Resident Engagement Evidence: What Shows the BSR Your Strategy Is Being Run

TL;DR: When the Building Safety Regulator assesses a higher-risk building for a Building Assessment Certificate, section 81(5) of the Building Safety Act 2022 lets it test whether the principal accountable person is acting in accordance with the residents' engagement strategy. That is a test of records. This guide is written for building safety consultants preparing a client for a call-in, and it sets out the resident engagement evidence that answers it: what was given to residents and when, what they were consulted on, which decisions their views changed, how complaints ended, and how resident duties were enforced.

Read the complete Golden Thread guide →

If you need the basics first, our explainer on the resident engagement strategy and the duties around it covers what the strategy must contain and who prepares it. Nothing below repeats it.

#What the BSR Can Test: Resident Engagement in Section 81(5)

The BSR must give a certificate only if it is satisfied that all relevant duties are being complied with, and section 81(5) defines which duties those are.

In this section “relevant duty” means a duty of an accountable person for the building under, or under prescribed regulations made under, any of the following: (a) section 83 (duty to assess building safety risks); (b) section 84 (management of building safety risks); (c) section 85 (duties relating to safety case report); (d) section 87(5) (duties relating to mandatory occurrence reporting system); (e) section 89 (provision of information to regulator, residents etc); (f) section 91 (duty to produce a residents' engagement strategy).

— Building Safety Act 2022, s.81(5)

Three of those six reach residents directly:

• Section 91 includes section 91(1)(d): the PAP must act in accordance with the strategy. A strategy that promises quarterly updates and a three-week consultation is a list of things the BSR can ask you to show happened.
• Section 89 covers the information an accountable person must give residents. The application carries a PAP statement confirming each AP has complied (SI 2023/907 reg 3(2)).
• Section 84 carries resident engagement in by regulation. Among the principles prescribed for managing building safety risks is to consider the impacts on residents and carry out engagement with residents (SI 2023/907 reg 4(1)(h)).

Section 93, the complaints procedure, is not on the list, and neither is section 95 or 96 on resident duties. Their records still belong in the pack, for reasons covered in Steps 5 and 6.

The BSR has not published an evidence checklist for this. Its application guidance asks for a copy of the strategy and says the BSR may ask for additional records, a meeting, or a demonstration of the systems you use to manage building safety risks. The BSR announced simplified assessment criteria on 9 July 2026; we had not found them published by 2 November 2026. So the pack below is built from the statute and regulations, which do not change when the criteria do.

Nor can anyone say how often engagement is why a building fails. In its FOIBSR-123 response of 19 May 2026, the BSR had refused 658 of the 1,012 applications it had decided, and said in the same response that it does not track refusal reasons (our FOI analysis).

#Before You Start

Ask your client for six things before you open a single folder:

1. The current residents' engagement strategy and the record of every review, with the decision on each review and its reasons
2. The issue log for information given to residents and owners, by item and by date
3. Every consultation run since the strategy was first prepared: notice, distribution list, opening and closing dates, responses
4. The section 93 complaints policy and the complaints log
5. Any contravention notices given under section 96, and what happened after each
6. The log of resident requests for further information under section 92

Most of this is already prescribed golden thread information under the Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2024 (SI 2024/41), Schedule 1. If a client cannot produce an item, that gap is your first finding.

#Step-by-Step: Building the Resident Engagement Evidence Pack

#Step 1: Turn the strategy's promises into a test list

Read the strategy as an auditor would: every will, must and timeframe is a test. Regulation 10(7) of SI 2023/907 also requires every strategy to contain five things, so they are tests in every building.

Then add the building's own promises. A strategy that commits to a quarterly safety bulletin and a five-day complaint acknowledgement has created eight bulletins and a measurable acknowledgement rate for every two years of operation.

"Done" looks like a two-column table: promise on the left, evidence reference on the right, no blank cells.

#Step 2: Evidence the information given to residents

Records of information given are dated issue logs, item by item. Schedule 2 to SI 2024/41 lists what an AP must provide, including a summary of the fire risk assessment, a summary of the safety case report, the residents' duties under section 95, and the current residents' engagement strategy. Regulation 8 of SI 2023/907 sets the triggers: when a new resident moves in, and when information already given goes out of date. It also requires the reporting route, the complaints route and the AP contact details to be displayed in the common parts.

Log the version, date, method and recipients for each item, then test two triggers:

• New arrivals. Pick three flats with a new occupier in the last year and find the pack each received.
• Out-of-date information. A fire risk assessment summary dated before the current assessment fails the regulation 8 trigger.

Section 91(4) separately requires each AP to give every resident aged 16 or over and every owner a copy of the strategy each time it is prepared or revised. A dated photograph of the lobby noticeboard covers the display duty and nothing more.

