RTM Companies and the Building Safety Act: Your Compliance Obligations

TL;DR: Your RTM company has the same legal obligations under the Building Safety Act 2022 as any professional managing agent. If your building is higher-risk (7+ storeys or 18m+), you must register with the BSR, maintain a safety case report, prepare PEEPs, report safety occurrences, and keep a digital golden thread. This guide covers each obligation and what to do first.

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#Your RTM Company Has the Same Obligations as a Managing Agent

There are 12,303 active RTM companies registered on Companies House. Every one that manages a higher-risk building carries the same legal obligations under the Building Safety Act 2022 as a professional managing agent with a team of compliance specialists.

The Accountable Person for a higher-risk building must take all reasonable steps to prevent the occurrence of a major incident. This duty applies regardless of whether the building is managed by a professional agent, a local authority, or an RTM company.

— Building Safety Act 2022, s.72

The difference is that your directors are volunteers. You took on Right to Manage for control over your building and transparency over service charges — not because you wanted to navigate a regulatory regime designed for professional building managers. But the BSA does not distinguish between volunteers and professionals. Your obligations are identical.

This guide breaks down each obligation so you know exactly what your RTM company must do, and in what order.

#Does the BSA Apply to Your RTM Company?

The Building Safety Act's Part 4 obligations apply to higher-risk buildings. Your building qualifies if it meets both criteria:

• Height: 7+ storeys or 18 metres or more
• Residential: Contains 2 or more residential units

If your building meets these thresholds, every obligation below applies. There is no exemption for volunteer-led management.

If your building is below these thresholds, the full BSA regime does not apply — but the Regulatory Reform (Fire Safety) Order 2005 still requires you to manage fire risk in common areas. Many RTM companies voluntarily adopt BSA-standard practices even for non-qualifying buildings, which strengthens your position if the criteria change.

#Registration with the Building Safety Regulator

Every higher-risk building must be registered with the BSR (BSA 2022, s.89). The original registration deadline was 1 October 2023. If your building is not yet registered, act immediately — failure to register is a criminal offence.

Registration requires you to identify the Principal Accountable Person (PAP). For most RTM-managed buildings, the RTM company itself is the PAP because it holds management responsibility for the building's common parts (BSA 2022, s.74).

What you need to register:

• Building address and height details
• Number of residential units and storeys
• Name of the Principal Accountable Person (your RTM company)
• Company registration number
• Contact details for a named individual

Registration is a one-time obligation, but you must notify the BSR of any changes to the building or accountable person within 28 days.

If multiple parties share accountability — for example, the freeholder retains responsibility for the structure while your RTM manages the common parts — each Accountable Person must be registered.

#The Safety Case Report

The safety case report is your primary compliance document (BSA 2022, s.77). It must demonstrate that you are actively managing building safety risks. The BSR can request it at any time, and you must produce it.

Your safety case report should include:

• Building description — structure, height, construction materials, fire safety systems
• Risk assessment — identified hazards and how you manage each one
• Management systems — who does what, how often, with what evidence
• Resident engagement — how you involve residents in safety decisions
• Ongoing maintenance — schedules, records, contractor assignments

This is not a document you write once and file away. It is a living record that must be reviewed at least annually and updated whenever material changes occur — new fire risk assessment findings, building works, changes to fire safety systems, or new hazards identified.

For an RTM company with volunteer directors, the challenge is maintaining institutional knowledge when directors change. A building where one director held all the safety information in their head fails the safety case test the moment they sell their flat.

Read the complete Safety Case Report guide →

#PEEPs — Personal Emergency Evacuation Plans

PEEPs are individualised evacuation plans for residents who may need assistance to evacuate safely — those with mobility impairments, visual or hearing difficulties, cognitive disabilities, or temporary injuries (BSR PEEPs guidance).

Your RTM company must:

1. Identify residents who need a PEEP — through a building-wide survey, ideally during your resident engagement process
2. Prepare individual plans — tailored to each resident's needs and the building's layout
3. Share plans with the fire and rescue service — so they have current evacuation information
4. Review and update — when residents' needs change, when residents move in or out, and at least annually

The challenge for RTM companies is capacity. Preparing individualised plans requires someone to survey residents, assess needs, and coordinate with the fire service. If your directors are already stretched, consider appointing a contractor with fire safety expertise to lead the PEEP process — but remember, the RTM company retains accountability.

