For most of a quantity surveyor’s career, “building safety” meant fire-stopping details, Part B compliance, and making sure the fire engineer’s specification made it into the bill of quantities. The Building Safety Act 2022 – the legislative response to the Grenfell Tower disaster – changed that. On higher-risk buildings, safety information is no longer something you specify and move on from; it’s a cost item, a programme risk, and in some cases a criminal liability that follows named individuals around for the life of the building. The mechanism tying this together is what the Act calls the “golden thread”, and it’s increasingly something QSs are expected to understand well enough to price, procure around, and defend at a gateway review, not just leave to the fire engineer and the principal designer. This post sets out what counts as a higher-risk building, how the gateway process and the golden thread work in practice, where the cost and programme risk really sits for a QS, and how Australia’s rather different approach to the same underlying problem compares.
What Counts as a “Higher-Risk Building”
The Act’s safety regime targets “higher-risk buildings” (HRBs) specifically, not every project. During occupation, a building is generally in scope if it’s at least 18 metres tall or has at least seven storeys, and contains at least two residential units. The test used during design and construction, set out in the Higher-Risk Buildings (Descriptions and Supplementary Provisions) Regulations 2023, isn’t worded identically, and there are specific exclusions for particular building types – so don’t assume a scheme is in or out of scope on a quick height check; check the Regulations against the specific building type and project phase. A separate, lower threshold – 11 metres or five storeys, with at least two dwellings – governs something else entirely: what remediation costs can be passed through to leaseholders via the service charge. The two thresholds get confused constantly; they answer different questions.
The Building Safety Regulator and the Gateway Process
Since the regime went fully live in 2024, the Building Safety Regulator (BSR), sitting within the Health and Safety Executive, is the building control authority for HRBs in England – developers can no longer appoint a private approved inspector on these projects. New HRBs must clear three gateways: Gateway 1 at planning stage, where an in-scope scheme’s planning application must include a fire statement; Gateway 2 before construction starts, where the BSR must confirm the building control application demonstrates the design meets the Building Regulations, with work barred from starting until that’s granted; and Gateway 3 at completion, where the developer applies for a completion certificate and must show full compliance before anyone can occupy the building.
Breaching the gateway requirements isn’t just administrative – it’s a criminal offence that can be pursued against the principal accountable person personally. Significant design or construction changes made after Gateway 2 approval don’t get waved through on an ordinary variation instruction the way they might on a conventional scheme procured under NEC, JCT or FIDIC. They go through a formal change control process, and “major” changes need BSR sign-off before work can continue – exactly the kind of approval-stage delay a QS has to build into the programme and risk allowance on an HRB job.
The Golden Thread: What It Actually Has to Contain
The golden thread is meant to stop safety information getting lost at every handover point from designer to contractor to building owner – roughly where it kept getting lost on the buildings that failed. Legally, it’s an accurate, up-to-date, secure digital record of the safety-critical information about a building: how it was designed and why; the products, materials and fire safety systems actually installed, not just specified; construction methods and sequencing; plant, equipment and how critical systems are operated and maintained; the fire and emergency file and mandatory occurrence reporting arrangements; and any significant change made once the building is occupied.
The detailed list of what an accountable person must keep once a building is occupied sits in Schedule 1 of the Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2024. There’s no prescribed software or file format – the Regulations are deliberately format-neutral – but the information must be held digitally, kept secure, kept current, and be genuinely retrievable, not buried in an unindexed folder of PDFs on someone’s laptop.
Who’s Actually Holding It, and When
Responsibility moves through the building’s lifecycle, roughly in the same sequence a QS deals with on an HRB project. During design and construction, the client holds overall responsibility and must share design information with every designer and contractor; in practice, the principal designer captures and updates design-stage information, and the principal contractor takes it over once work starts on site. At practical completion, the client must hand that information to whoever takes on building safety responsibility for the occupied building, and a Gateway 3 completion certificate application must include a statement confirming the handover happened. Once occupied, every accountable person – broadly, whoever owns or is legally responsible for repairing the building’s common parts – must keep and share the golden thread information for the parts they’re responsible for; where there’s more than one, one of them is the principal accountable person, who also registers the building with the BSR and produces the safety case report.
