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Cladding Remediation Bill 2026: What Housing Providers Must Know

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Seven Issues We See Repeatably in Development Projects

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PAS 9980:2026 Is Here. What’s Changed and What You Need to Know

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Managing Compliance Across a Property Portfolio

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The Building Safety (Remediation of Unsafe Cladding etc) Bill was introduced to Parliament on 14th October 2026, proposing new requirements for assessing and addressing fire safety risks associated with external walls in residential buildings across England. For housing associations, local authorities, managing agents and residential building owners, the proposed legislation could introduce additional responsibilities for identifying buildings at risk, undertaking external wall fire risk assessments and progressing necessary remediation works. Of particular significance are the proposals affecting residential buildings between 11 and 18 metres in height, alongside greater scrutiny of Fire Risk Appraisals of External Walls (FRAEWs) and stronger requirements for building owners to address identified risks. Although the Bill has not yet become law, understanding the proposed changes now will help housing providers prepare their portfolios and identify where further assessments or investigations may be required. What Is the Building Safety Remediation Bill 2026? The Building Safety (Remediation of Unsafe Cladding) Bill is proposed legislation intended to strengthen the identification, assessment and remediation of unsafe external wall systems in residential buildings. The Bill builds on the existing building safety framework, seeking to improve accountability and establish clearer requirements for those responsible for managing external wall fire safety risks. While much of the regulatory attention in recent years has focused on higher-risk buildings, the proposed legislation places particular emphasis on medium-rise residential buildings, including those between 11 and 18 metres. If enacted, the Bill could result in a more structured approach to identifying affected buildings, assessing their external walls and ensuring appropriate action is taken where risks are identified. What are the Key Proposed Changes? 1. Registration of Residential Buildings Between 11 and 18 Metres One of the most significant proposals is the introduction of a registration framework for medium-rise residential buildings in England. This would help establish a clearer picture of the buildings within scope and support the identification of properties requiring further external wall fire safety assessment. For housing providers managing large residential portfolios, this could mean reviewing existing building information to establish which properties fall within the proposed requirements. Building height, construction characteristics, existing fire safety documentation and previous external wall assessments may all be relevant when preparing for the potential changes. 2. Mandatory External Wall Fire Risk Assessments The Bill proposes requirements for external wall fire risk assessments of relevant residential buildings, with a proposed assessment period linked to the commencement of the legislation. These assessments would help establish whether external wall systems present a fire risk and whether further investigation, mitigation or remediation is necessary. A Fire Risk Appraisal of External Walls (FRAEW) provides a structured assessment of the fire risks associated with a building's external wall construction, including cladding systems, insulation and other relevant components. For housing providers, the proposed requirements reinforce the importance of understanding which buildings have already undergone appropriate assessments and where gaps remain. Importantly, the Bill is not yet law, and any future assessment deadlines will depend on the final legislation and its commencement provisions. 3. Greater Scrutiny of FRAEW Assessments The proposed legislation also introduces additional oversight of external wall fire risk assessments, including auditing arrangements. This places greater importance on the quality, consistency and supporting evidence behind assessments, particularly where recommendations involve interim measures or remediation. Housing providers should consider whether existing assessments provide a sufficiently clear understanding of the external wall construction, associated risks and recommended actions. Where previous assessments are incomplete, outdated or based on limited information, further technical review or investigation may be appropriate. However, the proposed legislation should not be interpreted as automatically requiring every existing FRAEW to be repeated. 4. Stronger Requirements for Remediation Identifying external wall fire safety risks is only part of the process. The Bill also proposes stronger responsibilities for ensuring that appropriate action is taken to address any identified risks. Depending on the findings of an assessment, this could involve additional investigations, interim safety measures, targeted remediation or more extensive works to external wall systems. For housing providers, the challenge may involve managing multiple buildings with different risk profiles, remediation requirements and operational considerations. A structured, risk-based approach will be important in determining priorities, planning works and maintaining appropriate records of decisions and progress. 