Higher-risk buildings, BSR submissions, UK wide
Gateway 2 and Gateway 3 Support
On a higher-risk building the Building Safety Regulator decides when you may start on site and when anyone may move in, which makes a thin application the most expensive delay in the programme. AL23 Safety prepares, submits and defends Gateway 2 and Gateway 3 applications and runs the change control between them, on projects UK wide.
What is gateway support?
Getting the application right the first time, not the third
The gateways are the three statutory control points the Building Safety Act 2022 placed around higher-risk buildings. Gateway 1 sits at planning, Gateway 2 before construction, Gateway 3 at completion. At Gateway 2 and Gateway 3 the Building Safety Regulator is the building control authority. There is no approved inspector route and no negotiating your way onto site.
Gateway support means assembling the technical case, testing it against what the regulator actually asks for, submitting it and answering the requests for information that follow. Most refusals are not caused by unsafe design. They are caused by incomplete or inconsistent information across the design package, which is solvable before you submit.
Who needs one
Which buildings and which works are caught
- Higher-risk buildings under construction. At least 18 metres in height or at least 7 storeys, containing at least two residential units, in England. Height is measured from ground level to the floor surface of the top storey, excluding rooftop plant.
- Care homes and hospitals meeting the height test. These are in scope for the design and construction gateways even though they are excluded from the in-occupation duties. A new hospital wing at 18 metres goes through Gateway 2 and Gateway 3 in the same way as a block of flats.
- Conversions and change of use that create a higher-risk building where there was not one before.
- Works to existing higher-risk buildings, including internal alterations and external wall remediation, where building control approval is required.
- Projects in the change control period between Gateway 2 approval and the Gateway 3 completion certificate.
- The definition was reviewed and confirmed unchanged on 17 December 2025. There is no forthcoming relaxation to wait for.
The regulations that apply
Your legal framework, in plain terms
The Building Safety Act 2022 created the regime. The Building (Higher-Risk Buildings Procedures) (England) Regulations 2023 set out the gateway procedures. The Building Regulations etc. (Amendment) (England) Regulations 2023 inserted the dutyholder and competence requirements at regulations 11A to 11Q of the Building Regulations 2010. Both commenced on 1 October 2023. Gateway 1 came earlier, on 1 August 2021.
Gateway 1, planning
A fire statement must accompany the planning application for relevant high-rise residential development, with the regulator as a statutory consultee.
Gateway 2, pre-construction
A building control approval application goes to the regulator. Construction cannot start until it is approved. This is a hard stop, not a notification.
Change control
Between Gateway 2 and Gateway 3 changes are categorised. The significant ones need the regulator's agreement before they are built. The golden thread must be maintained throughout.
Gateway 3, completion
A completion certificate application goes to the regulator. Occupation cannot begin until the certificate is issued and the building registered.
Dutyholder competence
The client must appoint a principal designer and a principal contractor in writing and verify competence first.
The regulator itself has changed. The Building Safety Regulator became a standalone body sponsored by MHCLG on 27 January 2026, leaving the Health and Safety Executive, as the first step toward a single construction regulator. Its strategic plan for 2026 to 2027 targets Gateway 2 decisions within 18 weeks for non-complex cases. The Building Safety Levy commences on 1 October 2026 on certain building control applications for residential development in England, which is a cost to build into your appraisal.
What the regulator's throughput actually looks like
Published performance, May to July 2026
The Building Safety Regulator published its May to July 2026 figures on 12 August 2026. Read them before you set a programme date.
New higher-risk buildings and conversions
53 received, 45 decided, a 91 per cent approval rate, 131 in progress, median 22 weeks.
External remediation
103 received, 110 decided, 85 per cent approval, 330 in progress, median 34 weeks.
Higher-risk building internal works
448 received, 166 decided, 77 per cent approval, 981 in progress, median 32 weeks.
Gateway 3
127 in progress, 29 approvals, a 72 per cent approval rate, median 16 weeks. No new build project has yet reached Gateway 3.
A year earlier new build ran at 43 weeks with a 39 per cent approval rate. Performance has improved substantially. The pressure point in 2026 is internal works, where 981 cases sit in progress against 166 decided in the quarter. If your project is a refurbishment or a remediation scheme rather than a new block, plan for the longer tail.
What the service covers
Everything between a design package and an approval
- A pre-submission readiness review against the regulator's information requirements, scored package by package so you can see what is missing.
