Gateway 2: What the Building Safety Regulator Actually Checks

The Building Safety Act 2022 introduced a mandatory approval process for all Higher-Risk Buildings (18m+ or 7+ storeys): the Gateway 2 application. Before any construction work begins, the Building Safety Regulator (BSR) must approve the design and confirm the dutyholder arrangements are in place.

BSR can take up to 12 weeks to review a submission (and request further information, starting the clock again). A rejected or queried submission can delay your programme by months.

So what does BSR actually look for? Based on BSA 2022, the Building Safety Regulations 2023, and BSR published guidance, here is a practical breakdown of the six areas they assess — and where most submissions fall short.

1. Dutyholder appointments and competence evidence

The first thing BSR checks is whether the correct dutyholder structure is in place: Client, Principal Designer (PD), and Principal Contractor (PC). This is not the same as CDM 2015 dutyholders — BSA 2022 created separate, building-safety-specific roles with different competence requirements.

BSR requires evidence that:

• The Client has acknowledged their BSA 2022 duties in writing
• The Principal Designer holds appropriate professional competence (typically RIBA or similar, with specific fire and structural safety expertise)
• The Principal Contractor has BSA-specific management systems in place — not just CDM arrangements
• Each organisation has a nominated individual responsible for BSA compliance

2. The design documents — fire and structural safety

The technical core of the submission. BSR reviews the design against Approved Document B (fire safety), Approved Document A (structure), and the building-specific fire strategy.

Key documents typically required:

• Fire strategy report — prepared by a chartered fire engineer; must address compartmentation, means of escape, evacuation strategy (usually simultaneous for residential HRBs), firefighter access, and sprinkler system design
• Structural drawings — sufficient to demonstrate Approved Document A compliance; robustness checks, disproportionate collapse prevention
• Compartmentation strategy drawing — showing 60-minute fire resistance to structure; clearly showing fire doors, service penetrations, and vertical compartmentation between storeys
• Façade fire performance data — if the building has a ventilated cladding system or insulated external wall, test data and desktop studies required under BR 135 / BBA certificates

3. Change control arrangements

One of the most misunderstood Gateway 2 requirements. BSA 2022 Section 36 requires that before work starts, a change control process is agreed and documented — covering how design changes will be assessed, approved, and notified to BSR.

Not all changes require BSR notification — only Major Changes (defined in regulation) trigger a formal notification. But the submission needs to demonstrate that a system is in place to identify whether a proposed change is major or not.

BSR looks for:

• A written change control procedure (typically within the PD's design management plan)
• Criteria for classifying changes as major vs. non-major
• Sign-off levels (who can approve a non-major change; who escalates to BSR)
• Record-keeping arrangements — how changes will be logged in the Golden Thread

4. Golden Thread — initial digital record structure

The Golden Thread of information is a continuous digital record of the building from design through construction and into occupation. Gateway 2 does not require a completed Golden Thread — but BSR expects to see that the structure and format have been planned and that the PC has committed to maintaining it during construction.

BSR typically wants to see:

• A document register or information management plan identifying who creates and maintains each record
• The digital platform or system to be used (a SharePoint folder is not sufficient — a structured BIM or document control system is expected)
• How as-built information will be captured as construction progresses (not retrospectively)
• The handover plan — how Gateway 3 information will be compiled and transferred to the Accountable Person

5. Mandatory occurrence reporting arrangements

Under Regulation 37 of the Building (Higher-Risk Buildings Procedures) (England) Regulations 2023, the PC must notify BSR of certain events during construction: structural failure or damage, fire spread beyond the compartment of origin, failure of a safety-critical system, and near misses that could indicate a systemic issue.

BSR expects the submission to include a brief explanation of how these obligations will be managed: who is the nominated person to identify and report occurrences, what the decision tree looks like, and how it will be communicated to the site team.

6. Signed declarations from all dutyholders

Finally, BSR requires signed declarations from the Client, Principal Designer, and Principal Contractor confirming they accept their BSA 2022 duties. These must be on the correct BSR form (not a generic declaration) and must be signed by a person with actual authority within the organisation.

Common issue: declarations signed by a project manager rather than a director or authorised signatory. BSR returns these and asks for re-execution.

What happens if BSR rejects or queries your submission?

BSR issues a Further Information (FI) notice setting out what is missing or inadequate. You then have a specified period to respond. The 12-week clock restarts from when BSR receives a complete response.

On complex buildings, it is not unusual for a submission to go through two or three rounds of FI notices. Each round can add 8–12 weeks to your pre-construction programme.

A pre-submission review identifies these gaps before the submission goes in — allowing the team to address them without programme impact.