5. Increased Accountability and Enforcement The Bill proposes additional enforcement mechanisms intended to ensure that responsible parties take appropriate action to address unsafe external wall systems. This could increase the importance of maintaining clear assessment records, documented remediation strategies and evidence of progress. For organisations responsible for large residential estates, having a coordinated approach to external wall fire safety will help demonstrate how risks are being identified, assessed and managed. As is the trend, maintaining a golden thread of information across your building stock will remain an important part of achieving compliance across your property stock. How Does the Bill Relate to PAS 9980:2026? The introduction of the Bill follows the publication of the revised PAS 9980:2026, the British Standards Institution's code of practice for assessing the fire risk associated with external wall construction and cladding on existing buildings. PAS 9980 provides a methodology for carrying out Fire Risk Appraisals of External Walls, helping competent professionals evaluate external wall systems and recommend proportionate risk management measures. The revised 2026 guidance provides an important technical reference for organisations commissioning FRAEWs and professionals undertaking assessments. While the Bill establishes proposed legislative responsibilities, PAS 9980 provides a recognised technical framework for assessing external wall fire risks. For housing providers, the two developments reinforce the importance of commissioning assessments from suitably competent professionals and ensuring recommendations are supported by appropriate technical evidence. What Should Housing Providers Consider Doing Now? Although the Building Safety Remediation Bill remains subject to parliamentary scrutiny and change, housing providers can take some practical steps to understand their current position and plan for the future. Review residential building portfolios. Identify properties that may fall within the proposed scope, particularly residential buildings between 11 and 18 metres in height. Understand existing assessment coverage. Establish which buildings have already undergone external wall fire risk assessments and whether the relevant reports and supporting evidence are available. Identify gaps in information. Review whether existing building records provide sufficient information about external wall construction, materials and potential fire safety risks. Consider existing FRAEW recommendations. Determine whether previous assessments identified further investigations, interim measures or remediation works, and review progress against those recommendations. Develop a prioritised approach. Where multiple buildings may require attention, establish a structured programme based on risk, available information and existing statutory responsibilities. Taking these steps can help housing providers prepare for any changes while supporting their wider building safety obligations. How Firntec Can Support Housing Providers At Firntec, we work with housing associations, local authorities, building owners and managing agents to assess building safety risks and provide practical, evidence-based recommendations. Our external wall fire safety expertise includes undertaking FRAEWs in accordance with PAS 9980, reviewing existing assessments and supporting clients with remediation strategies. For organisations managing multiple residential buildings, we can also help review existing assessment coverage, identify gaps in technical information and develop prioritised programmes of work. As the Building Safety Remediation Bill progresses through Parliament, our team can support clients in understanding how the proposed requirements may affect their buildings and what action may be appropriate. Our focus is on providing clear technical advice that enables building owners to make informed decisions about the safety and compliance of their properties. As the Building Safety Remediation Bill progresses through Parliament, we'll continue to monitor developments and share updates on what the proposed changes could mean for building owners and housing providers. Follow Firntec on LinkedIn and keep an eye on our website for the latest legislative updates, practical guidance and expert insights to help you stay informed and prepared. If you would like support reviewing your residential portfolio, commissioning FRAEWs or understanding the implications of the proposed legislation, contact Firntec today.

Development programmes rarely slip because of one dramatic failure. More often, time is lost gradually: a query waiting for an answer, an action with no owner, a drawing issued a week later than the contractor needed it. Each delay looks small, but they compound across months of design, procurement and construction. Whether a scheme is a new-build, a conversion or the refurbishment of a listed building, we see the same seven patterns. This article sets out where time is lost, why it matters, and what changes when each is addressed early. It describes an industry-wide pattern rather than the shortcomings of any single team, and it is written for the people running live projects who want something they can check against their own. The cost is highest on schemes with a fixed completion date, such as an academic intake or a hotel opening, where a few weeks of slippage can mean missing the date altogether. 1. Slow response times A question that waits three days for an answer stops every task that depends on it. The cost is rarely the wait itself. It is the work downstream, such as procurement, design coordination and contractor instructions, that either sits idle or carries on based on an assumption that later has to be reversed. What helps: agreeing response times at appointment, such as same-day acknowledgement and a stated turnaround for technical queries, then reporting against them. Agreeing how queries are raised matters too, because a ten-minute call or site conversation often settles what a long email thread cannot. Firntec's team can act as a central coordination point across the client, design team and contractor. 