As construction teams enter 2026, a clear pattern is emerging across London’s higher-risk building (HRB) projects: Building Control applications are not failing because the rules have changed, but because expectations are now being enforced consistently.
The Building Safety Regulator (BSR) has published updated guidance clarifying how applications are validated, approved, approved with requirements, or rejected. While the document itself is procedural, its implications for live London projects are operational, commercial and immediate.
The Building Safety Regulator (BSR) has published updated guidance clarifying how applications are validated, approved, approved with requirements, or rejected. While the document itself is procedural, its implications for live London projects are operational, commercial and immediate.
In short, the era of submit now, clarify later is over and for London’s high-value schemes, a rejection at this stage can mean the difference between a project remaining viable or stalling indefinitely.
This guidance reinforces a broader industry shift already visible throughout 2025, where pressure stopped being temporary and became structural, as explored in our analysis of why 2025 quietly rewired the construction industry.
This guidance reinforces a broader industry shift already visible throughout 2025, where pressure stopped being temporary and became structural, as explored in our analysis of why 2025 quietly rewired the construction industry.
Why BSR Issued This Clarification Now
The regulator has now set out, in plain terms, how applications are validated, approved, approved with requirements or rejected, through its published criteria for validating, approving or rejecting building control applications.
The BSR guidance on validating, approving or rejecting building control applications was not issued in isolation. It is a direct response to the volume of incomplete, unclear or poorly evidenced submissions being made at Gateway 2 and Gateway 3.
The regulator’s position is now explicit: applications must be sufficiently detailed, coherent and demonstrably compliant at the point of submission. The full criteria are set out in the official BSR guidance on the Building Control Authority and application validation, which confirms that incomplete or unclear information is not a minor administrative issue, but a legal compliance failure.
For London projects operating under programme pressure, this has immediate consequences.
The regulator’s position is now explicit: applications must be sufficiently detailed, coherent and demonstrably compliant at the point of submission. The full criteria are set out in the official BSR guidance on the Building Control Authority and application validation, which confirms that incomplete or unclear information is not a minor administrative issue, but a legal compliance failure.
For London projects operating under programme pressure, this has immediate consequences.
What Valid Now Means in Practice
While the legal language refers to sufficiently detailed submissions, the practical interpretation is clear. A valid application must demonstrate that the duty holder understands the building, the risks and the control measures in place.
In 2026, this means that applications relying on generic statements, design intent alone or unresolved assumptions are far more likely to be delayed or rejected. The regulator is no longer prepared to infer compliance where evidence is missing.
This is why Golden Thread data is now being judged on substance rather than structure, a theme explored in detail in our analysis of how London contractors are proving the Golden Thread in 2026.
While the legal language refers to sufficiently detailed submissions, the practical interpretation is clear. A valid application must demonstrate that the duty holder understands the building, the risks and the control measures in place.
In 2026, this means that applications relying on generic statements, design intent alone or unresolved assumptions are far more likely to be delayed or rejected. The regulator is no longer prepared to infer compliance where evidence is missing.
This is why Golden Thread data is now being judged on substance rather than structure, a theme explored in detail in our analysis of how London contractors are proving the Golden Thread in 2026.
Approval with Requirements (AwR): What it Really Means
One of the most misunderstood aspects of the guidance is Approval with Requirements (AwR). Many teams still assume this is a route to submit partially developed designs and resolve issues later.
The BSR position is far stricter. AwR is only available where the application demonstrates substantive compliance with Building Regulations, and the outstanding items are minor, defined and non-life-safety critical. It is not a mechanism to defer fundamental design resolution.
In practice, teams that succeed with AwR are those that can evidence compliance through inspection records, calculations, test data and verification, not promises of future clarification.
One of the most misunderstood aspects of the guidance is Approval with Requirements (AwR). Many teams still assume this is a route to submit partially developed designs and resolve issues later.
The BSR position is far stricter. AwR is only available where the application demonstrates substantive compliance with Building Regulations, and the outstanding items are minor, defined and non-life-safety critical. It is not a mechanism to defer fundamental design resolution.
In practice, teams that succeed with AwR are those that can evidence compliance through inspection records, calculations, test data and verification, not promises of future clarification.
Why Applications Are Being Rejected
The guidance also clarifies the circumstances in which BSR will reject applications outright. These include material non-compliance with Building Regulations, significant information gaps, unclear presentation, or failure to respond adequately to Requests for Information (RFIs).
