Resident Engagement Strategy for Higher-Risk Buildings: Your BSA Obligations Explained

TL;DR: The Building Safety Act 2022 requires every Principal Accountable Person to prepare a resident engagement strategy for their higher-risk building. This means formally setting out how you will inform residents about safety, consult them on decisions, and give them a way to raise concerns. It is a legal duty under section 91, and the Building Safety Regulator expects to see it in practice -- not just on paper.

Check if your building qualifies as higher-risk

#Why Resident Engagement Is a Legal Duty

Before the Building Safety Act, resident engagement in building safety was largely informal. Building managers might send occasional newsletters or hold an annual general meeting. Residents who raised concerns about fire doors, cladding, or escape routes often felt ignored.

The principal accountable person for an occupied higher-risk building must ... as soon as reasonably practicable after the relevant time prepare a strategy (a "residents' engagement strategy") for promoting the participation of relevant persons in the making of building safety decisions.

— Building Safety Act 2022, s.91(1)(a)

The Grenfell Tower tragedy and Dame Judith Hackitt's Independent Review changed this fundamentally. Hackitt found that residents' concerns had been systematically dismissed. Her review recommended that residents become active participants in building safety -- not passive recipients of management decisions.

The Building Safety Act 2022 turned that recommendation into statute. Section 91 places a specific duty on the Principal Accountable Person (PAP) to prepare a strategy for promoting resident participation in decisions about building safety risk management. This is not optional guidance. It is a legal requirement backed by enforcement powers.

#What the Law Requires

The resident engagement framework sits across several sections of the Building Safety Act. Together, they create a comprehensive set of obligations.

#Prepare an engagement strategy (s.91)

Under section 91, the PAP must prepare a strategy that:

1. Promotes the participation of residents in decisions about building safety risk management
2. Sets out how residents will be informed about safety measures and decisions
3. Describes how residents' views will be sought on safety-related matters
4. Provides a mechanism for residents to raise concerns about building safety

Section 91 also fixes the cadence, and the detail is in secondary legislation rather than the Act. Regulation 10 of the Higher-Risk Buildings (Management of Safety Risks etc) (England) Regulations 2023 (SI 2023/907) sets the prescribed review times under section 91(1)(b): at least every two years, and also within a reasonable period after a mandatory occurrence report is sent to the regulator and after significant material alterations to the building are completed. Each consultation on the strategy must run for no less than three weeks. The BSR's guidance adds that you must record each review whether or not you change anything.

One step is easy to miss. Under section 91(4), as soon as reasonably practicable after the strategy is prepared or revised, each Accountable Person must give a copy to every resident aged 16 or over in the part of the building they are responsible for, and to every owner of a residential unit in that part. Publishing it on a notice board is not the same as giving each person a copy.

#Share safety information with residents (s.89) and answer requests (s.92)

Section 89 is the power under which regulations require an Accountable Person to give information to the regulator, to residents and to other persons. SI 2023/907 is where the resident-facing list actually lives. Between them they cover:

• The building's safety measures and fire safety arrangements
• The evacuation strategy (whether simultaneous evacuation or stay-put)
• Who the Accountable Persons are and how to contact them
• What safety works are planned or in progress
• The status of any fire risk assessment actions

This information must be provided proactively, not only when residents ask for it. Section 92 then gives residents aged 16 or over, and owners of residential units, a separate statutory right to request further information about the building. Regulation 11 of SI 2023/907 sets the standard for your answer: in writing, and in a form that lets the recipient understand it, including plain English summaries of complex or technical provisions where that is reasonable. A PDF of a fire engineer's report with no summary attached does not meet that bar.

#Establish a complaints system (s.93)

Section 93 requires the PAP to establish and operate a complaints system specifically for building safety concerns. This is separate from general property management complaints. The system must be accessible, transparent, and lead to timely action.

If a resident is not satisfied with how their safety concern has been handled, they can escalate to the BSR directly. A well-functioning complaints system reduces the likelihood of this happening -- but the resident's right to escalate exists regardless.

One more source now points at the same document. The RICS Service Charge Residential Management Code, 4th edition, in force 7 April 2026, lists the most up-to-date version of the resident engagement strategy in its Appendix D as something the principal accountable person has to provide to leaseholders in a higher-risk building. The Code does not create that duty and does not change it; its own section 9.1 calls its Building Safety Act material a very brief overview and tells you to seek legal advice, so section 91 remains the source. Our companion piece on what the RICS Code 4th edition changes for building safety works through section 9 and Appendix D in full.

Read the PAP responsibilities guide

#Building Your Resident Engagement Strategy: A Practical Approach

The statute tells you what you must do. This section covers how to do it. A good engagement strategy is specific to your building, proportionate to the risks, and practical enough that your team can actually deliver it.

