Status	2026 Regulatory Update
Regulator	Building Safety Regulator (BSR)
Applicability	London Higher-Risk Buildings (HRBs) – Design, Construction & Control of Safety-Critical Work
Compliance Window	Active (Immediate Application)

 

In 2026 London HRBs, “we’ll manage it on site” is not a control plan.

The Building Safety Regulator (BSR) is increasingly treating construction control planning as proof of whether a project team can actually deliver what it claims at Gateway 2. In London, where HRBs run through tight logistics, complex interfaces and high-density constraints, control plans are not paperwork — they are evidence of competence, governance and real delivery control.

If your project sits under BSR jurisdiction (or is moving into it), transferring building control functions to the BSR becomes a regulatory reset. The era of informal approvals and “we’ll confirm later” is over. The BSR is looking for deterministic control: who controls safety-critical work, how they control it, and what evidence proves it.

This matters most at Gateway 2, where the BSR expects materially complete, coordinated design. In 2026, that expectation extends beyond design drawings and strategies — it includes credible, auditable control plans that show how the design will be built without uncontrolled drift, substitutions or interface failures.

1. What a Construction Control Plan actually means in 2026

A Construction Control Plan (CCP) is the project’s “how we will keep the building safe while we build it” blueprint. It is not a generic method statement pack. For HRBs, it is a structured set of controls focused on safety-critical work: fire and structural risk controls, change control, inspections, evidence capture, and escalation routes.

In plain terms, the CCP must prove:

• Accountability: named owners for each control (no “TBC”).
• Specificity: controls tied to your actual building, not template language.
• Verification: how you will inspect, test and evidence compliance as you go.
• Change control: how you prevent safety drift (design changes, substitutions, sequencing changes).
• Golden Thread capture: how evidence is structured, stored and kept auditable.

This links directly to competence expectations for Principal Designers, because control plans are where competence becomes visible: a credible team can define controls that match risk reality, and can prove those controls are working.

2. The safety-critical work the BSR cares about most

BSR scrutiny concentrates where failure would create life-safety consequences. On London HRBs, the most common “control plan hotspots” are:

Fire performance (façade + compartmentation + penetrations)

• Façade system control: approved system definition, procurement lock, substitution rules, installation checks.
• Cavity barriers and fire stopping: installation sequencing, photo evidence, inspection sign-off, remedial loop.
• Penetration control: MEP penetrations tracked, sealed, verified, and re-verified after changes.

This connects directly to façade strategy, fire performance and liability exposure, because façade and fire controls are now treated as regulated safety system delivery, not “finishes”.

Structural risk controls (temporary works + sequencing + tolerances)

• Temporary works governance: design checks, hold points, permits-to-load, monitoring if required.
• Sequencing controls: pour sequences, backpropping rules, early loading restrictions, strike criteria.
• Interface risk: structural openings, anchor drilling, load transfers, and late-stage strengthening changes.

For refurbishment and change-of-use schemes, investigation evidence is part of the control plan: you can’t “control” a structure you haven’t verified. That ties to Legacy Concrete Frames: structural investigation expectations in 2026 London projects.

3. London-specific controls that separate “compliant” from “credible”

London projects fail when control plans ignore London reality. Three recurring areas cause programme pain and BSR pushback:

• Zone 1 logistics control: delivery windows, storage constraints, night works, and how these affect quality and inspections.
• TfL / neighbour interfaces: access restrictions, oversailing risks, vibration/noise limits, and interface approvals tracked as evidence.
• High-density access reality: fire appliance access assumptions and emergency route protection maintained during construction.

A credible control plan explicitly shows how London constraints will not degrade safety-critical workmanship. If controls rely on “we’ll manage it”, you are effectively admitting the building will be built under uncontrolled conditions.

4. The control-plan backbone: hold points, evidence and escalation

The BSR does not want promises — it wants a system. A robust control plan typically includes:

• Hold points: defined points where work stops until verification is complete (e.g., fire stopping sign-off before closing-up).
• Inspection & test plans (ITPs): safety-critical checks with acceptance criteria and named signatories.
• Evidence capture: photo records, product batch traceability, installation records, test results, NCR close-out.
• Nonconformance loop: how defects are identified, rectified, re-checked, and evidence filed.
• Escalation routes: what triggers escalation, who decides, and how decisions are recorded for audit.

This is where the Golden Thread becomes real: the control plan defines what data must exist, who owns it, and how it remains auditable.

5. Occupation risk: why control plans must anticipate Gateway 3

Many London HRBs pursue phased completion to protect cash flow and programme. In 2026, that only works if the control plan anticipates the “construction/occupation interface” from day one.

If you intend any form of early occupation, your control plan must align with phased occupation and partial Gateway 3 approval expectations: separation boundaries, life-safety commissioning, interface management, resident protection, and evidence completeness for the occupied phase.

6. A practical 2026 Construction Control Plan checklist (London HRBs)

Governance

✔ Named PD/PC and safety-critical work owners (no “TBC”).
✔ Clear escalation and decision-recording process.
✔ Competence evidence aligned with PD competence expectations.

Fire controls

✔ Façade system definition locked; substitution rules documented.
✔ Fire stopping / cavity barriers: hold points, photo evidence, sign-off route.
✔ Penetrations tracked and re-verified after changes.

Structural & temporary works controls

✔ Temporary works governance and hold points defined.
✔ Sequencing controls prevent unsafe early loading / premature strike.
✔ Anchor drilling / openings: verified zones and rebar clash controls where relevant.

London constraints

✔ Zone 1 logistics controls linked to quality and inspection access.
✔ TfL / neighbour interface approvals tracked as evidence, not assumptions.
✔ Emergency route protection maintained during construction and (if applicable) early occupation.

Evidence & Golden Thread

✔ Evidence structure defined (what is captured, where stored, who owns it).
✔ NCR and remedial loops are auditable (defect → fix → re-check → record).
✔ Decisions and changes are recorded and attributable to named dutyholders.

Key takeaway

In 2026 London HRBs, the BSR is not only assessing whether a design could be safe. It is assessing whether your team can control the build so the design stays safe under real delivery pressure. A Construction Control Plan is the proof. If it’s generic, it’s weak. If it’s specific, evidenced and auditable, it becomes a competitive advantage.

image: constructionmagazine.uk

Expert Verification & Authorship: Mihai Chelmus Founder of London Construction Magazine | Construction Testing & Investigation Specialist | 15+ years in construction, 10+ years delivering projects in London. Writing practical guidance on regulation, compliance and real on-site delivery reality.