The BSR Has Refused 31 of 37 Decided RTM Building Assessment Certificate Applications. The Refusal Reasons Are Not Recorded.

TL;DR: Of the 1,012 Building Assessment Certificate applications the BSR has decided to date, RTM-led applications account for 6 approvals and 31 refusals. RMC-led applications: 18 approvals and 78 refusals. The BSR confirmed in writing on 19 May 2026 that it does not record refusal reasons or managing-agent identity. The cohort is small and self-selected, so the rates do not generalise to the 11,717 buildings still in the queue. But they do show what the bar looks like when the call comes.

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#The cross-tab in plain English

On 19 May 2026 the Building Safety Regulator released its response to FOI request FOIBSR-123 — a follow-up to FOIBSR-088 from 23 April 2026. The new release contains the table the April response did not: Principal Accountable Person type against Building Assessment Certificate application status, on the full 13,699-building register.

Two columns matter for this piece. Approved and Refused. Together they capture the 1,012 applications the BSR has made a binary call on so far.

"I can confirm the Building Safety Regulator holds the following information... Please refer to the attachment." — BSR FOI response FOIBSR-123, 19 May 2026

The full per-PAP-type rates, ordered by approval rate among the decided applications:

The "of decided" qualifier matters. Of the 13,699-building register, only 1,012 have received an approve-or-refuse decision. The other 12,687 are spread across "Not yet directed to apply" (11,717), "In progress" (714), "On hold" (86), "Pre-validation" (71), "Directed to apply" (68), "Cancelled" (28), and "BAC started but not submitted" (3).

For an RTM director sitting in the not-yet-directed cohort — and 530 of the 607 RTM-led HRBs are sitting there — the cross-tab does not predict the outcome of a future application. It does show what the bar reads like in the cases the regulator has already adjudicated.

#What the regulator does not capture

The FOIBSR-123 cover letter answered two further questions plainly.

"No information held." — BSR FOI response FOIBSR-123, on whether managing-agent identity is captured at Part 4 registration

"We DO NOT track Refusal reasons." — BSR FOI response FOIBSR-123, on reasons cited across the 658 refused applications

Two answers, two specific questions. Both confirm structural gaps rather than refusing to disclose data the regulator holds.

The first gap means BSR cannot tell whether a given building is run day-to-day by the PAP or by a professional managing agent acting on the PAP's behalf. The Part 4 registration form captures the PAP type only. So when the RMC cohort shows a 19 percent approval rate of decided applications, the data cannot say whether the 78 refused RMCs were self-prepared submissions or MA-prepared submissions on behalf of the RMC. The data cannot disambiguate.

The second gap means there is no structured aggregation of "the top reasons BSR refused a BAC". A director whose application has been refused will receive correspondence from their inspector setting out the specific grounds for that building. There is no portfolio-scale dataset behind it. An applicant cannot benchmark their refusal against others'.

Both gaps are structural to the Part 4 registration form and to BSR's case-by-case decision process as it stands in May 2026. Both could be filled in a future iteration of the form or in a future BSR data publication. Today they are not.

Read how to prepare for a BSR call-in →

#What this tells RTM and RMC directors

For the 530 RTM-led and 1,801 RMC-led HRBs sitting in the not-yet-directed cohort, three things follow from the data.

One. The cohort that has been adjudicated so far is small. Read the per-PAP figures as a directional signal, not a probability estimate. The next 1,000 decisions could move the rates in either direction. RTMs going through the application now are not statistically guaranteed to be refused; they are entering the process at a moment when the regulator is identifying substantive issues in most of the submissions it reviews.

Two. The four articles of the Fire Safety Order that appear most often on Fire and Rescue Authority enforcement notices — Article 8 (general fire precautions), Article 14 (emergency routes and exits), Article 9 (risk assessment), Article 17 (maintenance) — are the same areas a Building Assessment Certificate submission needs to evidence. The connection between FRA enforcement patterns and BAC quality bars is direct. The longer-form analysis of the 1,347 NFCC enforcement notices on multi-storey residential blocks sits at /blog/four-duties-fire-safety-enforcement-residential-blocks.