2. Limited access to technical engineering support A project manager can often spot a problem without being able to or have the technical capabilities to resolve it. When structural, fire or building services questions have to be sent to a separate specialist, each round trip adds days, and the answer often arrives after the programme has moved on. What helps: engineering input inside the delivery team, available when the question arises rather than after a separate appointment. Firntec can bring fire and structural engineering input into the early planning and design stages, so technical queries are resolved within the team. 3. Consultants appointed separately Project management, cost, technical review and monitoring are often appointed one by one, by different people, at different times. Each firm works to its own scope, and the gaps between those scopes belong to nobody. On conversions and listed buildings, where existing conditions are uncertain, those gaps are where surprises tend to land. What helps: one multi-disciplinary team working from a single brief, so a question that crosses disciplines is answered once, by people who already share the context. Firntec can provide Employer's Agent, Quantity Surveyor and Clerk of Works as well as Fire Engineering & Structural Engineering services within one coordinated team, or support a client's existing team in individual roles. 4. No clear governance or responsibility structure When an action is raised in a meeting and no name sits against it, it is usually still open at the next one. Unclear ownership is most costly where disciplines meet, such as a design change that affects cost, programme and compliance at once. What helps: a simple responsibility matrix agreed at the start, and an action log where every item has one owner and one date. An Employer's Agent acting as a single point of coordination makes that structure far easier to maintain. 5. Decisions made late, not proactively Governance says who decides. This issue is about whether the right people and information are present when the decision is needed. If the person with the relevant experience is not in the room, the decision is deferred, then revisited, then made under time pressure. What helps: a team that brings options, costs and recommendations to the table together, so decisions are made at the meeting rather than after it. Having commercial, technical and programme input in the same room avoids the loop of query, referral and reply. 6. No dedicated project manager A project manager shared across many schemes cannot hold the detail of any of them. Oversight becomes periodic, and issues are found at the next reporting cycle rather than the day they arise. What helps: a named project manager assigned from start to completion, who knows the scheme, the client's team and the contractor's, and is reachable when needed. Consistency matters more than seniority here, because a lead who holds the detail of one scheme makes faster calls than one spread across many and can offer consistency across multi-year programmes. 7. Issues found too late A defect or design clash found at handover costs far more to correct than one found at first fix, and more again once it affects the contractor's programme. On higher-risk buildings, regulatory gateways raise the stakes further, because gaps in the information submitted can delay approval and, with it, the start of work. Late discovery is almost always a symptom of the six points above. What helps: regular site inspections and independent technical oversight, so problems are identified while remediation is still cheap. Firntec's Clerk of Works and engineer inspections provide reporting and photographic evidence throughout delivery, giving clients an independent record rather than relying on contractor reports alone. How the seven issues connect These issues rarely occur alone. A consultant who is slow to respond (1) often has no engineer to call on (2), which pushes decisions to a later meeting (5) and lets problems reach site before anyone has seen them (7). Fixing one in isolation helps, but the biggest gains come from the structure underneath: a coordinated team, clear ownership and a named lead. Seven questions to ask of your live project Issue Questions to ask Warning sign 1. Response times Is there an agreed turnaround, and is it reported? Open queries with no date for an answer. 2. Technical support Who answers a structural or fire question, and how quickly? Technical queries leave the team to be answered. 3. Separate appointments Who owns the gaps between scopes? Two consultants each assume the other covers an item. 4. Governance Does every action have one owner and one date? Actions carried over meeting after meeting. 5. Decisions Are decisions made in the meeting? Items deferred pending further information. 6. Dedicated lead Is there one named lead for this scheme? The lead changes, or is unreachable at key points. 7. Late issues Who inspects independently, and how often? Defects first reported at handover. Our approach to project management consultancy We would rather say what we will do than describe what we believe. On every scheme, we aim to commit to: A stated response time for acknowledgement and for technical queries, reported against throughout A named lead who is on the project from start to completion Engineering input within the team, not a separate appointment Early flagging of risks with a proposed mitigation, rather than escalation after the programme is affected Regular face-to-face project meetings with a clear action log Every project is different, and the level of support will depend on the scheme, the team already in place and the risks involved. Some clients want full oversight, while others want specialist technical services integrated into an existing delivery team. To learn more about Firntec, contact us today via our contact page.

