Your responsibilities as building manager

If you manage or own a higher-risk building in England (18 metres or 7+ storeys with 2+ residential units), you have legal duties under the Building Safety Act 2022. Non-compliance is a criminal offence with unlimited fines.

This learning path covers your key obligations during the occupation phase.

Understand the Building Safety Act

The Building Safety Act 2022 created a new regulatory regime for higher-risk residential buildings. The Building Safety Regulator (an executive non-departmental public body sponsored by the Ministry of Housing, Communities and Local Government) oversees compliance.

gov.uk

Criteria for a higher-risk building in occupation (opens in a new tab)

GOV.UK guidance on which occupied buildings are in the regime.

Higher-risk building definition

Check whether your building meets the statutory definition.

A higher-risk building is subject to the Building Safety Act 2022 regulatory regime if it meets specific height or storey thresholds and contains residential units. This definition applies in England only. The definition is assessed both during design and construction, and during the occupation phase.

Height threshold: 18 metres or more
Storey threshold (alternative): 7 storeys or more
Residential units requirement: Must contain 2 or more residential units
Geographic scope: England only
Regime commencement: 1 October 2023
Latest clarification: Updated 28 May 2025 (roof garden tribunal decision)

Buildings meeting either the height criterion (18 metres) OR the storey criterion (7 storeys) AND containing 2+ residential units are subject to mandatory registration with the Building Safety Regulator before occupation. A building does not need to meet both the height and storey thresholds - meeting one is sufficient if it contains 2 or more residential units.

Building Safety Regulator guidance on HRB criteria (opens in a new tab)

Know your role as Accountable Person

Every higher-risk building must have one or more Accountable Persons (APs). If there are multiple APs, one must be the Principal Accountable Person (PAP) with coordination duties.

Accountable Person duties

Detailed guide to AP and PAP responsibilities under the Building Safety Act

Who is an Accountable Person

APs typically include freeholders, management companies, and housing associations.

Under Part 4 of the Building Safety Act 2022, every occupied higher-risk building in England has one or more accountable persons (APs) responsible for managing building safety risks. Where there is more than one AP, one of them is the principal accountable person (PAP), who carries additional duties.

Legislation: Building Safety Act 2022, Part 4
Geographic scope: England only
Registration offence in force: 1 October 2023
Risk assessment and safety case duties in force: 16 January 2024
Higher-risk building (occupation phase): At least 2 residential units and at least 18 metres or at least 7 storeys
Regulator: Building Safety Regulator

Who is an accountable person

Under section 72, an accountable person is either:

a person who holds a legal estate in possession in any part of the common parts, or
a person who holds no legal estate in the building but is under a relevant repairing obligation for any part of the common parts.

An estate owner is not an accountable person where every long lease it grants gives a repairing obligation for those common parts to someone else, or where its repairing obligations are functions of a right to manage company. On commonhold land, the commonhold association is the accountable person. Each accountable person is responsible for the part of the building set by regulations.

The principal accountable person

Under section 73, where a building has one accountable person, that person is the PAP. Where it has more than one, the PAP is the accountable person who holds the legal estate in possession in, or is under the repairing obligation for, the relevant parts of the structure and exterior of the building. Those parts exclude anything included in the demise of a single dwelling or business premises. If more than one person qualifies, the tribunal can decide under section 75.

PAP registration: Commits an offence if the building is occupied but not registered (section 77)
PAP safety case report: Prepare as soon as reasonably practicable once the building is occupied or the person becomes PAP; revise when needed (section 85)
PAP notification: Tell the regulator when a safety case report is prepared or revised; give a copy on request (section 86)
PAP residents' engagement strategy: Prepare, review and act on it (section 91)
PAP complaints system: Establish and operate it for safety complaints (section 93)
PAP mandatory occurrence reporting system: Establish and operate it (section 87)

Duties of every accountable person

Each accountable person for an occupied higher-risk building must, for the part of the building they are responsible for:

Assess building safety risks: As soon as reasonably practicable once occupied, then at regular intervals, if the assessment may be invalid, and when the regulator directs (section 83)
Manage building safety risks: Take all reasonable steps to prevent a risk materialising and reduce the severity of any incident, promptly and with arrangements to plan, control and review them (section 84)
Report to the regulator: Give prescribed information in prescribed circumstances; an offence without reasonable excuse (section 87)
Keep information: Keep prescribed information and copies of prescribed documents, kept up to date (section 88)
Give information to residents: Provide prescribed information and respond to requests from residents and owners (sections 89 and 92)

Keeping information about the building

Section 88 requires each accountable person to keep the prescribed information about the building, in line with prescribed standards, and to obtain any prescribed information or documents they do not hold unless that is not practicable. The Secretary of State sets the detail in regulations.

Relationship with the Fire Safety Order

The accountable person role works alongside, not instead of, the responsible person duties under the Regulatory Reform (Fire Safety) Order 2005. The same person can hold both roles.