#Step 3: Evidence consultation

Consultation records prove three things the regulation tests. Regulation 10(8) of SI 2023/907 requires consultations to use appropriate methods, to take reasonable steps so anyone likely to be affected knows about them, and to run for a reasonable period, at least three weeks for the strategy itself.

A requirement that the PAP must give due consideration to the responses to any consultation.

— SI 2023/907, reg 10(7)(c)

For each consultation, keep the notice, the list of who received it and how, the opening and closing dates, and every response. Count responses against the number of flats. Section 91(3)(d) requires the strategy to say how the appropriateness of engagement methods will be measured, and a response rate is the simplest measure a regulator can read.

#Step 4: Show how residents' views changed decisions

The regulations assume this record exists. Schedule 3 to SI 2024/41 lets any resident request a summary of the representations made to the most recent strategy consultation, and any record of a decision, with reasons, about whether to revise the strategy. If a resident can ask for it, an assessor can too.

Keep one decision record per consultation, with four fields: the view received, the decision it concerned, what changed or the reason nothing changed, and the date residents were told. The BSR's strategy guidance is explicit that the PAP need not change the strategy if it does not think a change is appropriate. A recorded reason for not changing is evidence of due consideration. A consultation with responses on file and no decision record shows nothing either way.

A worked example (illustrative). A 14-storey block of 62 flats is replacing flat entrance fire doors on floors 3 to 14 over six weeks. Access to each flat is limited for most of a day, so regulation 10(7)(b) applies and residents are consulted on days, times and mitigation. 23 of 62 flats respond. Nine ask for no work before 9.30am because of night-shift workers on floors 6 and 7; four ask for Saturday slots. The decision record shows the contractor start moved to 9.30am on floors 6 and 7, Saturday slots refused because the contractor's fire-stopping supervisor works weekdays only, and a letter to all 62 flats on the outcome, dated before work started. That one page answers section 91(1)(d), regulation 10(7)(b) and (c), and section 84's engagement principle at once.

#Step 5: Evidence complaints handling and its outcomes

Complaint evidence is the log of outcomes, kept for seven years. Schedule 1, paragraph 14 of SI 2024/41 requires a summary of each relevant complaint to the PAP: what it said, the steps any AP took, any involvement of the regulator, and the outcome. Paragraph 30 adds a log of recurring complaints about the same issue or person.

Regulation 12 of SI 2023/907 sets the standard the log is read against: acknowledgement as soon as reasonably practicable, and substantive responses that address all material points, give reasons, and set out action taken and planned with a timeframe. The first substantive response must explain how to ask for reconsideration, and later ones how to refer the complaint to the BSR.

Section 93 sits outside the section 81(5) list, and the log still earns its place. If the strategy promises a complaints route with response times, the log shows the strategy being followed under section 91(1)(d). A recurring complaint about a broken self-closing device on floor 9 may point to a building safety risk you must manage under section 84, and the log should show it reaching the fire risk assessment action list. And because the BSR runs its own complaints system under section 94, an escalated complaint may already be on the regulator's file.

Breaches of section 93 are also enforceable by a compliance notice under section 99, and the application must list any compliance notice in force (SI 2023/907 reg 3(5)(e)).

Brocade's resident portal logs each issue a resident reports with a status timeline, and emails the resident when work starts and when the issue is resolved, closed or reopened. Residents can see the building's fire strategy and the safety documents the manager marks as visible, and Golden Thread documents are stored with version history and an audit trail. It does not run your section 93 procedure or your consultations for you. See how Brocade keeps resident-facing records →

#Step 6: Evidence resident duties and contravention notices

Resident duties evidence starts with proof residents were told about the duties. Section 95 puts duties on residents aged 16 or over and on owners: avoid acts that create a significant risk of a building safety risk materialising, leave relevant safety items in the common parts alone, and answer requests for information the AP reasonably needs for its section 83 or 84 duties. Schedule 2 to SI 2024/41 requires the AP to tell them so.

Where an AP has given a contravention notice under section 96, regulation 13 of SI 2023/907 prescribes its content, including any previous communication about the alleged breach, any relevant BSR guidance, and details of the section 93 complaints procedure the recipient can use to dispute it. The owner of the flat gets a copy (SI 2023/907 reg 8(8)(b)). Each notice is kept for five years (SI 2024/41 Sch 1 para 31).

For the pack: list each notice with the safety item involved, the steps required, the outcome, and whether the recipient complained. Regulation 13(1)(b) expects a notice to cite the earlier contact, so a communal fire door wedged open, with two dated letters on file before the notice is the pattern the regulation assumes. A notice with no prior contact, or one missing the complaints route, is a defect you want to find before the assessor does.