Following our recent Gateway 2 CPD webinar, we received a significant number of questions from attendees about how the Gateway 2 process is working in practice. Across Parts 1 and 2 of this series, we have covered everything from the scope of Gateway 2 and Higher-Risk Building (HRB) definitions to fire doors, emergency works, Gateway 3 and the types of work that may trigger an application. In this final instalment, we answer the remaining questions from the session, looking at design responsibility, procurement, the Building Safety Levy, application fees, product compliance and many others. 1. How should challenges with Gateway 2 approval for residential misting systems be approached? Where approval concerns arise around a specialist system such as high-pressure residential misting, a robust technical justification is particularly important. This should be supported by appropriate fire engineering evidence, product certification and testing data, alongside a clear explanation of how the proposed system satisfies the relevant regulatory requirements. Early coordination between the design team, fire engineer and other key stakeholders can help identify potential issues before submission. Where concerns remain, an independent specialist review may also help strengthen the evidence supporting the proposed solution. 2. Does Gateway 2 require contractors to be appointed early in the design process? Not necessarily. Clients can retain greater responsibility for the design through later RIBA stages before appointing a contractor, provided the relevant statutory dutyholder requirements are met. The procurement route should be structured so that the Principal Designer and Principal Contractor can fulfil their respective duties appropriately throughout the project. Whether a two-stage design-and-build approach is suitable will depend on the complexity of the project, the procurement strategy and how design responsibility and risk are allocated. 3. What is the Building Safety Levy and what could it mean for projects? The Building Safety Levy is intended to contribute towards the cost of remediating historic building safety defects. It is expected to apply to certain new residential developments, with charges linked to characteristics of the development. This means developers will need to consider the potential additional cost when planning and budgeting for future projects. Detailed implementation arrangements and final charging mechanisms should be confirmed through the relevant regulations before commencement. 4. What happens to the application fee if a Gateway 2 application is rejected? If an application is rejected at the initial stage, the original application fee still applies. Where an applicant subsequently resubmits, this is treated as a new application and a further fee is payable. Portal-based change control submissions are also chargeable. Routine notifications following approval, such as updates to a project start date submitted by email, are not treated in the same way. 5. Can a lack of product compliance evidence prevent a Gateway 2 application from progressing? Yes. The availability and quality of technical evidence can have a significant impact on the progress of a Gateway 2 application. Submissions need to demonstrate appropriate technical evidence and tested outcomes, with a clear relationship between the proposed design, relevant regulatory requirements and project-specific reports. Where a specified product or proposed solution cannot be adequately evidenced as compliant, there is a risk of further information being requested, delays to the application or potentially rejection. This makes early review of proposed products and specifications particularly important, especially where specialist contractors identify potential compliance concerns during the tender process. 6. Can reporting through the Building Remediation Hub conflict with a BSR application? No widespread formal conflicts have been reported, but consistency between different submissions is important. Organisations should ensure that information provided through remediation programmes aligns with the information submitted to the BSR. Differences in the stated scope, design information or proposed solutions could lead to further scrutiny or requests for clarification. Maintaining coordinated and accurate information across each process can therefore help reduce potential complications. 7. How do late design changes affect a Gateway application? Late design changes need to be managed through the appropriate change control process. A clear record should be maintained detailing what has changed, who made the decision, how the change was approved and whether it has any impact on building safety. Minor changes may be capable of being managed through change control, while more significant changes could require a fresh application. This makes effective change management an important consideration throughout the project rather than something addressed only at completion. 8. Are there different Gateway requirements for social landlords and non-profit organisations? There are currently no separate Gateway requirements specifically for social landlords or non-profit organisations. Government guidance, consultation exercises and engagement with the sector are intended to help understand how building safety requirements affect different organisations. However, providers continue to raise concerns around the potential cost, capacity and programme implications of meeting the requirements. For organisations managing large housing portfolios in particular, early planning and understanding how Gateway requirements could affect future programmes of work can be important. 9. Can Gateway information be made easier for residents to understand? Yes. Technical and regulatory information can be translated into clearer, more accessible communications that help residents understand what the Gateway process involves, likely timescales and some of the reasons projects may experience delays. Firntec can support organisations in developing resident-friendly versions of technical Gateway information. We can also review existing resident communications for accuracy and help ensure complex information is presented clearly and appropriately. To discuss support with resident communications, contact marketing@firntec.com. 10. Why might similar Gateway 2 applications receive different outcomes? Even where buildings or proposed works appear similar, each application is assessed according to the information submitted for that particular project. Reported reasons for rejection or requests for further information include missing documentation, unclear competence declarations, missing client letters of authority, missing scale drawings, insufficient technical evidence and gaps in coordinated project information. The overall quality and completeness of the submission can therefore be just as important as individual technical elements. Similar projects should not necessarily be assumed to receive identical outcomes. 