Principal Accountable Person additional duties

What is a Principal Accountable Person?

Where a higher-risk building has multiple Accountable Persons (APs), one must be designated as the Principal Accountable Person (PAP). The PAP has all the duties of an ordinary Accountable Person, plus additional coordination, registration, and liaison responsibilities.

This guide explains the additional duties that apply specifically to the PAP role. If you are the only Accountable Person for your building, you are automatically the PAP and these duties apply to you. If there are multiple APs, you should first determine which party is the PAP based on the legal ownership and repair obligations.

Who becomes the Principal Accountable Person?

The PAP is determined by a statutory test under Section 73 of the Building Safety Act 2022:

• If there is only one Accountable Person, that person is automatically the PAP
• If there are multiple Accountable Persons, the PAP is the person who holds a legal estate in possession of (or a relevant repairing obligation for) the structure and exterior of the building (typically the freeholder)
• If it is unclear or disputed who the PAP is, an application can be made to the First-tier Tribunal for a determination under Section 75

Common PAP scenarios:

• Freeholder owns entire building: Freeholder is PAP
• Freeholder with head leaseholder: Usually the freeholder remains PAP unless the head lease transfers structure/exterior obligations
• Right to Manage (RTM) company: The RTM company may become an AP for common parts management, but the freeholder typically remains PAP for structure/exterior
• Commonhold: The commonhold association is PAP

If you are uncertain whether you are the PAP for your building, seek legal advice. The Building Safety Regulator can request evidence of your status, and incorrectly identifying the PAP exposes both parties to enforcement action.

Additional PAP duties overview

Beyond the standard Accountable Person duties (assessing and managing building safety risks, maintaining the golden thread, engaging with residents), the PAP has these additional responsibilities:

1. Coordination duty: Coordinate with all other APs to ensure building safety duties are fulfilled
2. Building registration: Register the building with the Building Safety Regulator
3. Safety case report: Prepare and maintain the safety case report for the whole building
4. Residents' engagement strategy: Create and implement the strategy for the entire building
5. BSR liaison: Act as the primary point of contact with the Building Safety Regulator
6. Building Assessment Certificate: Apply for and display the Building Assessment Certificate

Coordination duty between Accountable Persons

Where multiple Accountable Persons exist, the PAP must coordinate with all of them to ensure that collectively, all building safety duties are discharged effectively. This is not a passive role - the PAP must actively facilitate cooperation.

What coordination requires

The PAP must:

• Identify all other Accountable Persons and establish formal communication channels
• Ensure there are no gaps or overlaps in safety responsibilities across different parts of the building
• Hold regular coordination meetings or establish processes for ongoing communication
• Share relevant building safety information with other APs
• Ensure that safety measures implemented by one AP do not compromise measures by another
• Document coordination activities as part of the golden thread

When coordination is particularly important

Coordination becomes critical when:

• Planning building works that affect multiple areas of responsibility
• Responding to a mandatory occurrence that must be reported to the BSR
• Updating fire risk assessments that cover the whole building
• Implementing changes to evacuation strategy
• Revising the safety case report

If another AP fails to cooperate or fulfil their duties, document your attempts to coordinate and consider reporting the situation to the Building Safety Regulator. The PAP cannot delegate the coordination duty - it remains your responsibility even if other APs are uncooperative.

Building registration responsibilities

The PAP must register the higher-risk building with the Building Safety Regulator. This is a mandatory duty and operating an unregistered occupied higher-risk building is a criminal offence.

PAP-specific registration duties

As PAP, you must:

• Submit the initial registration application to the BSR
• Provide accurate information about all Accountable Persons
• Pay the registration fee (GBP 251 per building under the BSR charging scheme 2026 to 2027, from 8 April 2026)
• Provide detailed building information within 28 days of application
• Notify the BSR within 14 days of any changes to registrable information (including changes to APs)
• Display the prescribed building safety notice (with Accountable Person details), the most recent Building Assessment Certificate once issued, and any relevant compliance notice in a prominent position within the building, as required by Section 82

If the identity of the PAP changes (for example, following a sale or lease restructure), the outgoing PAP must notify the BSR and the incoming PAP must update the registration.

Safety case report preparation

The PAP must prepare a safety case report for the building as soon as reasonably practicable after it becomes occupied. This is one of the most important PAP duties - the safety case demonstrates how building safety risks are being identified, assessed, and managed.

What the safety case must contain

The safety case report must include:

• Risk assessment: Identification and assessment of building safety risks (fire spread and structural failure) under Section 83
• Risk management steps: Description of steps taken to prevent or reduce the severity of building safety risks under Section 84
• Monitoring arrangements: How you monitor the effectiveness of safety measures
• Review schedule: How often you review and update the safety case

Ongoing safety case duties

The safety case is not a one-time document. The PAP must:

• Keep the safety case under review and revise it when appropriate - the law does not prescribe a fixed frequency, but an annual review (or sooner if circumstances change) is good practice
• Revise the safety case if the risk assessment identifies new risks or if additional steps are taken
• Notify the BSR as soon as reasonably practicable after preparing or revising the safety case
• Provide a copy to the BSR on request
• Make relevant safety case information available to residents

Where multiple APs exist, the PAP coordinates the safety case but each AP must provide information about their area of responsibility. The PAP is responsible for ensuring the safety case covers the entire building coherently.

