The Building Control Do’s and Don’ts for High Rise Buildings
The Building Safety Act 2022 introduced mandatory Gateway hold points, new dutyholder obligations, and a documentation standard that many development teams are still catching up with. For higher-risk buildings, the margin for late decisions and undocumented changes is very small. The cost of getting it wrong is not just regulatory; it is commercial.
What follows is a practical guide drawn from our experience working with developers on higher-risk building projects across England and Wales. It covers the decisions that determine whether a project progresses efficiently or stalls, and the mistakes that come up consistently enough to be predictable.
The Do’s
DO #1 Appoint your Building Regulation Consultant (BRC) before design is established
A Gateway 2 application requires complete, coordinated design information. That coordination cannot be achieved by assembling documents in the weeks before submission. It has to run through the design process itself.
Appointing your Building Regulation Consultant at RIBA Stage 1 or 2 allows fire strategy, structural approach, external wall specification, and compliance documentation to be shaped as the design develops. Projects where the BRC is involved from concept stage produce more coherent Gateway 2 submissions and fewer post-approval change requests. Bringing the BRC in after planning is finalised, consistently costs more than the early appointment would have.
DO #2 Integrate fire safety at concept stage
Fire safety cannot be added to a completed design. For buildings above 18 metres, it has to inform structural strategy, compartmentation, external wall specification, means of escape, and evacuation approach from the outset. A fire strategy document produced after the design has been settled is not a strategy. It is a justification exercise, and it frequently requires the design to be revisited.
The 2026 Approved Document B consultation signals further evolution of requirements for external walls, balconies, and evacuation lifts. Developers who have fire safety expertise embedded in the design team from the start are better placed to absorb those changes without costly redesign. Salus provides in-house fire safety consultancy alongside building control, so both requirements are coordinated from day one.
DO #3 Treat the Golden Thread as a live project control, not a handover task
The Golden Thread is not assembled at the end of a project. It is built throughout it. Version-controlled design records, change management logs, material specification decisions with their compliance evidence, and construction-stage inspection records all need to be captured in real time, not reconstructed from whatever happens to have been saved.
Developers who treat documentation as an administrative function consistently find themselves unable to produce the evidence Gateway 3 requires. The practical approach is to specify Golden Thread obligations as a contractual requirement for all consultants and contractors from appointment. For more on what the BSR expects at each stage, see our article on why good documentation matters for building control sign-off.
DO #4 Treat Gateway 2 as the product of your design process, not a submission event
Gateway 2 is a full building control application to the Building Safety Regulator, submitted before construction begins. The BSR has an eight-week target determination period, but incomplete or inconsistent submissions routinely extend that timeline significantly.
Gateway 2 is not an event. It is the outcome of a design process that has been run with compliance in mind from the start.
Project teams that begin assembling documentation in the weeks before submission rarely produce the coordinated information the BSR expects. The fire and emergency file, the design information, and the compliance evidence need to have been building throughout the project.
DO #5 Know where your dutyholder obligations begin and end
If you are developing to sell, the point at which ownership transfers and obligations shift to the incoming owner needs to be clearly defined in your legal and commercial agreements. Between Gateway 2 approval and Gateway 3 sign-off, the obligations sit with the dutyholder, regardless of the commercial structure around the transaction.
Where you retain ownership, the Principal Accountable Person obligations include registering the building with the BSR, maintaining the building safety case, engaging with residents on safety matters, and holding a current Building Assessment Certificate. These cannot be delegated by appointing a managing agent.
DO #6 Lock down external wall compliance before design is frozen
External wall systems on buildings above 18 metres must use non-combustible materials throughout, covering cladding, insulation, fixings, and all components, in line with Approved Document B or the British Standard Fire Codes (BS9991:2024 – Fire Safety In The Design, Management and Use of Residential Buildings – Code of Practice). The evidence trail must be complete and well-structured at Gateway 2, including product certification, test data, and a clear demonstration of how the system as a whole meets the standard.
Broadly compliant is not an acceptable position. The commercial consequences of non-compliant external wall systems cover BSR enforcement, mortgage lender risk, insurance implications, and remediation liability.
Establishing a clear compliance strategy before the design is frozen, with documented product selection rationale, is significantly more efficient than resolving it at or after Gateway 2.
The Don’ts
DON’T #1 Treat Gateway commitments as permissions rather than baselines
Commitments made at Gateway 2, covering design intent, fire strategy, structural approach, and materials specification, must be honoured through to Gateway 3. They are not permissions to proceed. They are the baseline against which the completed building will be assessed.
Design evolution during construction is not expected. Post-Gateway 2 amendments must be formally processed through a change control process with the duty holders before submission to the BSR. Undocumented changes constitute a compliance failure, this is one of the most consistent failure points seen on complex projects, and it is avoidable with a robust change control protocol in place from the start.
DON’T #2 Appoint an BRC on cost without verifying HRB competence
Level 3 competence is required for higher-risk building work, and not all BRC’s are Registered Building Inspectors who have relevant experience for Gateway 2 submissions. An under-specialised appointment creates coordination gaps, delays submissions, and generates compliance issues that cost considerably more to resolve than any fee saving justifies.
When appointing a BRC for a HRB project, the questions that matter are: what is their specific track record with Gateway 2 submissions? What Level 3 Registered Building Inspectors do they employ? Do they carry in-house fire safety expertise, or will coordination gaps emerge between building regulations and fire strategy? Salus has operated as a Registered Building Control Approver for over 20 years, with Level 2 and Level 3 inspectors and in-house fire safety consultants. Our Building Regulation Consultancy service provides early-stage advisory support for developers at the project planning stage.
DON’T #3 Defer evacuation strategy beyond RIBA Stage 1
Evacuation strategy determines staircase sizing, core layout, alarm specification, and lift provision. It cannot be resolved at detailed design stage without cost implications, and it must be fully evidenced at Gateway 2. Developers who treat it as a fire strategy document entry rather than a design decision consistently find it creating structural and programme problems that are expensive to unpick.
The 2026 Approved Document B or British Standard Fire Codes (BS9991:2024 – Fire Safety In The Design, Management and Use of Residential Buildings – Code of Practice) consultation reinforces the direction of travel and evacuation lift provision for buildings above 18 metres. If this decision is not in the Stage 1 brief, there is a real risk that the design cannot accommodate it at the point it becomes a requirement.
DON’T #4 Start construction before Gateway 2 approval is in place
Commencing construction on a higher-risk building before Gateway 2 approval has been granted is an offence under the Building Safety Act 2022. The BSR has enforcement powers that extend to stop orders and prosecution.
Working with a Specialist Partner
The decisions that determine whether a higher-risk building project runs smoothly are almost all made in the first two RIBA stages. Compliance cannot be retrofitted at Gateway 2 any more than fire safety can be added to a finished design.
At Salus, our Level 2 and Level 3 Registered Building Inspectors, within our Building Regulation Consultancy, work alongside our in-house fire safety consultants, which means building regulations and fire safety are reviewed from concept stage through to Gateway 2 sign-off. If you are planning a higher-risk building project, or want a second view on a project already in progress then request a consultation.