client must create arrangements that support compliance.
The client should:
- Appoint competent designers and contractors
- Confirm that the principal designer and principal contractor understand their duties
- Provide relevant project information
- Allow enough time and money for safe work
- Create suitable management systems
- Maintain or oversee the golden thread
- Work with other dutyholders
The client may delegate tasks. However, delegation does not remove the client’s legal duties.
Once the building is occupied, the client may also need to work with the accountable person. This person manages ongoing building safety.
The principal designer
The principal designer leads and coordinates the design work.
The principal designer should:
- Plan, manage and monitor design work
- Take reasonable steps to support compliance
- Coordinate designers and specialists
- Share information with the client and principal contractor
- Consider how design choices affect safety
- Help create and maintain the golden thread
- Check that designers have the right competence
The principal designer must have real control over design decisions. Appointing an organisation with little involvement in design may create a gap between responsibility and control.
The principal contractor
The principal contractor manages the construction work.
The principal contractor should:
- Plan, manage and monitor construction
- Coordinate contractors and specialist trades
- Check that work follows building regulations
- Provide suitable supervision and instructions
- Control construction changes
- Record completed work
- Share information with the principal designer
- Keep accurate construction records
The principal contractor should create clear systems for:
- Checking workmanship
- Recording inspections
- Reporting problems
- Escalating safety concerns
These systems are vital when several subcontractors work on connected building elements.
Designers, contractors and specialist trades
Every designer and contractor contributes to building safety. The principal designer and principal contractor do not carry all the responsibility.
Specialist workers should:
- Work within their competence
- Follow the approved design
- Follow project procedures
- Report non-compliant work
- Provide accurate product information
- Record inspections and tests
- Record corrective work
- Work with other project participants
- Report changes that may affect compliance
These duties apply to electricians, HVAC technicians, gas engineers, fire protection specialists, structural engineers, surveyors and other skilled trades.
Technical skills must be supported by good communication and accurate records.
What is the golden thread of information?
The golden thread is a set of accurate, trusted and accessible records. It helps people understand a building and manage its safety.
It should show:
- The original design
- The building’s structure and systems
- The products and materials used
- The safety risks identified
- How the team managed those risks
- What changed during design or construction
- Who approved key decisions
- How teams tested and commissioned systems
- What future teams need for maintenance and alterations
The golden thread is not one document. It connects the information needed throughout the building’s life.
Dutyholders must store the required information. They must also share it with the right people and keep records of competence and compliance.
Project teams should review Building Safety Regulator guidance when setting up their information systems.
What should digital compliance records include?
A good digital record system helps authorised users find the latest approved information.
| Record type | Examples |
|---|---|
| Design information | Drawings, specifications, calculations and design reviews |
| Fire safety information | Fire strategy, escape routes and fire-stopping records |
| Structural information | Calculations, surveys, inspections and material records |
| Product information | Product data, certificates and installation instructions |
| Construction records | Inspections, photographs, permits and quality records |
| Change control | Change requests, reviews, approvals and reasons |
| Testing and commissioning | Test results, certificates and corrective actions |
| Competence records | CVs, qualifications, training and experience |
| Handover information | As-built drawings, manuals and maintenance information |
Teams should avoid duplicate or conflicting files. A controlled system should show the latest approved version.
It should also keep older versions and show who changed each file.
Record decisions, not just documents
A project file should explain why the team made a safety decision.
For example, if the team changes a fire-stopping detail, the record should show:
- What changed
- Why the change was needed
- Who reviewed it
- Which risks the team considered
- Whether other systems were affected
- Who approved the change
- How the completed work was checked
This helps teams prove compliance with certain safety-related matters. It also provides useful evidence during an investigation or regulatory review.
Make information accessible
Clients, dutyholders, building control professionals, facilities teams and accountable persons must be able to access the information they need.
Teams should control access to protect data. However, too many restrictions can make safety management harder.
Protect information integrity
Digital records need protection from loss and unauthorised changes.
Useful controls include:
- User permissions
- Version control
- Approval workflows
- Backups
- Audit trails
- Clear file names
- Retention periods
- Regular data checks
Update records throughout the project
Teams should record information as work progresses. This includes decisions, inspections, product installations and approved changes.
They should not try to create the golden thread at handover. Late record collection can leave gaps and make information hard to trust.
Managing change during construction
Construction projects often change. Materials may become unavailable. Site conditions may differ from surveys. Design clashes may appear. A specialist contractor may suggest another solution.
A change does not always create a safety risk. However, teams must assess every important change.
They should consider whether the change affects:
- Fire resistance
- Structural stability
- Compartmentation
- Fire alarms
- Smoke control
- Evacuation
- Building services
- Maintenance access
- The approved design
- Information needed for Gateway 3
A good change control process should include:
- A written change request
- A technical review
- An approval decision
- Updates to drawings and records
The process should show who reviewed the change and who gave final approval.
For higher-risk building work, the change control plan shows how the project will remain compliant after Gateway 2. Informal instructions and unrecorded substitutions can cause serious problems at completion.
