Building Safety Act Compliance Checklist

#Introduction

The Building Safety Act 2022 (BSA) is the most significant reform to building safety regulation in a generation. Enacted following the Grenfell Tower tragedy, it creates a comprehensive framework for managing the safety of higher-risk residential buildings throughout their lifecycle.

Part 4 of the Act deals specifically with higher-risk buildings in occupation -- the day-to-day safety obligations that fall on building managers, freeholders, and management companies. This checklist covers those obligations.

For comprehensive context on the Building Safety Act -- what it covers, who it applies to, and why it matters -- read our Building Safety Act Complete Guide.

#Who this applies to

#Higher-risk building definition

The Building Safety Act's Part 4 regime applies to higher-risk buildings (HRBs) in England. Your building is a higher-risk building if it meets all of the following criteria:

For detailed criteria and edge cases (measuring height, counting storeys, mixed-use buildings), see the GOV.UK guidance on HRB criteria.

#Key roles and responsibilities

The BSA introduces specific legal roles for building safety. Understanding who fills each role in your building is the foundation of compliance.

#Principal Accountable Person (PAP)

The Principal Accountable Person is defined in section 73 of the BSA. The PAP is the person who holds the legal estate in the building's structure and exterior (the common parts that form the building's envelope).

In practice, the PAP is typically:

• The freeholder of the building
• A commonhold association (where the building is commonhold)
• An RTM company that has acquired the right to manage

The PAP has overall responsibility for building safety. Key duties include:

• Registering the building with the Building Safety Regulator (BSR)
• Applying for and holding the Building Assessment Certificate (BAC)
• Assessing and managing building safety risks
• Maintaining the Golden Thread of building information
• Preparing and keeping a Safety Case Report
• Establishing a residents' engagement strategy

#Accountable Person (AP)

An Accountable Person is defined in section 72 of the BSA. An AP is anyone who holds a legal estate or is under a repairing obligation for the common parts of the building.

There can be multiple APs in a single building. For example, if the freeholder owns the structure and a management company has a repairing obligation for the internal common areas, both are APs. The freeholder would typically also be the PAP.

Each AP must cooperate with the PAP and take reasonable steps to manage building safety risks in the parts they are responsible for.

#Building Safety Manager -- no longer statutory

#Building Safety Regulator (BSR)

The Building Safety Regulator is the body that oversees the new regime. As of 27 January 2026, the BSR operates as a standalone body under MHCLG (the Ministry of Housing, Communities and Local Government). Previously, the BSR sat within the Health and Safety Executive (HSE).

The BSR's role includes:

• Maintaining the register of higher-risk buildings
• Processing Building Assessment Certificate applications
• Receiving and acting on mandatory occurrence reports
• Issuing compliance notices and taking enforcement action
• Publishing guidance for accountable persons

#Registration and Building Assessment Certificates

#Registration

All higher-risk buildings in occupation in England were required to be registered with the BSR by 1 October 2023. If your building is not yet registered, this should be treated as an urgent priority.

Registration requires submitting Key Building Information (KBI) to the BSR, as defined in the Key Building Information Regulations 2023 (SI 2023/963). KBI includes basic information about the building's structure, height, materials, fire safety systems, and occupancy.

#Building Assessment Certificates (BAC)

A Building Assessment Certificate is the BSR's confirmation that your building meets the requirements of the new regime. The BSR is calling in buildings for BAC applications in priority order:

When the BSR calls your building in, the PAP has 28 days to submit the BAC application (per the Higher-Risk Buildings Procedures Regulations 2023 (SI 2023/909)).

#Golden Thread obligations

The Golden Thread is one of the most significant new requirements. Under section 88 of the BSA and the Higher-Risk Buildings (Keeping and Provision of Information) Regulations 2024 (SI 2024/41), the PAP must maintain a complete, digital, up-to-date record of building safety information.

#What the Golden Thread must include

• Structural and architectural information (original design, as-built records)
• Fire safety information (fire risk assessments, fire strategy, compartmentation details)
• Building services information (mechanical, electrical, lift systems)
• Maintenance records and inspection reports
• Safety Case Report
• Residents' engagement strategy documentation
• Mandatory occurrence reports and follow-up actions
• Records of any building work, refurbishment, or material changes
• Previous owner documentation (where available)

#Golden Thread format requirements

The Golden Thread must be:

For a detailed guide to setting up and maintaining your Golden Thread, see our complete Golden Thread guide.

