Following our recent Gateway 2 CPD webinar held on Friday 11^th 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.