#Step 1: Identify your residents and their needs

Start by understanding who lives in your building:

• Owner-occupiers who may have detailed knowledge of the building's history and a financial stake in safety improvements
• Assured shorthold tenants who may not know who the Accountable Person is or how building safety decisions are made
• Vulnerable residents who may need accessible formats, translation, or additional support to participate
• Absent leaseholders (buy-to-let investors) who may sub-let but remain interested in building safety as it affects their asset

A 15-storey tower with 80% owner-occupiers will need a different engagement approach from one with 80% short-term renters. Document these demographics in your strategy.

#Step 2: Set up a Residents' Panel

Nothing in section 91 or SI 2023/907 requires a panel, and residents have no statutory right to demand one. What section 91(3)(c) does require is that your strategy sets out the arrangements for obtaining and taking account of residents' views. A standing panel is one of the more practical ways to deliver that on a building where the same 40 leaseholders will be consulted repeatedly.

How to set one up:

1. Invite participation -- write to all residents explaining the panel's purpose and inviting expressions of interest. Aim for representation across different floor levels, tenure types, and demographics
2. Define the scope -- the panel discusses building safety matters, not general property management. Make this clear from the start to avoid scope creep
3. Set a meeting frequency -- quarterly is a practical starting point. More frequent if there are active safety works; less frequent if the building has a stable risk profile
4. Record minutes -- every meeting should produce minutes recording what was discussed, what residents asked, and what actions were agreed. These minutes form part of your Golden Thread
5. Report back -- after each meeting, share a summary with all residents (not just panel members). This demonstrates that the panel's input is being heard and acted upon

#Step 3: Establish communication channels

Not every resident will join the panel. You need additional channels to reach all residents:

Brocade includes a resident portal that gives leaseholders direct access to building safety information -- fire risk assessment status, safety works progress, and a channel for raising concerns. This kind of transparency builds trust and reduces the volume of ad-hoc enquiries to your management team. Book a demo to see how it works.

#Step 4: Design your information-sharing process

Section 89 requires you to provide safety information proactively. Build this into your regular operations:

On an ongoing basis:

• Display the current evacuation strategy in common areas and provide a copy to every new resident
• Make Personal Emergency Evacuation Plans (PEEPs) available for residents who need them
• Publish the names and contact details of the Accountable Persons. Where the PAP is an organisation rather than an individual, SI 2023/315 reg. 15 requires the registration application to name the individual acting as the PAP's single point of contact, and reg. 4 gives the PAP 14 relevant days to tell the regulator when that changes. On who it can be, the BSR's accountable persons guidance is permissive: someone from the organisation can take the role, or a third party such as a management company with the PAP's written consent. That individual should have authority or duties relating to the safety of the building, and it does not make them the PAP. Naming them to residents as well costs nothing and saves a round of "who do I actually call"

After key events:

• Share fire risk assessment outcomes and planned remediation works within 28 days of completion
• Notify residents of any changes to the evacuation strategy
• Communicate the outcome of any mandatory occurrence reports that affect resident safety (while respecting any investigation confidentiality requirements)

Annually:

• Provide a building safety summary covering the year's assessments, maintenance, works completed, and planned activities for the coming year

#Step 5: Implement your complaints system

The section 93 complaints system needs specific elements:

1. A clear submission process -- residents must know how to raise a safety concern (email, online form, physical letterbox, or all three)
2. Acknowledgement timelines -- confirm receipt within a defined period (five working days is reasonable)
3. Investigation process -- describe how concerns are investigated and by whom
4. Response timelines -- commit to a substantive response within a defined period (28 days is common practice)
5. Escalation path -- explain that residents can refer unresolved concerns to the BSR
6. Record-keeping -- log every complaint, investigation, and outcome in your Golden Thread

#A scenario to make this concrete

Imagine you are the PAP for a 10-storey residential building with 45 flats. You have just completed a fire risk assessment that identified 12 actions, including replacement of three fire doors on the eighth floor and remedial fire stopping work in two service risers.

Without an engagement strategy: You commission the works, contractors come and go, and residents on the eighth floor wonder why their fire doors are being replaced. A resident on the ninth floor notices a hole in the corridor ceiling from the fire stopping work and files a complaint with the BSR, believing the building is unsafe.

With an engagement strategy: You email all residents summarising the fire risk assessment findings and the planned works. The Residents' Panel reviews the action plan at their quarterly meeting. You post updates in the resident portal showing progress on each action. The ninth-floor resident sees the ceiling work explained as "fire stopping remediation -- work in progress, completion expected 15 April" and understands it is a safety improvement, not a safety failure.

The difference is not just compliance. It is the difference between a building where residents trust the management and one where residents escalate to the regulator.

#What the BSR Expects to See

When the BSR assesses your building for a Building Assessment Certificate, your resident engagement strategy is one of the things they review. Based on the BSR's published approach, they are looking for:

Residents aged 16 or over, and owners of residential units, have a statutory right under section 92 of the Building Safety Act 2022 to ask an Accountable Person for prescribed information or documents. The Accountable Person must give it to them as soon as reasonably practicable, in writing, and in a form they can understand.