The RFI process is particularly important in 2026. The regulator now expects timely, meaningful responses, often within 48 hours to one week. Delayed, partial or unfocused responses are increasingly being treated as confirmation that the submission was not ready.
This is where evidence-led submissions outperform narrative-based ones. Teams that can point to verified site data, inspection outcomes and test results reduce the volume and complexity of RFIs significantly. This is one reason why structural investigation and testing services in London are becoming embedded in compliance strategies, rather than treated as reactive problem-solving tools.
The guidance also clarifies the circumstances in which BSR will reject applications outright. These include material non-compliance with Building Regulations, significant information gaps, unclear presentation, or failure to respond adequately to Requests for Information (RFIs).
The RFI process is particularly important in 2026. The regulator now expects timely, meaningful responses, often within 48 hours to one week. Delayed, partial or unfocused responses are increasingly being treated as confirmation that the submission was not ready.
This is where evidence-led submissions outperform narrative-based ones. Teams that can point to verified site data, inspection outcomes and test results reduce the volume and complexity of RFIs significantly. This is one reason why structural investigation and testing services in London are becoming embedded in compliance strategies, rather than treated as reactive problem-solving tools.
Attached Structures: A London-specific Trap
The guidance also addresses a common failure point on London schemes: attached structures.
Where buildings are structurally connected, they are treated as a single building for the purposes of Building Regulations, regardless of ownership, tenure or phasing. Submitting separate applications for structurally attached buildings is likely to result in rejection.
Equally, plant rooms or systems serving multiple HRBs must be included in each relevant application. Omitting shared elements, even where they appear secondary, creates compliance gaps that are now being flagged early by the regulator.
Given the density and complexity of London developments, this clarification alone will prevent a significant number of avoidable rejections in 2026.
The guidance also addresses a common failure point on London schemes: attached structures.
Where buildings are structurally connected, they are treated as a single building for the purposes of Building Regulations, regardless of ownership, tenure or phasing. Submitting separate applications for structurally attached buildings is likely to result in rejection.
Equally, plant rooms or systems serving multiple HRBs must be included in each relevant application. Omitting shared elements, even where they appear secondary, creates compliance gaps that are now being flagged early by the regulator.
Given the density and complexity of London developments, this clarification alone will prevent a significant number of avoidable rejections in 2026.
What This Means for 2026 Submissions
Taken together, the message from the BSR is clear. The regulator is not raising the bar; it is enforcing it.
For duty holders, designers and contractors, this means that evidence-led preparation is no longer optional. Submissions that rely on future clarification, unresolved assumptions or incomplete verification will struggle. Those that integrate physical inspection, testing, traceability and clear Golden Thread records will move more smoothly through the process.
This enforcement reality sits alongside broader delivery pressures already shaping London’s pipeline, as seen in the City of London planning pipeline and the delivery constraints emerging into 2026.
Taken together, the message from the BSR is clear. The regulator is not raising the bar; it is enforcing it.
For duty holders, designers and contractors, this means that evidence-led preparation is no longer optional. Submissions that rely on future clarification, unresolved assumptions or incomplete verification will struggle. Those that integrate physical inspection, testing, traceability and clear Golden Thread records will move more smoothly through the process.
This enforcement reality sits alongside broader delivery pressures already shaping London’s pipeline, as seen in the City of London planning pipeline and the delivery constraints emerging into 2026.
Conclusion: Enforcement Through Expectation
2026 will not be defined by dramatic enforcement headlines. It will be defined by consistent decision-making.
The BSR guidance confirms that approval, conditioning or rejection will be based on clarity, completeness and evidence at the point of submission. For prepared teams, this provides certainty. For those still relying on paper compliance, it introduces friction and delay.
The lesson is simple. In London’s higher-risk building environment, compliance is no longer about what is written. It is about what can be demonstrated, defended and relied upon, now, not later.
2026 will not be defined by dramatic enforcement headlines. It will be defined by consistent decision-making.
The BSR guidance confirms that approval, conditioning or rejection will be based on clarity, completeness and evidence at the point of submission. For prepared teams, this provides certainty. For those still relying on paper compliance, it introduces friction and delay.
The lesson is simple. In London’s higher-risk building environment, compliance is no longer about what is written. It is about what can be demonstrated, defended and relied upon, now, not later.
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Expert Verification & Authorship: Mihai Chelmus
Founder, London Construction Magazine | Construction Testing & Investigation Specialist |