Building Safety Regulator guidance on Accountable Persons (opens in a new tab)

Building Safety Act 2022 - Legislation (opens in a new tab)

Register your building

The PAP must register the building with the Building Safety Regulator. Allowing occupation of an unregistered higher-risk building is a criminal offence.

Register a higher-risk building

Step-by-step registration process with the Building Safety Regulator

Registration requirements

Key Building Information (KBI) required for registration.

The Principal Accountable Person must register a higher-risk building with the Building Safety Regulator before occupation. It is a criminal offence to allow occupation of an unregistered higher-risk building.

Who must register: Principal Accountable Person (PAP)
Registration deadline (new buildings): Before first occupation (Gateway 3 approval required first)
Registration deadline (existing buildings): Deadline was 30 September 2023 for existing occupied HRBs
Criminal offence: Allowing occupation of unregistered HRB is a criminal offence
Penalty: Unlimited fine

Key Building Information (KBI) required

Registration requires submission of Key Building Information to the Building Safety Regulator.

Building address: Full postal address and UPRN
Building description: Number of storeys, height, number of residential units
AP/PAP details: Names and contact details of all Accountable Persons and Principal Accountable Person
Year of construction: When the building was substantially completed
Number of residential units: Total residential units in the building
External wall systems: Information about external wall materials including cladding
Structural systems: Information about building structure type

Building Assessment Certificate

The Building Assessment Certificate (BAC) confirms the Building Safety Regulator has assessed the building's safety case and the PAP's compliance with their occupation-phase duties. The PAP does not apply on their own initiative: they must apply within 28 days of being directed to do so by the Building Safety Regulator under section 79. The BAC is not the same as the Gateway 3 completion certificate, which relates to the design and construction phase.

Certificate purpose: Confirms the BSR has assessed the building and the PAP has demonstrated compliance with building safety duties
Application timing: Within 28 days of a Building Safety Regulator direction to apply (section 79) - not a proactive application
Not Gateway 3: The BAC is distinct from the Gateway 3 completion certificate issued at the end of construction
Display requirement: Once issued, the certificate must be displayed prominently in the building (section 82)

Prepare your safety case report

The PAP must prepare and maintain a safety case report demonstrating how building safety risks are identified and managed. The Regulator can request this at any time.

Safety case report requirements

Content and review requirements for safety case reports.

Legislation: Building Safety Act 2022, Part 4
Geographic scope: England only
Registration offence in force: 1 October 2023
Risk assessment and safety case duties in force: 16 January 2024
Higher-risk building (occupation phase): At least 2 residential units and at least 18 metres or at least 7 storeys
Regulator: Building Safety Regulator

Who is an accountable person

Under section 72, an accountable person is either:

a person who holds a legal estate in possession in any part of the common parts, or
a person who holds no legal estate in the building but is under a relevant repairing obligation for any part of the common parts.

The principal accountable person

PAP registration: Commits an offence if the building is occupied but not registered (section 77)
PAP safety case report: Prepare as soon as reasonably practicable once the building is occupied or the person becomes PAP; revise when needed (section 85)
PAP notification: Tell the regulator when a safety case report is prepared or revised; give a copy on request (section 86)
PAP residents' engagement strategy: Prepare, review and act on it (section 91)
PAP complaints system: Establish and operate it for safety complaints (section 93)
PAP mandatory occurrence reporting system: Establish and operate it (section 87)

Duties of every accountable person

Each accountable person for an occupied higher-risk building must, for the part of the building they are responsible for:

Assess building safety risks: As soon as reasonably practicable once occupied, then at regular intervals, if the assessment may be invalid, and when the regulator directs (section 83)
Manage building safety risks: Take all reasonable steps to prevent a risk materialising and reduce the severity of any incident, promptly and with arrangements to plan, control and review them (section 84)
Report to the regulator: Give prescribed information in prescribed circumstances; an offence without reasonable excuse (section 87)
Keep information: Keep prescribed information and copies of prescribed documents, kept up to date (section 88)
Give information to residents: Provide prescribed information and respond to requests from residents and owners (sections 89 and 92)

Keeping information about the building

Relationship with the Fire Safety Order

The accountable person role works alongside, not instead of, the responsible person duties under the Regulatory Reform (Fire Safety) Order 2005. The same person can hold both roles.

Building Safety Regulator guidance on Accountable Persons (opens in a new tab)

Building Safety Act 2022 - Legislation (opens in a new tab)

Maintain the golden thread

You must maintain a digital record of key building safety information throughout occupation. This includes design decisions, as-built information, and maintenance records.

Create and maintain the golden thread

Guide to golden thread requirements and digital information management

Golden thread requirements

What information the golden thread must contain during occupation.

The golden thread is the digital record of information about a higher-risk building in England. During design and construction the client must create and maintain an electronic facility holding it, and the people designing or carrying out the work must be able to use it. Once the building is occupied, each accountable person must keep the golden thread information and documents listed in Schedule 1 to the Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2024.