Maintaining a digital Golden Thread is one of the most operationally demanding requirements of the BSA. It touches every aspect of building management -- from fire risk assessments to contractor works to resident communications. Platforms like Brocade are designed to serve as the Golden Thread, providing a single digital record with audit trails, version control, and structured information management.

#Safety Case Report

Under sections 83-85 of the BSA, the PAP must:

1. Assess building safety risks (section 83)
2. Manage those risks with reasonable steps (section 84)
3. Prepare a Safety Case Report documenting the assessment and management approach (section 85)

The Safety Case Report is not a one-off document. It must be kept up to date as risks change, building work is carried out, or new information becomes available.

A Safety Case Report should include:

• A description of the building (structure, systems, materials, occupancy)
• Identified building safety risks (structural, fire, other)
• The measures in place to manage each risk
• How risks are monitored on an ongoing basis
• How the Safety Case connects to the fire risk assessment
• Who is responsible for each area of risk management

#Mandatory Occurrence Reporting

Section 87 of the BSA requires APs to report certain safety occurrences to the BSR. This is known as Mandatory Occurrence Reporting (MOR).

#What must be reported

Safety occurrences that pose a risk of significant harm to people in or around the building, including:

• Structural failures or concerns
• Spread of fire
• Failure of fire safety systems (suppression, detection, compartmentation)
• Any event that could cause a significant risk to life safety

#Reporting process

See the GOV.UK guidance on submitting mandatory occurrence notices and reports for the submission process.

#Residents' engagement strategy

Under section 91 of the BSA, the PAP must prepare and give effect to a residents' engagement strategy. This strategy must describe how the PAP will:

• Promote the participation of residents in building safety decisions
• Provide building safety information to residents
• Consult residents on changes that affect building safety
• Operate a system for residents to raise complaints about building safety

The engagement strategy must be in writing and made available to residents. It should cover how residents can:

• Report safety concerns
• Request building safety information
• Participate in consultations about changes affecting safety
• Escalate complaints if they are not resolved

#Duties on residents

Residents also have duties under sections 95-97 of the BSA:

• Cooperate with the AP in meeting building safety duties
• Not interfere with safety measures (fire doors, smoke detectors, ventilation)
• Comply with requests for information relevant to building safety
• Not create risks that affect safety of other residents

#Contractor competence and accountability

While the BSA does not have a specific "contractor competence" section, the PAP's duties under sections 83-84 (risk assessment and management) require ensuring that contractors working on the building are competent and accountable.

Tracking fire risk assessment actions through to completion -- including which contractor was assigned, what evidence they provided, and whether the work was verified -- is a core compliance workflow that Brocade is built to manage.

#Scheduled checks and maintenance

Regular maintenance and inspections are essential to maintaining building safety. While the BSA does not prescribe a specific maintenance schedule, the PAP's duty to manage building safety risks (section 84) implicitly requires a structured approach to maintenance.

#Hypothetical scenarios

These are fictional examples designed to show how the BSA obligations work in practice.

#Scenario 1: Oakwood House -- 8 storeys, 24 units, RTM company as PAP

Oakwood House is a purpose-built residential block in Manchester. The RTM company holds the right to manage and is the PAP (as the party responsible for the structure and exterior). The original freeholder retains the freehold but has no repairing obligation -- so the RTM company is the sole AP and PAP.

Registration: The building was registered with the BSR in September 2023. KBI was submitted including details of the external wall system (brick cavity construction, no cladding concerns).

Golden Thread: The RTM company uses a digital building management platform to store fire risk assessments, maintenance records, and building safety documents. Version control is maintained through the platform's audit trail.

Safety Case: A Safety Case Report was prepared with input from the building's fire risk assessor. Key risks identified: ageing fire doors on floors 3-8, communal ventilation system needing upgrade. Actions tracked and progressing.

Resident engagement: The RTM sends a quarterly building safety newsletter and holds an annual residents' meeting. A dedicated email address handles safety complaints with a 5-working-day response target.

BAC readiness: Oakwood House is in the 18-29.99m category with fewer than 378 units, so it has not yet been called in for a BAC. The RTM is preparing materials in advance.