Get the handover wrong at Gateway 3, and the principal accountable person is left reconstructing “as-built” information months or years after the people who actually knew it have moved on – precisely the situation the Act exists to stop happening again.
Why This Is a Cost and Procurement Problem, Not Just a Compliance One
None of the above sounds like a QS’s job until you notice where the cost lands, and where the mechanism most often fails on real projects.
Information management now has a price: capturing and maintaining golden thread records needs its own budget line and named resource, not an assumption that the BIM model will cover it automatically. Change control costs time, and time costs money – a major post-Gateway-2 change needing BSR approval is a genuine programme risk that belongs in the risk register and contingency, priced in rather than discovered when a variation gets stuck in the approval queue. Procurement documents have to place the obligation explicitly, too: if the golden thread duty isn’t written into appointments and subcontracts – who captures what, handed to whom, by when – it tends not to happen reliably, and the client, not the subcontractor who dropped it, carries the legal exposure. Leaving the handover off the final account checklist is just as common a gap, and it tends to surface as a dispute item months later, in exactly the kind of standoff that can end up in adjudication once the team that held the information has demobilised.
The Building Safety Levy adds a further line to the cost plan. It funds remediation of unsafe buildings and is charged to developers on most new residential schemes requiring a building control certificate (small schemes under 10 units and some community-benefit developments are exempt), calculated per square metre of gross internal area at a rate that varies by local authority, with a discount for substantially brownfield sites. It’s currently expected to apply from autumn 2026, and must be paid as a lump sum before a completion certificate is issued – a cash-flow item as much as a cost-plan one, and worth pricing into the appraisal from day one rather than discovering it just before completion, exactly when cash flow is tightest.
Dutyholder competence is now a legal requirement rather than a nice-to-have, too. The Act requires designers, contractors and accountable persons to demonstrate competence, and that increasingly shows up in pre-qualification and tender evaluation criteria for HRB work – and, for anyone working toward chartered status, in the kind of question now coming up at the RICS APC interview.
Australia’s Approach: No Golden Thread, But a Growing Paper Trail
Australia doesn’t have a single Act, regulator or golden thread concept mirroring the UK regime – building regulation is a state responsibility, and reform has moved at different speeds in different places. The clearest parallel is New South Wales’s Design and Building Practitioners Act 2020: registered design practitioners must lodge “declared designs” on the NSW Planning Portal and declare compliance with the Building Code of Australia before work can start, and builders must then declare the work was carried out in accordance with those declared designs. Variations must be re-declared, and the regulation introduces its own record-keeping obligations for class 2 buildings – apartment buildings – and buildings with a class 2 component.
It isn’t styled as a golden thread, and the two frameworks aren’t equivalent line for line, but the direction of travel – a documented, traceable, digitally lodged record connecting design intent to what actually got built – is the same. It’s worth watching closely if you’re QSing multi-residential work in NSW specifically; other states run their own, differently timed reforms, so the NSW position shouldn’t be assumed to apply elsewhere.
What This Means for You
On any project that’s even plausibly a higher-risk building, check the HRB status properly before pricing, procuring or programming anything. Then treat the golden thread like any other scope obligation: write it into appointments and subcontracts explicitly, budget for the resource that maintains it, build gateway and change-control approval time into the programme and risk allowance, price the Building Safety Levy into the appraisal from day one, and put golden thread handover on the practical completion and final account checklist. The buildings this regime exists to prevent were ones where nobody owned that information all the way through. On an HRB project, making sure someone demonstrably does is now as much a QS deliverable as the cost plan itself.