The Building Safety Act 2022 is the most significant piece of building safety legislation the UK has seen in a generation. It was a direct response to the Grenfell Tower fire in 2017, which killed 72 people and exposed serious failures in how buildings were built, managed, and regulated.
The Act is no longer new. In 2026, enforcement has matured. The Building Safety Regulator is active. Duty holders are being held to account. And facilities managers who have not yet fully understood their obligations under this law are carrying real risk.
This guide explains what the Building Safety Act means for facilities managers in plain terms: what changed, who is responsible, what you must do, and what happens if you do not.
Codedevza AI builds FM compliance platforms that include golden thread documentation, duty holder records, and building safety evidence in one place.
What the Building Safety Act Changed
Before the Act, building safety regulation in the UK was fragmented. Different bodies oversaw different aspects of building safety. Accountability was unclear. The Grenfell Inquiry found that this fragmentation was a direct contributor to the conditions that made the fire so catastrophic.
The Building Safety Act 2022 changed this in three main ways.
- It created the Building Safety Regulator (BSR) , a new body with the power to enforce building safety law, prosecute non compliance, and maintain a register of higher risk buildings.
- It introduced a clear duty holder framework specific roles with specific legal responsibilities for building safety throughout a building’s life.
- It established the golden thread as a requirement to maintain and share structured digital records of building safety information throughout a building’s lifecycle.
The Act applies to all building work in England and Wales. Higher risk buildings over 18 metres or 7 storeys face additional and more demanding obligations. But the general principles of competence, accountability, and evidence apply across all building types.
Who Are the Duty Holders?
The Building Safety Act creates named roles with legal responsibilities. Understanding which role applies to your FM operation is the starting point for compliance.
The Accountable Person
The Accountable Person (AP) is the individual or organisation with legal control over the common parts of a higher risk building. This is typically the building owner, landlord, or management company. The AP must assess and manage building safety risks, engage with residents on safety matters, and demonstrate to the BSR that they are managing the building safely. Where more than one AP exists, a Principal Accountable Person (PAP) must be designated to take overall responsibility.
The Responsible Person
Under the Regulatory Reform (Fire Safety) Order 2005 which sits alongside the Building Safety Act the Responsible Person (RP) is accountable for fire safety. In managed buildings, this is often the facilities manager or the managing agent. The RP must ensure a current Fire Risk Assessment is in place, fire systems are maintained, escape routes are clear, and all required actions are carried out and documented. These two roles Accountable Person and Responsible Person may be held by the same organisation but carry distinct legal duties.
The Principal Contractor and Principal Designer
For any building work including refurbishment, fit out, and major maintenance the Act requires a Principal Contractor and Principal Designer to be appointed where more than one contractor is involved. They are responsible for planning, managing, and monitoring the work to ensure it complies with building regulations and the Act. Facilities managers who commission significant building works must ensure these appointments are made and documented correctly.
The Golden Thread: What It Is and What FM Teams Must Do
The golden thread is one of the most practical requirements of the Building Safety Act. It is a structured digital record of key building safety information that must be kept accurate, accessible, and up to date throughout the building’s life.
For higher risk buildings, the golden thread must include:
- The building’s current safety case an assessment of all significant safety risks and how they are being managed
- Structural and fire safety information about the building’s design and construction
- Records of all safety related incidents, near misses, and complaints
- Details of all duty holders, their responsibilities, and their competence
- Records of all maintenance, inspections, and remedial actions relating to safety critical systems
- Resident engagement records, including how safety information has been shared and how concerns have been addressed
A 2026 industry survey found that 37 per cent of FM teams have asset registers that are no more than 50 per cent accurate. Six per cent have no asset register at all. In the context of the Building Safety Act, an inaccurate or incomplete asset register is not just an operational problem, it is a compliance failure with legal consequences.
Codedevza AI helps FM teams build and maintain the structured digital records that the Building Safety Act requires from asset registers to safety case documentation.
Higher Risk Buildings: Additional Obligations
Buildings over 18 metres or 7 storeys with at least two residential units are classified as Higher Risk Buildings (HRBs) under the Act. These buildings face the most demanding obligations.
Registration with the Building Safety Regulator
All HRBs must be registered with the BSR. Registration requires the submission of key building information including address, height, number of storeys, number of residential units, and the identity of all Accountable Persons. Operating an HRB that is not registered is a criminal offence.