11. Do fire doors have a defined lifespan or replacement cycle? There is no universal mandatory replacement period for a fire door purely based on its age. Fire doors should instead be regularly inspected and maintained, with decisions around replacement considering factors such as their condition, performance, certification evidence, damage, previous modifications and suitability for the building's current use. An older fire door may remain serviceable where it continues to meet the required performance, while another may require replacement considerably sooner because of its condition or alterations. 12. Is a digital evidence trail required alongside paper records? Yes. Documents, drawings and supporting evidence need to be digitally captured, uploaded and maintained as part of the building safety case and golden thread. A paper trail alone is unlikely to provide the information management approach required by the BSR process, which relies on digital submissions and the maintenance of an accessible, reliable source of information. Establishing effective information management from the beginning of a project can therefore make it easier to maintain the evidence trail as designs develop, changes are made and works progress. Bringing Our Gateway 2 Q&A Series to a Close Across this three-part series, we have answered 36 questions submitted by attendees of our Gateway 2 CPD webinar, highlighting both the breadth of the new regime and the practical challenges organisations are encountering as they apply it to live projects. One consistent theme throughout the questions has been the importance of preparation. Understanding the scope of the proposed works, establishing responsibilities early, coordinating information and maintaining a robust evidence trail can all help organisations approach the Gateway process with greater clarity. We would like to thank everyone who attended the session and submitted questions. The level of engagement throughout the webinar has helped us explore some of the practical issues building owners, landlords, consultants and project teams are currently navigating. Support with Your Gateway 2 Submission As this Q&A has highlighted, navigating Gateway 2 requires detailed planning, coordinated information and a clear understanding of the evidence expected throughout the process. Firntec can support clients with the preparation and management of Gateway 2 submissions, bringing together the required documentation, technical information and project evidence to help create a clear and comprehensive application. From early-stage advice through to submission and responding to BSR queries, our building safety specialists can provide support throughout the Gateway 2 process. Continue Your Building Safety CPD with Firntec Firntec regularly hosts CPD sessions, webinars and industry events covering the evolving building safety and compliance landscape. Keep an eye on our website and LinkedIn page for details of upcoming sessions. If your organisation requires support with Gateway applications, building safety consultancy or understanding the requirements affecting a particular project, speak to the Firntec team. Disclaimer: These responses reflect current understanding of the Higher-Risk Building regime and industry experience at the time of writing. They are provided for general guidance only and do not constitute legal or regulatory advice. Requirements may vary depending on project-specific circumstances and the interpretation of the Building Safety Regulator (BSR). Organisations should seek project-specific professional advice where appropriate.

Following our recent Gateway 2 CPD webinar held on Friday 11th September 2026, we received a significant number of questions from attendees looking for greater clarity around how the Gateway 2 process applies in practice. In Part 1 of our Q&A series, we explored some of the initial questions raised around the scope and applicability of Gateway 2, Higher-Risk Buildings (HRBs), fire doors, emergency works and current review timescales. For Part 2, we’re covering further questions around multi-building applications, cladding refurbishment, Gateway 3, maintenance and repair works, emergency situations and some of the circumstances that may trigger a Gateway 2 application. As with our first article, the answers below reflect current understanding of the Higher-Risk Building regime and industry experience at the time of writing. 1. For a project involving multiple HRB tower blocks or properties, can these be submitted under a single Gateway application? Current industry understanding suggests that where each tower or block has its own HRB registration number or separate address, each tower will generally require its own Gateway application, even where buildings have identical or very similar layouts and the proposed remedial works are the same. Where several blocks form part of a single HRB registration, a different approach may be possible. Applicants should confirm the position based on their specific circumstances and ensure that information within any combined submission can be clearly identified against each individual building. 2. What are some of the key lessons from Gateway 2 applications for cladding refurbishment projects? Experience reported across the industry reinforces the importance of beginning the evidence-gathering process as early as possible. Product certification and test evidence should be readily available, while designers, fire engineers and contractors should coordinate information from the outset. Detailed drawings and specifications will also form an important part of the submission. Applicants should allow sufficient time for BSR review and potential requests for further information, while maintaining a clear audit trail for design decisions and any subsequent changes. Ultimately, early planning and thorough preparation can help improve the quality of the submission and reduce the risk of avoidable delays. 