#Step 7: Tie the engagement evidence to the safety case

Engagement evidence and the safety case share facts, and an assessor will read them side by side. The BSR's safety case guidance asks for the resident profile, and says it should be the same as in the residents' engagement strategy. It also asks how the emergency plan has been communicated to residents and how their needs were taken into account.

Check three joins:

• Resident profile. The number of residents who need help to evacuate should match across the strategy, the safety case report and the PEEPs records.
• Summaries. The safety case report summary issued to residents under Schedule 2 should match the current report. A summary written at registration and never reissued fails this check.
• Triggers. Regulation 10(1)(b) of SI 2023/907 requires a strategy review within a reasonable period after a mandatory occurrence report. Every report in the MOR log should have a dated strategy review after it.

Residents can request the full report and the documents it relies on under Schedule 3 to SI 2024/41. For how the safety case itself is built, see what a real safety case actually takes and the safety case report guide.

#Common Mistakes to Avoid

1. Submitting the strategy as the evidence. Section 80(1)(d) requires a copy with the application. That copy proves the strategy exists. Section 91(1)(d) is answered by Steps 2 to 6.

2. A complaints log with no outcomes. A log of dates and subjects meets neither Schedule 1, paragraph 14 nor regulation 12(20). Each row needs the outcome and the action taken.

3. No record of triage. Regulation 12(10) puts a relevant complaint through the system whether or not the resident calls it one, and regulation 12(13) requires reasons when you decide something is not a relevant complaint. Log each triage decision.

4. Engagement that reaches leaseholders only. Section 91(7) covers residents aged 16 or over as well as owners, so a list of leaseholders' email addresses misses tenants. Managing agents also have the RICS Service Charge Residential Management Code 4th edition, which lists the current strategy as a leaseholder disclosure item (our section 9 analysis).

#Checklist

• Strategy promises and regulation 10(7) items mapped to records, no blank cells
• Review log covering every two-year cycle and every MOR and significant-alteration trigger
• Schedule 2 issue log, tested on sample flats; common-parts display photographed and dated
• Section 91(4) copy of the strategy given to each resident aged 16+ and each owner after each revision
• Consultation records: notice, distribution, dates (three weeks minimum for the strategy), responses, response rate
• One decision record per consultation: view, decision, change or reason, date residents were told
• Complaints policy covering regulation 12(2), plus a 7-year log with outcomes and a recurring-complaints log
• Contravention notices with prior contact, regulation 13 contents and outcomes, kept 5 years
• Section 92 request log, with reasons recorded wherever information was not provided
• Resident profile, safety case summary and MOR-triggered reviews consistent with the safety case report

#Questions

#Does the BSR check resident engagement at a building assessment?

Yes. Section 81(5) of the Building Safety Act 2022 lists the duties the BSR assesses. They include section 91, which requires the principal accountable person to act in accordance with the residents' engagement strategy, and section 89 on giving information to residents. Section 84 adds resident engagement as a prescribed risk-management principle.

#Is the section 93 complaints procedure one of the duties assessed for a building assessment certificate?

No. Section 81(5) does not list section 93. Complaint records still matter: they are golden thread information under SI 2024/41, they show whether the strategy's complaints commitments are kept, and a breach of section 93 can lead to a compliance notice that must be declared on the application.

#What counts as evidence that residents' views changed a decision?

A dated record that links a consultation response to the decision it concerned, says what changed or why nothing changed, and shows residents were told the outcome. Residents can request the summary of representations to the latest strategy consultation and the reasons for any revision decision under Schedule 3 to SI 2024/41, so the record has to exist.

#How long must complaint records be kept for a higher-risk building?

Seven years. Schedule 1 to SI 2024/41 requires a summary of each relevant complaint, the steps taken, any involvement of the regulator and the outcome, plus a log of recurring complaints. Contravention notices given under section 96 are kept for five years.

#Has the BSR published a checklist of resident engagement evidence?

Not that we have found as of 2 November 2026. The BSR's application guidance asks for a copy of the strategy and says it may request additional records, a meeting or a demonstration of systems. The simplified assessment criteria announced on 9 July 2026 had not been published by that date.

#Further Reading

• Resident Engagement Strategy for Higher-Risk Buildings: the strategy and its duties
• The BSR Assessment Process: the call-in and the 28-day window
• BSR BAC refusal rates by PAP type: the FOIBSR-123 data
• What a Real Safety Case Actually Takes
• The Golden Thread Guide
• Safety Case Report guide

This article is for informational purposes. For building-specific advice, consult a qualified building safety professional.

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