Applies to: Higher-risk buildings in England
Design and construction: Client keeps the electronic facility
Occupation: Each accountable person keeps Schedule 1 information
Storage: Electronic, transferable without loss
Changes: Record who changed it and when

The client adds the designs, the approved plans and documents, and the evidence of compliance to the facility before construction (or the relevant stage of it) begins, then keeps it up to date as the work changes. Before applying for a completion certificate the client hands the specified golden thread information to the relevant person, who confirms in writing that they can access it and that it is enough to understand, operate and maintain the building and its fire safety systems.

Golden Thread Information guidance (opens in a new tab)

Engage with residents

The Principal Accountable Person must prepare a residents' engagement strategy and run a complaints system, and every Accountable Person must give residents the prescribed safety information. Residents can escalate to the Building Safety Regulator if dissatisfied.

Resident engagement requirements

Guide to consulting residents and handling safety complaints

Ongoing compliance and reporting

Accountable Persons must report certain safety occurrences to the Regulator - give notice as soon as reasonably practicable, with a full report within 10 days. You must also assess the risk of fire spread and structural failure at regular intervals and whenever you have reason to think an assessment is no longer valid, and either be competent or appoint competent persons to assist.

Mandatory occurrence reporting

Which safety events must be reported and within what timeframe.

Accountable Persons must report certain safety occurrences to the Building Safety Regulator. This mandatory occurrence reporting system helps the Regulator identify trends and take action to improve building safety across England.

Reporting duty: Accountable Persons must report prescribed safety occurrences to Building Safety Regulator
Scope: Applies to all higher-risk buildings during occupation phase
Purpose: Enable Regulator to identify trends and systemic safety issues

Reportable safety occurrences

The following types of occurrences must be reported to the Building Safety Regulator:

Structural failure: Any structural failure or movement that causes concern about structural integrity
Spread of fire: Any fire that spreads beyond the room or compartment of origin
Fire safety failure: Failure of fire safety systems (detection, alarm, suppression) during a fire
Near misses: Events that could have caused structural failure or uncontrolled spread of fire
Death or serious injury: Any death or serious injury arising from building safety risks

Reporting timescales

Immediate risk: Report immediately if there is an immediate risk to life
Standard occurrences: Report within 10 calendar days of the occurrence becoming known
Investigation findings: Must provide further information if requested by Regulator

Resident reporting

Residents can also report safety concerns directly to the Building Safety Regulator if they are not satisfied with the AP's response to their complaint.

Resident complaints: Residents should first complain to AP using the complaints procedure
Escalation to Regulator: If dissatisfied with AP response, residents can complain to Building Safety Regulator
Regulator action: Regulator can investigate and take enforcement action against AP

Submitting mandatory occurrence notices and reports (opens in a new tab)

gov.uk

Building Safety Regulator (opens in a new tab)

Official guidance and reporting portal for higher-risk buildings

What happens if you fail to comply

The Building Safety Regulator has extensive enforcement powers. Criminal penalties include unlimited fines and imprisonment. Enforcement also includes compliance notices (breach of a notice is itself a criminal offence) and special measures, where the First-tier Tribunal can appoint a manager on the BSR's application.

Penalties for non-compliance

Criminal and civil enforcement powers under the Building Safety Act.

The Building Safety Act 2022 creates criminal offences for non-compliance with the building control and higher-risk building regimes. Companies and individuals can be prosecuted, and officers of a company can be personally liable where an offence is committed with their consent or connivance or is attributable to their neglect (section 40).

Building regulations breach: Either-way offence, up to 2 years on indictment (section 39)
Occupation before completion certificate: Either-way offence, up to 2 years on indictment (section 76)
Unregistered occupied building: Either-way offence, up to 2 years on indictment (section 77)
Compliance notice breach: Either-way offence, up to 2 years on indictment (section 99)
Critical risk contravention: Either-way offence, up to 2 years on indictment (section 101)
False or misleading information: Either-way offence, up to 2 years on indictment (section 24)
Obstructing an authorised officer: Summary offence, fine up to level 3 (section 23)
Special measures: On the regulator's application the First-tier Tribunal can appoint a special measures manager (section 102 and Schedule 7)

The Building Safety Regulator can give an accountable person a compliance notice requiring specified steps or remedial action within a set period (section 99). Failing to comply without reasonable excuse is an offence.

Managing an occupied higher-risk building

Your responsibilities as building manager

Understand the Building Safety Act

Criteria for a higher-risk building in occupation (opens in a new tab)

Know your role as Accountable Person

Accountable Person duties

Register your building

Register a higher-risk building

Prepare your safety case report

Maintain the golden thread

Create and maintain the golden thread

Engage with residents

Resident engagement requirements

Ongoing compliance and reporting

Building Safety Regulator (opens in a new tab)

What happens if you fail to comply

Next steps

Growing your business

Start importing goods to the UK

Transfer ownership of your business

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