3. If residents are decanted during works, is Gateway 3 required before they can return to the building? Gateway 3 is the process for evidencing that the works approved under Gateway 2 have been completed as intended. For new-build Higher-Risk Buildings, Gateway 3 must be completed before occupation. The position is different for existing occupied buildings, where residents may already have been living within the property before the works began. Where residents have been decanted and a phased or sectional return is proposed, a sectional completion strategy may be required. This should therefore be considered as part of the project and occupation planning rather than waiting until works are nearing completion. 4. What types of work fall within the definition of maintenance and repair works? Maintenance and repair can include like-for-like replacement of minor components, such as replacing a broken fire door closer or worn intumescent seals, where the work is supported by the original door evidence and operation and maintenance information. Replacing an entire door leaf and frame is different and is likely to require Gateway approval, or potentially an emergency works application where the circumstances are genuinely urgent – If the police have been forced to remove a door to gain entry as an example. The distinction between routine maintenance and more substantial building work is therefore important when considering the appropriate route. 5. When is Gateway 3 required, who is responsible for it, and does it apply to an already occupied building? Gateway 3 is required to evidence that the works approved through Gateway 2 have been completed as intended and to formally close out the Gateway 2 process. Responsibility sits with the client, although the work involved in preparing and coordinating the submission can be delegated to a consultant, similar to Gateway 2. For new-build Higher-Risk Buildings, Gateway 3 is required before occupation. For existing occupied HRBs, Gateway 3 is still expected to close out the process, although the circumstances differ because residents may already be living within the building. 6. Is BSR approval required when renewing flooring in the communal area of a tower block? This will depend on the nature and scope of the proposed works. Straightforward like-for-like maintenance may not require Gateway approval. However, where replacement works affect fire performance, means of escape, compartmentation, structural elements or other controlled building work, Gateway requirements may be triggered. The specific scope and potential impact of the work should therefore be considered before determining the appropriate route. If you would like to share further information about your particular example by submitting via the form below then one of our consultants will get back to you. 7. What qualifies as emergency work, and what happens once the immediate risk has been addressed? Emergency works are urgent repairs required because of an immediate risk to the health, safety or welfare of people in or around the building. The emergency provisions are intended for imminent risks rather than planned programmes of work. The immediate priority is to make the situation safe. Consider the earlier example of the police removing a flat entry door to gain access to a property, in that instance, repairing/replacing that flat entry door would be considered an emergency. Once that immediate risk has been addressed, any permanent repair or wider programme of work would usually need to follow the normal Gateway 2 process unless it clearly falls within maintenance or another exemption. 8. Can a full roof replacement be treated as emergency work if a tower block has a significant leak? A full roof replacement would not automatically qualify as emergency work simply because a leak has occurred. Temporary works required to prevent water ingress and address an immediate risk may potentially be considered emergency measures. A subsequent planned roof replacement, however, would normally need to be considered through the standard process. Whether particular works are exempt will depend on their scope and whether Building Regulations approval would otherwise be required. 9. If a HRB project benefits from transitional arrangements, would additional works such as window replacement require a separate Gateway 2 application? Where additional works form a separate package that was not included within the original scheme benefiting from transitional arrangements, those works should be assessed against the current HRB regime in their own right. For example, replacing all windows at a later stage may need to be considered separately where it was not included within the original project. Certification through a scheme such as FENSA does not automatically remove the potential requirement for a BSR application within a Higher-Risk Building. Where works affect Building Regulations requirements, external walls, fire performance or other controlled building work, Gateway 2 requirements may apply. 10. What experience has there been with exempt works where the wording is open to interpretation? One of the challenges organisations are encountering is establishing where genuinely urgent safety works end and planned remedial works begin. Situations such as urgent works associated with falling masonry can require careful consideration of the immediate risk, the work required to make the building safe and any subsequent permanent remediation. Where emergency or exemption provisions are relied upon, organisations should maintain a clear record of their rationale, retain supporting evidence and obtain appropriate professional advice. Worth referring to the section titled building work that does not need approval on Gov’s guidance building control approval for higher-risk buildings. 11. What should an Accountable Person do if a leaseholder alters the internal layout of a flat within an HRB without a BSR application? Changing the internal layout of a flat within a Higher-Risk Building can potentially affect fire safety, means of escape, smoke movement and compartmentation. A report from a fire engineer does not, by itself, determine whether BSR approval was required. The Accountable Person should obtain the relevant documentation, review the works against the applicable HRB requirements and seek specialist legal or regulatory advice where necessary. Where there are concerns that work may not comply with the relevant requirements, engagement with the BSR may also be appropriate. 