Brocade
TL;DR: The Building Safety Regulator opened a 14-week consultation on Approved Document B (fire safety) on 25 March 2026. It closes 1 July 2026. The proposals affect new-build and refurbishment design, not your day-to-day duties as a building manager, but the direction of travel matters for any project you are planning beyond summer 2026.
Read the fire risk assessment tracking guide →
What the BSR is Actually Consulting On
On 25 March 2026 the Building Safety Regulator opened a consultation on proposed changes to Approved Document B, the statutory guidance that sits under the fire-safety requirements of the Building Regulations 2010. The consultation runs for 14 weeks and closes on 1 July 2026. Responses are submitted through the HSE Citizen Space portal or by email to [email protected].
The consultation is not a rewrite of fire-safety law. It is a review of the statutory guidance that designers, fire engineers, and Building Control use to show that a new or materially altered building meets the Building Regulations.
This is the first consultation under the government's December 2024 commitment to keep Approved Document B under continuous review, rather than the large, infrequent revisions that characterised the pre-Grenfell period. The background is the government's response to the Grenfell Tower Inquiry Phase 2 report in February 2025 and its annual progress report in February 2026.
The consultation covers a package of targeted technical and policy changes. The headline proposals:
- Two staircases and two evacuation lifts in all new residential buildings above 18 metres, with provisions allowing a firefighting lift to serve a dual function
- Revised guidance on external wall systems and balconies, including a review of the scope of the ban on combustible materials in and on external walls and specified attachments
- A new threshold for combustible structural elements beyond which Approved Document B guidance should not be relied on
- Consolidated guidance on building work on existing buildings, pulling together fragmented refurbishment advice
- Replacing the term "sheltered housing" with "specialised housing" and extending alarm coverage requirements for these premises
The proposed draft text of Approved Document B Volumes 1 and 2, incorporating 2025, 2026, and 2029 amendments, is published alongside the consultation on the HSE site.
Why This Matters to Building Managers
Approved Document B is primarily read by architects, fire engineers, and Building Control Bodies. If you manage an occupied building, the consultation does not change a single duty you owe today under the Regulatory Reform (Fire Safety) Order 2005, the Fire Safety Act 2021, or the Building Safety Act 2022.
That is worth stating plainly, because "new BSR consultation on fire safety" reads like something that should be on the manager's to-do list. It usually is not.
Where it does matter is in three specific situations.
If you have refurbishment or remediation work planned beyond summer 2026. The consolidated guidance on building work on existing buildings is the proposal most likely to touch an occupied portfolio. Cladding remediation, balcony replacement, and major internal reconfiguration all sit in this space. Designers will start aligning with the direction of travel before the guidance formally lands.
If you are involved in a new-build scheme. Two staircases and two evacuation lifts in residential buildings above 18 metres change the design brief, the floorplate, and the viability of smaller sites. Developers and their designers are already responding. If you are the future managing agent or accountable person, expect these conversations to land in your inbox during the design stage.
If your building is classed as sheltered housing. The proposed relabelling to "specialised housing" and the extended alarm coverage provisions will feed through into fire-risk-assessment scope and into the technical standards your contractors work to. A fire risk assessor updating guidance to reflect "specialised housing" is worth a calm conversation, not a surprise.
What Is Likely to Change and What Is Not
This consultation is open in substance, not a formality. That said, the shape of the change is visible.
Likely to land broadly as proposed: the two-staircase and two-evacuation-lift rule for new residential above 18 metres. This aligns with the mandatory second-staircase requirement coming into force separately in September 2026 and was trailed in the government response to the Grenfell Phase 2 report. The policy direction is set. The consultation is refining thresholds and technical detail, not asking whether the principle is right.
Likely to move but with contested detail: the external wall systems and balcony proposals, and the combustible structural elements threshold. These are the sections where industry, insurers, and fire-engineering bodies will have the sharpest technical views. Expect some movement between consultation and final text.
Not changing here: the Fire Safety Order, PEEPs duties under the Fire Safety (Residential Evacuation Plans) (England) Regulations 2025, the Accountable Person regime under Part 4 of the Building Safety Act, or the Golden Thread duties under the Building Safety Regulator's assessment regime. The consultation sits upstream of occupation. Your downstream duties are unchanged.
The Parallel Expert Panel Review
Alongside this consultation runs a wider review that matters for the longer horizon.
In July 2025, BSR appointed a six-person expert panel to conduct a fundamental review of Building Regulations guidance, including all Approved Documents and BS 9414, the British Standard that governs extending results from BS 8414 fire tests to assess external wall system performance. The panel is expected to deliver interim findings in spring 2026 and a final report in summer 2026.