— Building Safety Act 2022, s.92(1)-(2) and SI 2023/907 reg. 11

• Evidence that a strategy exists -- a written document, not just an informal approach
• Evidence that it is being followed -- meeting minutes, communication records, complaint logs
• Evidence that residents can participate -- a Residents' Panel or equivalent, accessible communication channels, accessible complaint mechanisms
• Evidence that complaints are handled -- a log showing complaints received, investigated, and resolved
• Evidence that information is shared -- records of what was communicated to residents and when

A strategy that exists only as a document in a filing cabinet, with no evidence of implementation, will not satisfy the BSR. They want to see the strategy working in practice.

Not sure whether your building qualifies as higher-risk? Our guide to higher-risk building criteria under the Building Safety Act explains the height and residential unit thresholds that determine which buildings require a resident engagement strategy.

See how Brocade helps you track resident engagement

#Common Mistakes to Avoid

#1. Treating engagement as a one-off exercise

Writing a strategy document and filing it away is not compliance. Regulation 10 of SI 2023/907 requires a review at least every two years, plus one after any mandatory occurrence report and one after significant material alterations. Record each review even when you change nothing, because the record is the only evidence the review happened.

#2. Confusing general property management with building safety engagement

Your resident engagement strategy under section 91 is specifically about building safety. It is not your AGM agenda, your service charge consultation process, or your general complaints procedure (though it may overlap). Keep the building safety focus distinct.

#3. Limiting engagement to owner-occupiers

Section 91(7) defines "relevant persons" as residents of the building aged 16 or over and owners of residential units. That wording captures assured shorthold tenants and sub-tenants, not only leaseholders. Your engagement channels must reach everyone in that definition, not just those who attend AGMs or own the lease.

#4. Not recording engagement activities

If you held a Residents' Panel meeting but did not take minutes, you cannot evidence that engagement happened. If you sent an email update but did not save a copy, you cannot demonstrate compliance. Document everything. Your engagement records are part of the Golden Thread and your evidence for the due diligence defence.

#5. Ignoring the complaints system

Section 93 requires a separate complaints system for building safety. If you are routing all complaints through a general property management inbox with no specific tracking for safety concerns, you are likely non-compliant. Safety complaints need their own process, their own timeline, and their own records.

#Frequently Asked Questions

#What is a resident engagement strategy under the Building Safety Act?

A resident engagement strategy is a formal document that the Principal Accountable Person must prepare under section 91 of the Building Safety Act 2022. It sets out how residents of a higher-risk building will be informed about building safety, consulted on safety decisions, and given a mechanism to raise safety concerns.

#Do I need a Residents' Panel for my higher-risk building?

No. Neither section 91 of the Building Safety Act nor SI 2023/907 requires a panel, and there is no statutory right for residents to demand one. Section 91(3) requires the strategy to set out your arrangements for obtaining and taking account of residents' views. A panel is one common way to deliver that, but a consultation process with no panel can satisfy section 91.

#What building safety information must residents receive?

Section 89 of the Building Safety Act lets regulations require Accountable Persons to give information to the regulator, residents and others. SI 2023/907 sets out what residents get, including a fire risk assessment summary, a safety case report summary, evacuation information, and how to report a building safety risk. Section 92 gives residents aged 16 or over a separate right to request further information.

#What happens if I do not have a resident engagement strategy?

Failure to prepare a resident engagement strategy is a breach of section 91. The Building Safety Regulator can issue compliance notices requiring you to prepare one, and continued non-compliance can lead to enforcement action. Beyond the legal risk, poor engagement increases the likelihood of resident complaints escalating to the BSR.

#How often should a resident engagement strategy be reviewed?

At least every two years. Regulation 10 of SI 2023/907 sets the prescribed times under section 91(1)(b), and also requires a review within a reasonable period after a mandatory occurrence report is sent to the regulator and after significant material alterations to the building. Each review must be recorded whether or not the strategy changes.

#Further Reading

• Principal Accountable Person Responsibilities Guide -- who holds the PAP role and their full obligations
• Accountable Person Duties Under the Building Safety Act -- AP obligations including resident engagement
• The Complete Golden Thread Guide -- your engagement records are part of the Golden Thread
• PEEPs Guide: What Building Managers Need to Know -- Personal Emergency Evacuation Plans that residents should have access to
• What Is a Building Safety Case? -- how safety case information connects to resident communication
• Building Safety Act Complete Guide -- comprehensive overview of the full BSA regime
• Higher-Risk Buildings: Definition and Criteria -- which buildings require engagement strategies
• Golden Thread in Practice -- building the audit trail that includes engagement records
• Section 20 Consultation and the Building Safety Act -- financial consultation requirements that interact with engagement

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

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