#Scenario 2: Meridian Tower -- 22 storeys, 180 units, corporate freeholder with managing agent

Meridian Tower is a large residential tower in London. The PAP is the corporate freeholder. The freeholder has appointed a managing agent to handle day-to-day management. The managing agent assists with building safety duties, but the legal responsibility remains with the freeholder.

Key roles: The freeholder is the PAP and sole AP. The managing agent acts on behalf of the PAP but is not itself an AP (it does not hold a legal estate or repairing obligation -- it operates under a management contract).

Registration and BAC: At 22 storeys with 180 units, Meridian Tower falls into the BSR's early priority group. The PAP was called in for BAC application in 2025 and submitted within the 28-day window.

Golden Thread: The managing agent maintains the Golden Thread using Brocade's compliance platform, which provides structured information storage, audit trails, and document management. The freeholder has oversight access.

MOR incident: A fire suppression system failed on floor 14 during routine testing. The managing agent submitted an occurrence notice to the BSR within 10 working days. The full report was submitted within the BSR's specified timeframe, documenting the failure, root cause (valve degradation), and remedial action (full system inspection and valve replacement).

#Scenario 3: Riverside Court -- 12 storeys, 60 units, multiple accountable persons

Riverside Court has a complex ownership structure. The freeholder owns the structure and exterior. A separate company has a repairing obligation for the internal common areas (lobbies, corridors, stairwells) under a long lease. Both are Accountable Persons. The freeholder is the PAP.

Cooperation duty: Both APs must cooperate with each other. The PAP coordinates the Safety Case Report, but the AP responsible for internal common areas must provide information about their areas and manage risks within their control.

Practical challenge: Fire door maintenance falls to the internal AP (they have the repairing obligation for corridors). But the fire strategy and compartmentation integrity are the PAP's concern. A formal cooperation agreement sets out responsibilities, information sharing, and escalation procedures.

Resident engagement: The PAP leads the residents' engagement strategy, but the internal AP participates in responding to complaints about common area maintenance. Both APs share relevant information with each other and with the BSR as required.

#Enforcement and penalties

The BSA gives the Building Safety Regulator significant enforcement powers.

#Compliance notices

Under section 99, the BSR can issue a compliance notice requiring the PAP or AP to take specific steps within a set timeframe. Failure to comply with a compliance notice is itself a further ground for enforcement action.

#Criminal offence

Section 101 of the BSA creates a criminal offence for contraventions that give rise to a risk of death or serious injury. This is the sharpest enforcement tool in the regime. It applies to the individual or organisation that is the accountable person, not to employees or agents (though corporate liability provisions apply).

#Fire and Rescue Authority enforcement

For fire safety matters specifically (as opposed to structural or building safety risks), Fire and Rescue Authorities (FRAs) retain enforcement powers under the Regulatory Reform (Fire Safety) Order 2005. This includes enforcement of PEEPs requirements once those come into force on 6 April 2026.

#Timeline of upcoming changes

The BSA regime is being implemented in phases. Key dates and developments:

#Further reading and official sources

#Primary legislation

• Building Safety Act 2022 -- Part 4: Higher-risk Buildings in Occupation -- full text of the obligations covered in this checklist
• Building Safety Act 2022 -- Full Act -- complete legislation

#Secondary legislation

• Higher-Risk Buildings Procedures Regulations 2023 (SI 2023/909) -- BAC application procedures, safety case procedures
• Higher-Risk Buildings (Keeping and Provision of Information) Regulations 2024 (SI 2024/41) -- Golden Thread information requirements
• Key Building Information Regulations 2023 (SI 2023/963) -- registration information requirements

#GOV.UK guidance

• The Building Safety Act -- Overview and Resources -- BSA guidance hub
• Criteria for being a higher-risk building -- HRB definition
• Keeping information about a higher-risk building: the Golden Thread -- Golden Thread guidance
• Submitting mandatory occurrence notices and reports -- MOR process

#Related Brocade guides

• Residential PEEPs: What Building Managers Need to Do Before April 2026 -- PEEPs implementation guide
• Golden Thread Building Safety: The Complete Guide -- comprehensive Golden Thread requirements, digital records standards, and practical setup steps