If a change may create a safety concern, the team should check whether it requires a mandatory occurrence notice or another report.
Teams should also record any relevant transfer, revocation etc or approval arrangements.
Competence and recruitment under the new regime
The Building Safety Act has increased the importance of competence across the construction supply chain.
Clients must take reasonable steps to appoint people with the right skills, knowledge, experience and behaviours. Organisations must also show that they have the capability to complete the work.
Read the government guidance on competence and building work.
Employers should assess more than qualifications
A strong candidate may have:
- Relevant qualifications
- Experience with similar buildings or systems
- Knowledge of building regulations
- Quality assurance experience
- Experience with digital records
- The ability to report safety concerns
- Good communication skills
- Evidence of ongoing training
A qualification alone does not prove that someone can perform a specific role. Employers should assess practical competence and project experience.
Competence records should match the project
Employers should assess each person against the actual project.
For example, experience with low-rise commercial buildings may not prepare someone for a complex higher-risk residential project.
Employers should keep records of:
- Previous project experience
- Job responsibilities
- Relevant training
- Professional memberships
- Technical assessments
- References
- Supervision arrangements
- Skills gaps and development plans
Evidence may include a CIOB certificate or another recognised qualification. However, certificates should support a wider assessment. They should not replace it.
Recruitment partners can support compliance
Specialist recruitment agencies can help companies find people with the right technical and regulatory experience.
At YourConstruction Recruitment, we support employers across construction, civil engineering, surveying, site management and skilled trades.
Our approach combines sector knowledge with technology-supported candidate matching. This helps clients find people who suit both the role and the project.
A practical digital compliance workflow
Construction firms can improve compliance with a clear workflow. This can also support the tender management process.
Before work starts
- Check whether the project includes higher-risk building work
- Identify the client, principal designer and principal contractor
- Confirm all appointments in writing
- Assess competence and organisational capability
- Agree the information management system
- Set file naming and approval rules
- Prepare construction and change control plans
- Identify the information needed for Gateway 2
- Confirm social value and supply chain requirements
- Check that suppliers are reliable and qualified
During design
- Record design reviews
- Link safety decisions to drawings
- Coordinate fire, structural and building services information
- Record design changes and approvals
- Check that designers share relevant information
- Confirm that the design follows the approved application
- Review the design against current building regulations
During construction
- Record inspections and tests
- Take dated photographs
- Check products before installation
- Record defects and corrective work
- Control substitutions and design changes
- Keep as-built information up to date
- Share construction information with the principal designer
- Record incidents, near misses and actions
Before completion
- Complete all inspections and tests
- Confirm that approved changes are recorded
- Assemble as-built drawings and specifications
- Check fire and structural information
- Collect commissioning records and certificates
- Prepare the Gateway 3 submission
- Confirm that the information supports safe occupation
- Review any assessment certificates 81 and related evidence
Common mistakes to avoid
Treating the golden thread as a handover folder
A folder created at the end of construction may contain useful documents. However, it may not show the full history of decisions and changes.
Relying on informal communication
Verbal instructions, messaging apps and undocumented conversations can leave gaps.
Teams should record important decisions in the approved project system.
Failing to control subcontractor information
Subcontractors often hold important information about fire-stopping, mechanical systems, electrical work and structural connections.
The principal contractor should collect, check and add this information to the main project record.
Using unclear responsibility matrices
Each project should show:Task owner: The person responsible for completing each task.
- Information reviewer: The person who checks the information for accuracy and completeness.
- Final approver: The person who gives the final sign-off before the work proceeds.
Clear responsibilities prevent duplicated work and missed tasks.
Appointing people without checking project competence
Someone may have extensive experience but still lack the competence needed for a specific building, system or legal role.
Employers should assess each person against the project requirements.
Ignoring regulatory updates
Teams should monitor relevant review 6, guidance updates and changes to approved processes.
References such as part 3 and ECA 1972 may also appear in specialist legal or technical work. Teams should check each reference against the rules that apply to the project.
Building a stronger compliance culture
The Building Safety Act is more than another building control rule. It changes how construction teams should work.
A strong approach depends on:
- Clear accountability
- Competent people
- Early risk management
- Good design coordination
- Controlled changes
- Accurate digital records
- Open communication
- Regular reviews
- Learning from incidents
This approach can improve more than compliance. Better information can:
- Reduce rework
- Support smoother handovers
- Improve maintenance
- Help teams make faster decisions
- Support better procurement
- Improve communication with clients and regulators
It can also help companies show their commitment to social value.
Final thoughts
The gateways and golden thread connect design, construction and long-term building safety.
They require teams to show that they considered, managed and recorded safety at each key stage.
The best approach makes compliance part of normal project management. Teams should:
- Appoint the right people early
- Set clear responsibilities
- Record information as work progresses
- Assess and record important changes
Construction companies that invest in skilled teams, reliable suppliers and good digital systems will be better prepared for regulatory checks.
They will also be better placed to deliver safe and efficient projects.