12. Do penetrations through external walls or building risers trigger Gateway 2 if the contractor belongs to a Competent Person Scheme? Potentially. Works affecting fire stopping, compartmentation or other safety-critical elements within a Higher-Risk Building may trigger Gateway requirements, regardless of whether the contractor undertaking the work is registered through a Competent Person Scheme. Contractor certification does not automatically exempt work within an HRB from the Building Safety Regulator process. The nature and impact of the proposed work still need to be considered. More Gateway 2 Questions Answered The number and variety of questions received during our Gateway 2 CPD really does highlight just how many practical considerations organisations are working through as they navigate the Higher-Risk Building regime. From determining whether individual blocks require separate applications to understanding emergency works, How Gateway 2 relates to Gateway 3 and seemingly routine maintenance activities, establishing the correct route can depend heavily on the circumstances of an individual building and project. We still have more questions to cover. Part 3 of our Gateway 2 Q&A series will answer the remaining questions from the session, including design responsibility, Principal Designer and Principal Contractor requirements, late design changes, application fees, the Building Safety Levy, product compliance and the golden thread. Keep Up to Date with Firntec We regularly host CPD sessions, webinars and industry events designed to help building owners, landlords and compliance professionals understand changing building safety requirements and what they mean in practice. Keep an eye on Firntec’s website and LinkedIn page for details of upcoming sessions, or speak to our team to find out how we can support your organisation with building safety consultancy and the Gateway process. Disclaimer: These responses reflect current understanding of the Higher-Risk Building regime and industry experience at the time of writing. They are provided for general guidance only and do not constitute legal or regulatory advice. Requirements may vary depending on project-specific circumstances and the interpretation of the Building Safety Regulator (BSR). Organisations should seek project-specific professional advice where appropriate.

Firstly, thank you to everyone who joined our Gateway 2 webinar on 11th September 2026. The session generated a huge number of questions and interaction throughout, with attendees submitting more questions than we were able to cover off during the webinar itself. From the scope of Gateway 2 applications and fire door replacements to emergency works, templates and current review timescales, the questions really highlighted just how many practical challenges organisations are encountering when navigating the Higher-Risk Building (HRB) regime. We received over 60 questions in total, so rather than trying to cover everything in one article, we will be publishing a three-part Q&A series addressing the questions raised by attendees. In Part 1, we answer the first 12 questions from the session. 1. If only one wing of a building is being refurbished, does the Gateway 2 submission need to cover the whole building? Where a building has multiple wings but they form a single HRB registration and share key services such as lifts, sprinklers and fire alarm systems, the submission would generally be expected to consider the building as a whole. While the physical works may only relate to one wing, the application would ordinarily include wider building information such as drawings, hydrant locations, access arrangements and the overall building context. The submission should clearly identify that the proposed works are confined to one area and explain how potential impacts on the remaining wings and residents will be managed. The exact information required may vary depending on the project and the BSR’s interpretation. 2. Why is student accommodation included within the HRB criteria while hotels are excluded? The government’s position is based primarily on the nature of occupation rather than building use alone. Student accommodation is considered residential because occupants typically live there as their primary residence for extended periods. Hotels generally operate under different management, occupancy and fire safety arrangements. There continues to be industry discussion around mixed-use and seasonally operated accommodation, particularly where student accommodation may operate in a similar way to a hotel outside term time. However, no significant change to the HRB definition has been introduced. 3. If a smoke ventilation system is not working, can replacement works be treated as emergency works? If works relate to a fire safety system within an HRB, they are likely to be treated as Category A work. However, where the failure creates an immediate risk to life safety, emergency works provisions may apply to allow the system to be made safe and operational. It is important to distinguish between the immediate repair required to address the risk and any wider planned replacement or upgrade. Works beyond the immediate emergency repair would normally need to follow the appropriate Gateway process. 4. Can emergency works include hazards presenting imminent harm under Awaab’s Law or WHQS requirements in Wales? Potentially, where there is a genuine and immediate risk to the health, safety or welfare of occupants. However, emergency works provisions should not be viewed as an alternative route for planned improvement or remediation programmes. The urgency and severity of the individual situation need to be considered when determining the appropriate approach. 