The Grenfell Phase 2 report was explicit that BS 9414 "should be approached with caution" and should not substitute for assessment by a suitably qualified fire engineer. The expert panel review is where that recommendation is worked through. BSR's current view, signalled in the consultation materials, is to keep Approved Document B guidance generic rather than naming specific standards, so that ambiguity about how to interpret fire-test results narrows over time.
Practically: the current consultation is a 14-week technical exercise. The expert panel review is the slower, more structural piece. If you follow only one of the two, follow the expert panel. It will shape the next three to five years of guidance, not the next three months.
What to Do Before and During the Consultation Window
For most building managers, the honest answer is: watch, prepare, and keep the records you already owe.
If you are going to respond. Keep it short and operational. BSR is looking for evidence of practical impact, not position papers. A managing agent who can say "we manage six buildings at 18–30 metres, and proposal X would mean Y for residents during remediation" will be read more carefully than a generic submission. Responses close 1 July 2026.
If you are not going to respond. Do three things.
- Flag the consultation to any designer, fire engineer, or principal contractor working on your portfolio. They need to know, and many smaller practices will not have noticed.
- Make sure your fire risk assessment is current and that your FRA actions are tracked to completion with dated evidence. The consultation does not change FRA duties, but any regulator attention on fire safety raises the baseline for what "good records" looks like in an enforcement conversation.
- Treat your golden thread as the primary artefact. Whatever lands in the final guidance, the regulator's expectation that responsible persons and accountable persons can produce a coherent, current fire-safety record is only going to harden.
See the fire risk assessment tracking guide →
Brocade's View on Two of the Proposals
On two staircases and two evacuation lifts for new residential above 18 metres, the principle is right. Simultaneous evacuation is already the reality for most post-Grenfell design and many existing buildings through PEEPs regulations. A building that is designed for simultaneous evacuation without a second stair or a reliable evacuation lift places a disproportionate load on residents with mobility impairments and on the firefighters helping them. The principle should not be the battleground. The detail worth arguing is the threshold and the definition of an evacuation lift that can be relied on in a real incident, not in a commissioning test.
On consolidated guidance for work on existing buildings, the instinct is right but the execution is the thing. Refurbishment advice across the current Approved Documents is fragmented, and fragmentation is where mistakes live. A single, consolidated chapter that a managing agent can point a contractor to is a genuine safety improvement, not bureaucratic tidying. The risk is that "existing buildings" becomes a catch-all that blurs the difference between a cosmetic refurbishment and a material alteration that triggers Building Regulations. Precision here matters more than completeness.
The consultation's value to building managers is not in its technical detail. It is in the signal that Approved Document B is now a living document, reviewed continuously, rather than a static reference that moves once a decade.
Frequently Asked Questions
When does the BSR Approved Document B consultation close?
The consultation opened on 25 March 2026 and runs for 14 weeks. The closing date is 1 July 2026. Responses go to [email protected] or via the HSE Citizen Space portal.
Does the consultation change my current legal duties?
No. Approved Document B is statutory guidance for new design and building work under the Building Regulations. Until the consultation closes and any changes are made, your duties under the Fire Safety Order and the Building Safety Act are unchanged.
Does this affect existing buildings or only new ones?
Approved Document B primarily governs new construction and material alterations. Existing buildings remain regulated under the Fire Safety Order 2005, the Fire Safety Act 2021, and the Building Safety Act 2022. The consultation does include updated guidance for work on existing buildings, which may affect refurbishment and remediation projects.
What is the expert panel review and how does it connect?
BSR appointed a six-person expert panel in July 2025 to conduct a wider review of Building Regulations guidance, including Approved Documents and BS 9414. Interim findings are expected in spring 2026 and a final report in summer 2026. The current consultation runs in parallel with this longer review.
Should I submit a response as a building manager?
You can. BSR welcomes responses from responsible persons, managing agents, RTM directors, and accountable persons. Responses are most useful when they describe practical operational impact, not just technical preference. If you manage buildings affected by any of the specific proposals, a short plain-English response is worth more than silence.
What should I do while the consultation is open?
Keep your fire risk assessment, evidence records, and golden thread documentation current. If you have new-build or major refurbishment work planned after summer 2026, flag the consultation to your design team now so the design brief accounts for likely changes.
Further Reading
- Review of Approved Document B: Fire safety guidance: the consultation landing page on gov.uk
- HSE Citizen Space consultation portal: where to submit a response
- Building Safety Act 2026 Update: the wider regulatory picture this consultation sits within
- PEEPs Deadline April 2026: the residential evacuation regulations already in force
- Fire Risk Assessment Tracking Guide: how to keep FRA actions audit-ready
- Golden Thread in Practice: the record-keeping duty this consultation sits on top of
- Fire Safety Approved Document B: the current statutory guidance
This article is for informational purposes. For building-specific advice, consult a qualified fire safety professional.