Three. A refused BAC is not a building-shutdown event. Of the 1,347 NFCC notices on Purpose Built Flats four storeys or higher, 87 percent are enforcement notices (fix-it within a defined period) and 9 percent are prohibition notices (restricted use). A BSR refusal directs the applicant back to the materials that did not satisfy the inspector, with the option to resubmit. The path back exists. The regulator works it case by case with the applicant rather than publishing portfolio-scale guidance on refusal grounds.

For a director starting prep now, the practical sequence is short. Read the Building Assessment Certificate guide. Read the Building Safety Case guide for RTM companies. Walk the escape routes with the FRA in hand. Date and photograph the fire-door maintenance log. Build the Safety Case Report on the four articles above. None of that is novel advice. The data simply confirms it is where the regulator is reading.

#What the data does not tell us

The cross-tab is a snapshot of decisions taken since Building Assessment Certificate applications opened, through to the FOIBSR-123 release date of 19 May 2026.

It does not record the lead time from application to decision. It does not record whether refusals concentrated in particular Local Authority areas. It does not record whether the same building has applied twice. It does not say how many of the 31 RTM refusals are buildings where the application was prepared by an external consultant versus by the directors themselves. It does not say whether the 78 RMC refusals concentrate in older buildings, larger buildings, or specific construction types.

Some of those answers may surface in future FOI releases. Some are answerable only by linking the BSR register to other public datasets (Companies House, the NFCC enforcement register, EPC data) that the regulator does not hold. A piece consolidating that broader picture is queued for June 2026.

What is certain from FOIBSR-123 is the shape of the bar. Sixty-five percent of decided applications across all PAP types have been refused. The rate is higher for resident-led PAPs. The reasons are not aggregated. The managing-agent picture is not captured. Reading the cover letter alongside the cross-tab is most of what an informed director can do this week.

Read the May companion analysis of fire-safety enforcement →

#Questions

#What is the BSR refusal rate for Building Assessment Certificate applications?

Of the 1,012 Building Assessment Certificate applications BSR has decided to date, 658 were refused and 354 were approved. The 65 percent headline rate is across all PAP types. Resident-led PAPs sit higher: 31 of 37 decided RTM applications and 78 of 96 decided RMC applications were refused. Source: BSR FOI response FOIBSR-123, 19 May 2026.

#Does the BSR record reasons for Building Assessment Certificate refusals?

No. In its FOIBSR-123 response of 19 May 2026, the Building Safety Regulator confirmed in writing that it does not track refusal reasons as structured data. 658 applications have been refused, and the grounds for each are held case by case rather than as a dataset the regulator could disclose.

#Does the BSR record which buildings are managed by an external managing agent?

No. The same FOI response confirmed BSR does not hold managing-agent identity for any registered HRB. The Part 4 registration form captures the Principal Accountable Person type but not whether the building is self-managed, managed by an external managing agent, or a mixed arrangement.

#How many RTM and RMC higher-risk buildings are on the BSR register?

On the 13,699-building Part 4 register, 607 are registered with a Right To Manage company as Principal Accountable Person and 2,025 with a Resident Management Company. Combined, that is 2,632 buildings or 19.2 percent of the register. Brocade's analysis of the "Other" free-text PAP bucket suggests the true leaseholder-led share is closer to 22 percent.

#How should an RTM or RMC director read these numbers?

The refusal rate is on the cohort that has received a decision so far — 1,012 of 13,699. Most resident-led buildings (530 of 607 RTM and 1,801 of 2,025 RMC) have not yet been directed to apply. The cross-tab shows the bar in the cases the regulator has already adjudicated; it does not predict outcomes for the buildings still in the queue. Reading the FOI cover letter alongside the cross-tab is the cleanest way to calibrate.

#Further Reading

• Three Regulators, Four Duties: 9,565 Fire-Safety Notices and 658 BAC Refusals — the May predecessor piece using FOIBSR-088 and the NFCC register
• BSR Assessment Process: How to Prepare Your Building — what a call-in looks like in practice
• How to Write a Building Safety Case for RTM Companies — the document the BAC submission depends on
• Building Assessment Certificate Guide — the form-and-evidence walkthrough
• Primary source: Building Safety Act 2022 on legislation.gov.uk
• BSR register and FOI page: Building Safety Regulator on gov.uk

This piece draws on the BSR's FOI response FOIBSR-123 of 19 May 2026 and the National Fire Chiefs Council Public Register of Enforcement Notices (snapshot 25 April 2026). The raw source documents and cross-tab are available on request.

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