Residents' engagement strategy ownership

The PAP must create and implement a residents' engagement strategy for the building. This strategy sets out how you will engage with residents on building safety matters - it is a mandatory duty under Section 91 of the Building Safety Act.

Strategy requirements

The residents' engagement strategy must explain:

• How you will promote participation of residents in making building safety decisions
• How you will provide building safety information to residents
• How residents can request building safety information
• How residents can make complaints about building safety and how complaints will be handled
• How you will consult residents about changes to the strategy

Implementing the strategy

The PAP must:

• Give a copy of the strategy to each resident when they become a resident, and on request thereafter
• Make the strategy available to residents in accessible formats where needed
• Review and update the strategy regularly
• Actually implement the strategy - having a strategy document is not sufficient
• Keep records of resident engagement activities as part of the golden thread

Where multiple APs exist, the PAP prepares the strategy for the whole building, but other APs must cooperate in implementing it for their respective areas.

Building Safety Regulator liaison

The PAP is the primary point of contact between the building and the Building Safety Regulator. This means you handle all formal communications, applications, and notifications to the BSR on behalf of the building.

Key liaison responsibilities

The PAP must:

• Respond to BSR requests for information within specified timeframes
• Report mandatory occurrences (safety occurrences) to the BSR
• Notify the BSR of changes to registrable information
• Apply for the Building Assessment Certificate
• Facilitate BSR inspections and provide access as required
• Apply for a Building Assessment Certificate within 28 days when directed by the BSR

There is no annual return or annual report duty to the BSR - the ongoing duties are mandatory occurrence reporting, notifying changes to registration and key building information, providing the safety case report on request, and applying for a Building Assessment Certificate when directed.

Mandatory occurrence reporting

The PAP must report safety occurrences to the BSR. A reportable safety occurrence is an incident or situation relating to structural integrity or the spread of fire that presents a risk of a significant number of deaths, or of serious injury to a significant number of people. Examples include:

• Structural failures or movements
• Spread of fire between residential units or into common parts
• Any event that could cause a significant risk to life from fire spread or structural failure

Not every fire is reportable - a minor, contained fire that did not present a risk to a significant number of people does not meet the threshold. Submit a mandatory occurrence notice as soon as reasonably practicable after becoming aware, followed by a full report within 10 days. Keep mandatory occurrence reporting records as part of the golden thread. The BSR publishes guidance on what constitutes a reportable occurrence and the required reporting format.

Building Assessment Certificate application

The PAP must apply for a Building Assessment Certificate (BAC) from the Building Safety Regulator within 28 days of being directed to do so by the BSR (Section 79). You cannot apply unprompted - the BSR calls buildings in for assessment in risk-prioritised tranches. The BAC confirms that the BSR has assessed the building's safety case report and is satisfied that the PAP is managing building safety risks appropriately.

Application process

When directed to apply for a BAC, the PAP must:

• Ensure the building is registered with the BSR
• Have a compliant safety case report prepared - have this ready before your building is called
• Submit the BAC application through the BSR online portal within 28 days of the direction
• Pay the application fee (GBP 312 plus GBP 156 per hour of assessment time under the BSR charging scheme 2026 to 2027, from 8 April 2026)
• Provide any additional information requested by the BSR during assessment

After receiving the BAC

Once the BAC is issued, the PAP must:

• Display the certificate in a prominent position within the building (failure to display is a criminal offence)
• Be ready to apply again when directed - the BSR aims to reassess each building's BAC around every 5 years, or sooner if there is significant change or a safety concern, and will direct a fresh application

If the BSR refuses to issue a BAC, they will explain why and what must be done to achieve compliance. The PAP can request a review of the decision or appeal to the First-tier Tribunal.

Non-delegable duties and personal liability

PAP duties are non-delegable. This means you can appoint agents, building safety managers, or contractors to help fulfil your duties, but legal responsibility remains with you as PAP. If an agent fails to perform properly, enforcement action is taken against you, not the agent.

Personal liability for directors and officers

Where the PAP is a corporate body (company, LLP, or association), individual directors, managers, or officers can be personally prosecuted for building safety offences if the offence was committed with their:

• Consent
• Connivance
• Attributable to their neglect

This means individuals cannot hide behind corporate structures. Directors who fail to ensure adequate building safety compliance risk personal criminal liability, including imprisonment for serious offences.

Practical steps for new PAPs

Penalties for PAP duty failures

Failure to comply with PAP duties can result in:

• Failure to register: Criminal offence - unlimited fine
• Failure to prepare safety case: Criminal offence - unlimited fine
• Failure to apply for a BAC within 28 days of a BSR direction: Criminal offence under Section 79
• Failure to display BAC: Criminal offence under Section 82
• Providing false information: Criminal offence - unlimited fine and up to 2 years imprisonment
• Obstruction of BSR: Criminal offence

The BSR also has civil enforcement powers including compliance notices and improvement notices. Under special measures, the BSR can apply to the First-tier Tribunal, which can make a special measures order appointing a manager to take over building safety duties from a failing PAP at the PAP's expense.