The Building Safety Act 2022 and Facades: A Practical Guide
The Building Safety Act 2022 is the biggest change to UK building regulation since Grenfell. For anyone specifying, procuring or installing facades on residential buildings over 18m (or seven storeys), it has changed the process end-to-end: who's responsible, what evidence has to be produced, and when work can start.
This guide covers what a higher-risk building is, the three gateways the Building Safety Regulator now controls, the golden-thread documentation regime, dutyholder responsibilities, and what all of this means for a facade installation package on site.
Higher-Risk Buildings (HRBs)
The Act defines a higher-risk building as one that is at least 18m tall or has at least seven storeys AND contains at least two residential units. Care homes and hospitals meeting the height threshold are also HRBs. Most of what follows applies to HRBs; some elements apply more widely.
The Three Gateways
Gateway 1 — Planning
Fire safety must be considered at planning stage. The planning application for an HRB includes a Fire Statement setting out how fire safety influences the site layout, access for firefighters, water supplies and building form.
Gateway 2 — Pre-construction
Before construction can begin, the Building Safety Regulator (BSR) must approve the design. Approval takes 12 weeks (typical) and requires full design information — including the external wall build-up, fire-strategy sign-off, and evidence that dutyholders are appointed and competent. No construction on the HRB starts without Gateway 2 approval.
Gateway 3 — Completion
Before occupation, the BSR must issue a completion certificate. This requires the as-built information to match the Gateway 2 approval, the golden-thread record to be complete, and the principal contractor and principal designer to have discharged their duties.
The Golden Thread
The golden thread is the digital record of building safety information kept for the whole life of the building. For a facade package this means:
- —Design drawings and specifications (as issued and as-built)
- —Fire classification certificates for every layer of the wall build-up
- —Batch numbers and traceability for insulation, panels, cavity barriers
- —Installation photographs — especially cavity barriers before they're covered
- —CWCT and other performance test results
- —Inspection and sign-off records
The golden thread is not a nice-to-have. Without it, Gateway 3 completion cannot be granted, and any future change to the building (or investigation after an incident) becomes impossibly hard.
Dutyholder Roles
| Role | Facade responsibility |
|---|---|
| Client | Appoints competent designers and contractors; ensures the golden thread is maintained. |
| Principal Designer | Coordinates the design (including the facade fire strategy) to be Building Regulations-compliant. |
| Principal Contractor | Manages construction to the approved design; captures the as-built record. |
| Facade sub-contractor / installer | Installs to the approved design; provides installation records and photographs into the golden thread. |
What This Means on Site
- —Every material batch has to be tracked and matched to the specification
- —Cavity barriers, fire-stopping and interfaces are photographed and signed off before being covered
- —Any design change on site goes through a formal change-control route — no undocumented substitutions
- —Installation crews need Building Safety Act-competent supervision (SMSTS + specific facade experience)
Frequently Asked Questions
Does the Building Safety Act only apply to new buildings?
No. The construction gateways apply to new HRBs, but the Act's in-occupation regime — including the requirement for an Accountable Person and Safety Case for existing HRBs — applies to every existing HRB in England.
How long does Gateway 2 actually take?
The statutory period is 12 weeks. Real-world timelines have run longer where design information has been incomplete or unclear. Front-loading the facade specification and fire strategy is the single biggest thing a design team can do to keep Gateway 2 on schedule.
Can existing buildings be re-clad without going through the gateways?
Re-cladding of an existing occupied HRB is generally treated as building work and requires BSR involvement. The Act's remediation acceleration provisions also apply to unsafe cladding on existing HRBs, with legal duties on freeholders to remediate.