Read our PEEPs implementation guide →

#Mandatory Occurrence Reporting

When a safety occurrence happens in your building, you must report it to the BSR (BSA 2022, s.78). This covers structural failures and fire safety incidents that could cause a significant risk to life.

What counts as a reportable occurrence:

• A structural failure or defect that presents a risk of collapse
• A fire spread that was not contained by compartmentation
• A fire safety system failure (detection, alarm, suppression, or ventilation)
• A fire door failure that compromised a means of escape

Reporting timeline: Reports must be submitted as soon as it is safe to do so and within 10 working days of the occurrence being identified.

What to include: A description of what happened, when, where in the building, what caused it (if known), what immediate action was taken, and what remedial action is planned.

For RTM directors, the key risk is not recognising when something is reportable. A fire alarm fault that lasts an afternoon might not feel like a major incident — but if it affected the means of escape for a mobility-impaired resident, it could be reportable. When in doubt, report. The BSR does not penalise over-reporting.

#The Golden Thread of Building Information

The golden thread requires you to create and maintain accurate, up-to-date digital records of your building's safety information throughout its lifecycle (BSR golden thread guidance).

The golden thread is not a single document — it is the entire chain of building safety information, from design through construction to occupation, maintained in a digital format that is accurate, up to date, and accessible.

What this means in practice for an RTM company:

• Fire risk assessments and all resulting actions — tracked to completion with evidence
• Contractor records — who did what work, when, with what qualifications
• Inspection logs — fire doors, emergency lighting, alarm tests, lift servicing
• Building plans — as-built drawings, fire strategy documents
• Resident information — PEEPs, contact details, engagement records
• Correspondence with the BSR — registration, notifications, any enforcement actions

Spreadsheets and email chains do not meet the golden thread standard. The information must be structured, searchable, and produce an audit trail showing who changed what and when. This is where most RTM companies find their current systems fall short — a shared Google Drive with inconsistently named files is not a golden thread.

Read the complete Golden Thread guide →

#Practical Next Steps for RTM Directors

If you are an RTM director of a higher-risk building, here is what to do — in order of priority:

1. Confirm your building's status — use the building checker to verify height and residential unit criteria
2. Check your BSR registration — search the BSR public register for your building. If it is not registered, start the process immediately
3. Identify your Accountable Person — confirm whether the RTM company is the PAP, or whether accountability is shared with the freeholder
4. Audit your current records — can you produce a safety case report if the BSR requests one? If not, start building one
5. Survey residents for PEEPs — identify anyone who needs an individual evacuation plan and start the process
6. Set up a reporting protocol — ensure all directors know what constitutes a reportable safety occurrence and how to submit a report
7. Move to digital records — if your building safety information lives in email threads, filing cabinets, or spreadsheets, start migrating to a structured, auditable system
8. Schedule a board item — building safety compliance should be a standing agenda item at every RTM board meeting

#Questions

#Does the Building Safety Act apply to RTM companies?

Yes. If your building is 7+ storeys or 18m+ with 2+ residential units, the BSA applies regardless of management structure. Your RTM company has the same obligations as any other Accountable Person. The Act does not distinguish between professional managing agents and volunteer-led RTM companies — the duties under Part 4 apply equally.

#Who is the Accountable Person in an RTM company?

The RTM company itself is typically the Accountable Person, as the entity holding management responsibility for the common parts (BSA 2022, s.72). Individual directors share operational responsibility for ensuring the company meets its obligations. If the freeholder retains responsibility for the building's structure, they may be a separate Accountable Person — in which case, both must be registered with the BSR.

#What happens if our RTM company doesn't comply with the BSA?

The Building Safety Regulator can issue compliance notices, impose financial penalties, and prosecute (BSA 2022, s.73). Directors of non-compliant RTM companies may face personal liability. Penalties include unlimited fines and, for the most serious offences, up to two years' imprisonment. The BSR has stated it will take enforcement action where Accountable Persons fail to meet their duties.

#Can we hire a managing agent to handle BSA compliance?

You can appoint agents to carry out specific tasks — preparing PEEPs, conducting fire risk assessments, managing contractors — but the RTM company retains legal responsibility as the Accountable Person. You cannot delegate accountability. If a managing agent fails to complete work you delegated, the BSR will hold your RTM company responsible, not the agent. Make sure any appointments include clear service level agreements and reporting requirements.

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

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