5. Is a self-certification route being introduced for fire door replacements in HRBs? There is currently no confirmed self-certification or Competent Person route for fire door replacements within HRBs. Flat entrance door replacements still need to follow the Gateway process. There has been industry discussion around whether fire doors or fire stopping could become exempt or potentially fall under a competent work route in the future, but no change is currently in place and there is no confirmed implementation date. 6. Could landlords submit a Gateway application in advance for future fire door replacement programmes? In principle, this may be a practical approach where future fire door replacements are anticipated and the proposed scope can be clearly defined. Based on current industry understanding, a whole-building Gateway 2 application may be capable of covering an approved programme of replacement works. However, organisations would need to ensure that any approval remains valid, that subsequent works remain within the agreed scope and that relevant commencement requirements have been satisfied. Project-specific advice should therefore be sought before relying on an existing approval for future phases of work. 7. When would fire safety enhancements be considered Category A rather than Category B work? The classification will depend on the nature and scope of the proposed work. Based on current industry practice and regulatory interpretation, replacement of fire doors within an HRB is generally treated as Category A work. It is therefore likely to require a Gateway application unless a relevant exemption applies or future regulatory changes introduce an alternative route. 8. Is there a Competent Person Scheme for installing flat entrance doors in HRBs? At present, there is no confirmed Competent Person Scheme that provides an alternative route for the installation of flat entrance doors within HRBs. These works still need to follow the Gateway process. An exemption or competent work route could potentially be introduced in the future, but this remains under discussion and there is currently no confirmed timescale for such a change. 9. What happens when building requirements change after plans have already been submitted? This will depend on the transitional arrangements associated with the particular legislative or regulatory change. In some circumstances, projects may be permitted to continue under requirements that applied when the original application was submitted. In others, new requirements could apply before the building is completed. This is particularly important for long-running projects. Developers should review the specific transitional provisions associated with the relevant legislation and seek project-specific advice where necessary. 10. Can AI-generated templates be relied upon as legal evidence for Gateway applications? AI can be a useful tool for supporting administrative and information-management processes, but AI-generated content should not be relied upon as legal evidence without thorough professional review and validation. Potential risks include factual inaccuracies, outdated references to regulations, missing project-specific information and uncertainty around accountability. Ultimately, the organisation making the submission remains responsible for the information provided to the BSR, regardless of how that information was initially produced. Any AI-generated content should therefore be appropriately reviewed and validated by competent professionals before being incorporated into a submission. 11. How can housing delivery targets be achieved alongside increasingly complex regulatory requirements? There is no single answer to balancing housing delivery with the additional cost, time and complexity associated with regulatory requirements. However, earlier design coordination and project planning can help organisations anticipate requirements rather than addressing them later in the programme. Greater standardisation of compliant designs, investment in digital information management and considering Gateway requirements from project inception can also help teams prepare more effectively. The relationship between building safety requirements and housing delivery remains an ongoing policy challenge across the sector. 12. How long are Gateway 2 applications currently taking to review? The published target for Gateway 2 reviews is eight weeks. However, experience reported by applicants across the industry suggests that applications can take significantly longer in some circumstances, particularly where additional information is requested or regulator workloads are high. Hospital refurbishment applications do not currently appear to follow a separate process from other HRB applications. Applicants may also be asked to agree to an extension to the review period. Experiences vary considerably between projects, so previous application timescales should not necessarily be treated as an indication of how long another submission will take. Where an applicant does not agree to a requested extension, the outcome will depend on the individual circumstances and the BSR’s assessment of the application. More Gateway 2 Questions Answered Thank you again to everyone who attended our Gateway 2 CPD webinar and contributed questions during the session. The volume and detail of the questions we received really do demonstrate the practical challenges organisations are facing in regards to completing works whilst adhering to the gateway process. With so many questions submitted, there is plenty more for us to cover. Part 2 of our Gateway 2 Q&A series will explore further questions around multiple HRBs, cladding refurbishment, Gateway 3, maintenance and repair works, emergency works and the circumstances in which different types of building work may trigger the Gateway process. Keep an eye on socials as this will likely go live next week. Part 3 will then look at further Gateway 2 application considerations, design responsibility, late changes, fees, the Building Safety Levy, resident communication and maintaining an appropriate evidence trail. Importantly, If your organisation is preparing for Gateway 2 or needs support understanding how the process could apply to planned works, Firntec can provide specialist building safety and fire engineering consultancy throughout the process including managing your gateway 2 submissions. Keep Up to Date with Firntec Our webinars and events are designed to help building safety, compliance and property professionals keep up to date with regulatory developments and understand what they mean in practice. Keep an eye on Firntec’s website and LinkedIn page for details of upcoming webinars, CPDs and industry events, and your next opportunity to join the conversation. Disclaimer: These responses reflect current understanding of the Higher-Risk Building regime and industry experience at the time of writing. They are provided for general guidance only and do not constitute legal or regulatory advice. Requirements may vary depending on project-specific circumstances and the interpretation of the Building Safety Regulator. Organisations should seek project-specific professional advice where appropriate.