Current Status: Interpretation of Building Safety Regulator (BSR) operational update issued to industry — December 2025. This analysis reflects how the update changes risk, behaviour and submission strategy for London projects entering 2026.
The Building Safety Regulator has today (23/12/2025) issued a year-end operational update to industry, reporting a record number of Gateway 2
determinations and early signs of reduced live application volumes following recent process changes.
On the surface, the data signals improving throughput. In practice, the implications for London project teams are more nuanced.
This article does not repeat the update. Instead, it explains what the figures mean for Gateway 2 risk, submission behaviour and regulatory strategy as the industry moves into the 2026 operating cycle.
What the BSR is reporting
According to the update issued today:
- 347 Gateway 2 determinations were made across all application types in the 12 weeks to 22 December
- 727 determinations have been issued since 29 September 2025
- Quarter 4 2025 is expected to exceed 700 determinations, compared with just over 200 in Quarter 1
- Live applications across all categories have reduced from 1,219 to 1,158
- 69% of all determinations during December related to London projects
- The Innovation Unit is now managing over 100 new-build applications, representing more than 22,000 residential units
These figures confirm that the regulator’s operational focus has shifted from system setup toward throughput and case resolution.
However, volume alone does not tell the full story.
Why London still carries disproportionate Gateway 2 risk
Nearly seven in ten recent Gateway 2 determinations relate to London projects.
This reflects not only volume, but complexity: taller buildings, mixed-use schemes, constrained sites,
legacy structures and higher fire and façade risk profiles.
For London teams, the increase in determinations should not be read as a relaxation of scrutiny.
Instead, it reinforces a pattern already visible throughout 2025: decisions are moving faster where submissions are coherent,
complete and internally controlled and stalling where evidence gaps remain.
This aligns with previously observed rejection drivers at Gateway 2:
What the Innovation Unit data actually shows
The BSR reports that the Innovation Unit (IU) has delivered several approvals within a 12-week window,
with further decisions expected before year-end. Importantly, the update notes that these outcomes are being achieved
where applications are of good quality and where additional information can be resolved through structured engagement.
This confirms a critical point for 2026: the Innovation Unit is not a shortcut for incomplete submissions.
It functions best where complexity is genuine and where the project team already demonstrates strong
multi-disciplinary coordination and evidence discipline.
This distinction is explored in more detail here:
Legacy cases, remediation and what this signals for new submissions
A significant proportion of recent determinations relate to historic and legacy cases submitted under earlier operating models.
The regulator’s update confirms a pragmatic approach: direct engagement, case-by-case resolution and targeted intervention
rather than automatic rejection.
For new submissions entering 2026, this has two implications.
First, BSR capacity is being freed by closing older cases.
Second, expectations for new applications are rising, because the benchmark for good quality is now better defined.
What project teams should take from this update
The update should not be interpreted as a signal to accelerate submissions at the expense of control.
The projects moving fastest are those that demonstrate:
- clear dutyholder responsibility
- coherent fire and structural strategies
- controlled design change
- evidence that remains consistent through submission and construction
These themes sit at the core of London’s post-2025 operating model:
Key takeaway
Today’s BSR update confirms that regulatory throughput is improving, but it does not change the underlying rule of 2026:
Gateway 2 success is driven by control, not optimism.
Faster decisions reward disciplined submissions. Poorly governed applications will continue to stall,
regardless of headline determination numbers.
image: constructionmagazine.uk
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Expert Verification & Authorship:
Mihai Chelmus
Founder, London Construction Magazine | Construction Testing & Investigation Specialist |
