Managing building safety responsibilities in complex estates is one of the most demanding challenges facing UK facilities managers today. Whether you’re overseeing a mixed use development, a multi tenancy commercial portfolio, or a higher risk residential block, the regulatory landscape has fundamentally changed and the stakes have never been higher.
This guide breaks down exactly who is accountable, what is legally required, and how modern FM teams can stay ahead of their obligations across multi structure or multi occupancy estates.
Take control of your compliance obligations. Whether you manage one site or twenty, building safety responsibilities in complex estates demand a structured, proactive approach. Explore how facilities professionals are transforming their compliance strategies.
What Makes an Estate “Complex” From a Safety Perspective
Not all properties carry the same compliance burden. A complex estate typically involves:
- Multiple buildings under one ownership or management structure
- Mixed use environments combining residential, commercial, or industrial occupancy
- Higher risk buildings (HRBs) defined under the Building Safety Act 2022 as residential blocks over 18 metres or 7 storeys
- Shared infrastructure, including fire systems, plant rooms, escape routes, and utilities
- Multiple contractors, leaseholders, and duty holders operating across the same footprint
The more stakeholders and structures involved, the more layered the accountability becomes. This is precisely where building safety responsibilities in complex estates become difficult to manage without a clear framework.
The Building Safety Act 2022: What Changed and Why It Matters
The Building Safety Act 2022 represents the most significant legislative shift in UK property management in decades. It introduced a new safety case regime, formal duty holder roles, and a Building Safety Regulator (BSR) with real enforcement powers.
For facilities managers operating across complex estates, the Act creates three key duty holder roles:
Accountable Person (AP) The AP is the legal entity typically a landlord, freeholder, or management company responsible for the safety of a higher risk building. On complex estates with shared structures or communal areas, there may be multiple APs, each with distinct obligations.
Principal Accountable Person (PAP). Where there is more than one AP, a Principal Accountable Person must be designated. The PAP takes overall responsibility for the safety case report, resident engagement strategy, and mandatory registration with the BSR.
Resident Engagement The Act mandates a documented approach to resident communication. On complex estates, this is often underestimated particularly when estates include both private and social tenants, or commercial and residential occupiers within the same development.
Facilities managers are rarely the Accountable Person themselves, but they are almost always the operational layer responsible for delivering compliance on behalf of whoever holds that duty.
Fire Safety Obligations Across Multi Structure Sites
Under the Fire Safety Act 2021 and Fire Safety (England) Regulations 2022, the Responsible Person must assess and mitigate fire risk across all common areas. On complex estates, this creates several practical challenges:
Overlapping fire compartments Where buildings share structural elements or are connected via walkways, atria, or basement car parks, fire compartmentation must be assessed holistically, not building by building.
Multiple Responsible Persons If different parts of the estate are under different management, there is a legal requirement for Responsible Persons to cooperate and share relevant information. This duty is often poorly documented in practice.
Evacuation strategy alignment Complex estates may require different evacuation strategies for different buildings. A stay put policy in one block and simultaneous evacuation in another, without a clear communication protocol, creates a serious risk.
Facilities managers should ensure each fire risk assessment (FRA) explicitly addresses the interfaces between buildings and identifies any shared or interdependent systems.
Statutory Compliance Across Shared Infrastructure
Beyond fire, complex estates carry a wide range of statutory compliance obligations that span multiple buildings and shared systems:
Legionella and Water Hygiene L8 compliance under the Health and Safety at Work Act requires a written scheme for controlling legionella risk. On complex estates with shared plant rooms, cooling towers, or communal hot water systems, a single poorly managed asset can affect the entire estate.
Electrical Testing Fixed wire testing (EICR) must be conducted on a building by building basis, but results should be reviewed at estate level to identify systemic issues with shared supply infrastructure.
Lift Safety LOLER inspections apply to all lifting equipment. On larger estates, managing inspection schedules and documentation across multiple lifts particularly where buildings share lift shafts or service cores requires a centralised tracking system.
Asbestos Management. Where estates include older buildings, asbestos surveys must be maintained and shared with any contractor working on the site. On mixed age estates, this is a particular risk area.
Gas and Mechanical Plant CP12 certificates, pressure vessel inspections, and plant room maintenance records must be current for every asset, across every structure.
The fundamental challenge is that compliance documentation is often held at the building level, when estate level visibility is what’s actually needed to identify gaps and manage risk.
Is your estate’s compliance data centralised and audit ready? Many FM teams are still managing building safety responsibilities in complex estates using disconnected spreadsheets and paper trails. Find out what a modern compliance framework looks like.
Contractor Management and the Golden Thread
One of the most significant and most overlooked aspects of complex estate safety is contractor management. On any given day, a large estate may have dozens of contractors working across its footprint: lift engineers, fire system contractors, cleaning teams, M&E engineers, and groundworks crews.
The Building Safety Act introduced the concept of the golden thread a digital record of information about a building’s design, construction, and ongoing management. For facilities managers on complex estates, this has practical implications:
- All contractor activity that affects the building fabric must be documented
- Contractors must be assessed for competence before being permitted to work on higher risk buildings
- Any changes to building systems must be recorded and reflected in the safety case
This is not a one time exercise. It requires an ongoing process of documentation, verification, and review embedded into everyday FM operations, not treated as an audit exercise.
From a contractor compliance perspective, facilities managers should ensure:
- Proof of relevant competency qualifications (e.g. Gas Safe, NICEIC, BAFE) is held on file for every contractor
- Method statements and risk assessments are reviewed and approved before work begins
- Post works sign off documentation is stored against the relevant asset record
- Contractor activity is logged and attributable, particularly for any work affecting fire compartmentation, structural elements, or life safety systems.