The Safety Case
Accountable persons for HRBs must prepare and maintain a safety case, a structured document that demonstrates how all significant building safety risks are being identified, assessed, and managed. The BSR can request the safety case at any time. Where the regulator is not satisfied with the safety case, it can issue compliance notices and ultimately pursue prosecution.
The Gateway Process
For new construction and major refurbishment of HRBs, the Act introduces a three gateway process. Buildings cannot progress from planning to construction to occupation without BSR approval at each stage. For facilities managers involved in major building projects, understanding which gateway applies and what evidence is required at each stage is now part of the role.
Resident Engagement
Accountable persons for HRBs have a legal duty to engage with residents on building safety matters. This includes providing information about the building’s safety case, creating a process for residents to raise safety concerns, and demonstrating that those concerns are taken seriously and acted upon. Records of all resident engagement must be maintained as part of the golden thread.
Competence Requirements
The Building Safety Act introduced competence requirements for anyone involved in building work or building safety management. This applies to designers, contractors, and building managers. The duty is not just to be competent it is to be able to demonstrate competence.
For facilities managers, this means being able to show that all contractors appointed to carry out work on managed buildings have the skills, knowledge, and experience appropriate to that work. Checking a contractor’s marketing materials is not sufficient. Verified accreditations, certifications, and relevant experience records are the expected standard.
From 2026, ICE members and other built environment professionals are required to complete CPD activity relating to safety and risk management. This reflects a broader expectation that competence in building safety is maintained as an ongoing professional obligation, not a one time achievement.
Codedevza AI’s FM compliance platforms include contractor verification, competence records, and audit trails that demonstrate due diligence under the Building Safety Act.
FAQ’s
Does the Building Safety Act apply to all buildings?
The Act applies to all building work in England and Wales. However, the most demanding obligations registration, safety case requirements, the gateway process, and resident engagement duties apply specifically to Higher Risk Buildings over 18 metres or 7 storeys with at least two residential units.
Who is the Accountable Person under the Building Safety Act?
The Accountable Person is the individual or organisation with legal control over the common parts of a higher risk building. This is typically the building owner, landlord, or management company. Where multiple Accountable Persons exist, a Principal Accountable Person must be designated to take overall responsibility.
What is the golden thread and who is responsible for it?
The golden thread is a structured digital record of all key building safety information for a higher risk building. It must be maintained by the Accountable Person and kept accurate, accessible, and up to date throughout the building’s lifecycle. It includes safety case documents, maintenance and inspection records, incident records, and resident engagement evidence.
What is the Building Safety Regulator?
The Building Safety Regulator (BSR) is a new body established under the Building Safety Act, operated by the Health and Safety Executive. It oversees building safety enforcement, maintains the national register of higher risk buildings, enforces the gateway process, and has the power to prosecute duty holders for non compliance.
What does the safety case requirement mean for FM teams?
Accountable persons for higher risk buildings must prepare and maintain a safety case document demonstrating that all significant building safety risks are being identified, assessed, and managed. The BSR can request the safety case at any time and can issue compliance notices or pursue prosecution where the safety case is inadequate.
What are the penalties for non compliance with the Building Safety Act?
Non compliance with the Building Safety Act can result in criminal prosecution of duty holders, unlimited fines, enforcement and compliance notices from the BSR, and prohibition of building occupation. Operating a higher risk building that is not registered with the BSR is itself a criminal offence.
What is the gateway process and when does it apply?
The gateway process is a three stage approval system for new construction and major refurbishment of higher risk buildings. Buildings must obtain BSR approval at planning, pre construction, and completion stages before progressing. Facilities managers involved in major building projects must ensure the correct gateway process is followed.
How does the Building Safety Act affect contractor management in FM?
The Act requires that anyone appointed to carry out building work or design work must have the competence appropriate to the task. Facilities managers must take reasonable steps to verify this competence before appointment. Checked and retained accreditation records are the expected standard of due diligence.
Does the Building Safety Act affect resident engagement?
Yes. Accountable persons for higher risk buildings have a legal duty to engage with residents on building safety matters, provide safety information, create a process for raising safety concerns, and demonstrate that concerns are acted upon. Records of all resident engagement must be maintained as part of the golden thread.
What should FM teams do now to ensure they are compliant with the Building Safety Act?
FM teams should confirm which buildings they manage qualify as higher risk and ensure they are registered with the BSR. They should review their duty holder structure, verify the accuracy of their asset registers, establish or update their golden thread documentation, and review their contractor competence verification processes.