- Preparation and assembly of the Gateway 2 building control approval application, including drawings, specifications and the compliance narrative that ties them together.
- The fire and emergency file and the construction control plan, written consistently with the design rather than assembled separately.
- Fire strategy interrogation covering means of escape, compartmentation, external wall construction and firefighting provision. Our in-house fire strategy team defends the argument rather than passing it on.
- Consistency checking between architectural, structural, mechanical and fire packages, which is where most requests for information originate.
- Management of requests for information, with tracked responses and a single version-controlled record.
- Change control from approval onwards, including categorisation of each change, the route it must follow and the audit trail behind the decision.
- Maintenance of the golden thread through construction so the information handed to the accountable person is complete.
- Gateway 3 completion certificate application, including as-built information and evidence that the building is as approved.
- External wall remediation submissions, including the interface with a fire risk appraisal of external walls where one exists.
- Dutyholder and competence evidence, coordinated with the Building Regulations principal designer role where we hold it.
Our process
Close the gaps before the regulator finds them
- 01
Gap review
We assess the current design package against the application requirements, then issue a written list of what is missing, inconsistent or unevidenced.
- 02
Package build
We work with your design team to close the gaps and write the compliance narrative explaining how the building meets each applicable requirement.
- 03
Submission and management
We submit, log the case and handle every request for information with a tracked response.
- 04
Change control
After approval we categorise every proposed change, route it correctly and keep the record straight through construction.
- 05
Gateway 3
We assemble the completion evidence, confirm the as-built position matches the approval and submit the completion certificate application.
What you get
A submission you can audit two years later
- A pre-submission readiness report with a package by package gap list and a recommended submission date.
- The complete Gateway 2 application as submitted, in a version-controlled index.
- A requests for information log with every question, response and date.
- A change control register with categorisation, decision route and status for each change.
- A golden thread index showing where each piece of information lives and who owns it.
- The Gateway 3 completion certificate application pack with the as-built evidence set.
What we need from you
The package as it really stands today
- The full design package, including drawings, specifications and the fire strategy at its latest revision.
- The construction programme with intended start on site and practical completion dates.
- The appointed principal designer and principal contractor with their competence evidence.
- Phasing intentions and any early works you are contemplating before approval.
- A single client decision maker. Gateway work generates questions that need answers within days.
Why AL23 Safety
Technical depth where the questions come from
Accountable
If the package is not ready, we tell you before submission rather than after a refusal. A postponed submission is cheaper than a rejected one.
One team, three disciplines
Fire engineering, fire safety and health and safety in-house. The fire strategy, the escape modelling and the compliance narrative are written by people who talk daily.
Expert and chartered
Led by a Chartered Building Engineer and Health and Safety Professional working to current standards and legislation.
UK wide
We support higher-risk building projects across the UK from our Manchester base.
Before you set the start on site date
The programme should follow the decision times, not the other way round
Median decision times of 22 weeks for new build and 32 weeks for internal works are published facts. A programme that assumes faster is the most common cause of gateway pain.
Common questions
Answers, up front
Cannot see your question? Get in touch and we will answer it directly.
Contact usBuilding work on the higher-risk building cannot start until the application is approved. This is a hard stop. Some enabling activity may fall outside the definition of building work. That has to be assessed case by case rather than assumed, which we do with you before anyone mobilises.
For the design and construction gateways, yes, where they meet the height and storey test. They are excluded from the in-occupation duties such as registration and the safety case report. The two questions have different answers and confusing them causes real problems.
The regulator published a median of 22 weeks for new higher-risk buildings and conversions in the May to July 2026 period and 32 weeks for internal works. Its strategic plan targets 18 weeks for non-complex Gateway 2 cases. Treat the published medians as your planning assumption.
It depends on the state of your design package, the size and complexity of the building, whether the work is new build or internal works and how much change control we expect to manage. A project arriving with a coherent package needs far less than one where four disciplines have worked to different revisions. Call us and we will look at the package before we price it.
You resubmit. The internal works approval rate was 77 per cent in the last published quarter. Refusals are not rare. The cost is programme time. That is precisely why the pre-submission gap review earns its fee.
The safety case report is an in-occupation duty for the principal accountable person rather than a gateway deliverable. Much of the underlying information is the same. We build the Gateway 3 evidence in a form that feeds straight into a building safety case report once the building is occupied.
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