ESG Reporting and Building Safety: The Emerging Connection
Building safety is increasingly being recognised as an ESG governance issue, not just a compliance matter. Investors, lenders, and corporate occupiers are scrutinising how estate operators manage safety obligations as part of broader ESG due diligence.
For facilities managers, this creates a dual imperative: demonstrate compliance to regulators, and provide auditable data to reporting stakeholders.
Key areas where building safety and ESG intersect in complex estates include:
- Social value: Resident and occupier safety outcomes as an indicator of social performance
- Governance: Clear accountability structures, documented duty holder roles, and audit trails as evidence of sound governance
- Operational risk: The financial and reputational impact of safety failures as a material ESG risk
Facilities professionals who treat safety compliance as a data management function rather than a box ticking exercise are far better positioned to meet both the regulatory and reporting demands of complex estate management.
Common Failures in Complex Estate Safety Management
Understanding where things go wrong is as important as knowing what good looks like. The most common building safety failures in complex estates include:
Fragmented documentation Safety records held at individual building level, with no consolidated estate wide view. Gaps become invisible until an audit or incident exposes them.
Unclear accountability between APs On multi structure estates, the boundaries of responsibility between different duty holders are often poorly defined and rarely tested until something goes wrong.
Reactive contractor oversight Contractors being permitted on site without adequate pre qualification, or with expired certifications that haven’t been flagged.
Inadequate resident communication A legally required element of the Building Safety Act that is frequently reduced to a one page letter rather than a genuine engagement programme.
Interface failures Fire, M&E, and structural interfaces between buildings on the same estate are being assessed in isolation rather than as a connected system.
Building a Compliance Framework That Works at Scale
For complex estates, a piecemeal approach to building safety responsibilities in complex estates will always leave gaps. A scalable compliance framework requires:
Centralised asset register Every asset, across every building, is held in a single system with inspection schedules, certification expiry dates, and responsible party clearly recorded.
Digital maintenance logs All planned and reactive maintenance documented in real time, with contractor sign offs captured at the point of completion.
Competency matrix for contractors A live record of approved contractors, their qualifications, and expiry dates, integrated with procurement and access management.
Safety case management For HRBs, a structured approach to maintaining and updating the safety case report, including change management protocols.
Escalation protocols Clear internal processes for flagging compliance risks before they become regulatory failures.
Ready to strengthen your approach to building safety? Facilities managers across the UK are rethinking how they manage building safety responsibilities in complex estates. Start with the right framework and stay ahead of the next regulatory shift.
Frequently Asked Questions
Who is the Accountable Person under the Building Safety Act 2022?
The Accountable Person is the legal entity typically a freeholder, landlord, or management company that owns or has a repairing obligation for the common parts of a higher risk building. On complex estates, there may be more than one AP, each responsible for specific structures or shared areas.
What is a higher risk building?
Under the Building Safety Act, a higher risk building is defined as a residential building in England that is at least 18 metres tall or has at least 7 storeys, and contains at least 2 residential units. Different criteria may apply during the design and construction phase.
Do building safety obligations apply to commercial only buildings?
The specific higher risk building regime under the Building Safety Act primarily covers residential buildings. However, fire safety legislation, statutory maintenance obligations, and health and safety law apply to all occupied buildings, including commercial premises.
What is the golden thread, and who is responsible for maintaining it?
The golden thread is a digital record of key information about a building its design, construction, and ongoing management that must be kept up to date throughout the building’s life. The duty to maintain it sits with the Accountable Person, but in practice,e it is often the facilities management team that creates and updates the underlying records. You can explore more about building safety responsibilities in complex estates and how FM teams are adapting to this duty.
How should fire risk assessments work across a connected estate?
Each building requires its own fire risk assessment, but on complex estates, FRAs must also address the interfaces between buildings shared escape routes, connected fire alarm systems, and common structural elements. The Responsible Persons for each building have a legal duty tcooperatete.
What happens if a facilities manager fails to meet building safety obligations?
Enforcement action under the Building Safety Act can result in compliance notices, prohibition orders, and unlimited fines. Criminal liability can attach to individuals as well as organisations where there is evidence of negligence or wilful non compliance.
How often should a safety case report be reviewed?
Safety case reports must be updated whenever there is a significant change to the building and reviewed on a regular basis. The Building Safety Regulator may request the safety case at any time and can require revisions if it is found to be inadequate.
What qualifications should contractors hold to work on higher risk buildings?
Contractor competency requirements depend on the type of work being carried out. For life safety systems, relevant third party accreditations (such as BAFE for fire, NICEIC or NAPIT for electrical, and Gas Safe for gas) are expected as a minimum. The Act requires that principal contractors and principal designers demonstrate competence for building control applications on HRBs.
How do building safety responsibilities connect to ESG reporting?
Safety governance is increasingly treated as a material ESG factor, particularly under the Social and Governance pillars. Investors and lenders are asking for evidence of duty holder compliance, safety incident data, and audit outcomes as part of ESG due diligence. Facilities managers managing building safety responsibilities in complex estates are, therefore,e also contributing directly to corporate ESG disclosures.
Where should facilities managers start if they are not sure whether their estate meets current requirements?
The best starting point is a compliance gap analysis a structured review of every statutory obligation applicable to the estate, mapped against current documentation and maintenance records. This identifies where the highest risks sit and allows resources to be prioritised accordingly.
