Introduction
Fire strategy failure is now the single most common trigger for Gateway 2 rejection on London Higher-Risk Buildings. In 2026, the Building Safety Regulator (BSR) is no longer assessing whether a fire strategy is theoretically compliant; it is assessing whether it is buildable, evidenced, coordinated and enforceable at the point of construction.
Across London, Gateway 2 submissions are being rejected not because teams ignored fire safety, but because strategies rely on assumptions, future design development, or generic narratives that collapse under regulatory scrutiny. The BSR’s position is clear: a fire strategy must function as a construction-ready safety control document, not a planning-stage intent statement.
1. Fire Strategy Is Treated as Indicative, Not Frozen
Fire strategy failure is now the single most common trigger for Gateway 2 rejection on London Higher-Risk Buildings. In 2026, the Building Safety Regulator (BSR) is no longer assessing whether a fire strategy is theoretically compliant; it is assessing whether it is buildable, evidenced, coordinated and enforceable at the point of construction.
Across London, Gateway 2 submissions are being rejected not because teams ignored fire safety, but because strategies rely on assumptions, future design development, or generic narratives that collapse under regulatory scrutiny. The BSR’s position is clear: a fire strategy must function as a construction-ready safety control document, not a planning-stage intent statement.
1. Fire Strategy Is Treated as Indicative, Not Frozen
The Failure
Many London Gateway 2 submissions still present fire strategies that depend on future coordination:
- Final compartmentation to be confirmed
- Smoke control zones subject to MEP coordination
- Evacuation strategy to be validated at later stage
Why the BSR Rejects It
Gateway 2 is a hard stop. The regulator expects a frozen design that demonstrates compliance without reliance on later clarification. Any element of the fire strategy that is not fixed introduces unacceptable safety uncertainty.
In dense London sites, where late-stage changes are common, the BSR now assumes that unfixed fire design equals unmanaged risk.
2. Inadequate Evidence for Performance-Based Fire Engineering
The Failure
Performance-based solutions are widely used in London, but often submitted with:
Why the BSR Rejects It
The BSR accepts performance-based design only where evidence is explicit, traceable, and scenario-tested. Generic statements or precedent-based arguments are no longer sufficient. For London HRBs, the regulator expects:
3. Fire Strategy Not Aligned with Structural Design Logic
Performance-based solutions are widely used in London, but often submitted with:
- High-level justifications
- Reference to standards without project-specific modelling
- Unsupported evacuation time assumptions
Why the BSR Rejects It
The BSR accepts performance-based design only where evidence is explicit, traceable, and scenario-tested. Generic statements or precedent-based arguments are no longer sufficient. For London HRBs, the regulator expects:
- Clear fire scenarios linked to building layout
- Modelling outputs referenced directly in the strategy
- Explicit explanation of why a performance solution is safer than prescriptive compliance
3. Fire Strategy Not Aligned with Structural Design Logic
The Failure
A recurring rejection trigger is misalignment between:
Why the BSR Rejects It
Fire and structural safety are treated as interdependent systems, not parallel disciplines. If a fire strategy relies on assumptions that conflict with structural design or ignores construction-stage vulnerability the submission fails the demonstrable control test.
This issue is particularly acute on London projects involving:
4. Evacuation Strategy Not Grounded in London Reality
A recurring rejection trigger is misalignment between:
- Fire compartmentation and structural grids
- Load paths and fire resistance assumptions
- Structural fire protection and construction sequencing
Why the BSR Rejects It
Fire and structural safety are treated as interdependent systems, not parallel disciplines. If a fire strategy relies on assumptions that conflict with structural design or ignores construction-stage vulnerability the submission fails the demonstrable control test.
This issue is particularly acute on London projects involving:
- Transfer structures
- Legacy concrete frames
- Complex temporary works
4. Evacuation Strategy Not Grounded in London Reality
The Failure
Evacuation strategies frequently fail because they assume:
Why the BSR Rejects It
London HRBs operate in constrained, occupied, and mixed-use environments. The BSR now actively tests evacuation logic against real conditions, including:
Evacuation strategies frequently fail because they assume:
- Ideal fire appliance access
- Simplified resident behaviour
- Generic travel distances that ignore site constraints
Why the BSR Rejects It
London HRBs operate in constrained, occupied, and mixed-use environments. The BSR now actively tests evacuation logic against real conditions, including:
- Narrow streets and restricted appliance access
- Mixed tenure occupancy
- Phased occupation scenarios
If the evacuation strategy works only in an idealised model, it will not pass Gateway 2.
5. Poor Coordination Between Fire Strategy and Other Gateway Documents
The Failure
Common administrative and coordination issues include:
Why the BSR Rejects It
Gateway 2 submissions are reviewed as a single safety case, not a bundle of standalone documents. Any inconsistency undermines confidence in dutyholder control and data governance. The regulator increasingly treats coordination failures as evidence of weak competence and poor Golden Thread readiness.
6. Dutyholder Accountability Not Explicitly Embedded
Common administrative and coordination issues include:
- Inconsistent terminology between documents
- Fire strategy drawings not matching architectural layouts
- MEP assumptions that conflict with smoke control logic
Why the BSR Rejects It
Gateway 2 submissions are reviewed as a single safety case, not a bundle of standalone documents. Any inconsistency undermines confidence in dutyholder control and data governance. The regulator increasingly treats coordination failures as evidence of weak competence and poor Golden Thread readiness.
6. Dutyholder Accountability Not Explicitly Embedded
The Failure
Fire strategies often fail to clearly identify:
Why the BSR Rejects It
The Building Safety Act regime is accountability-driven. A fire strategy without named responsibility, governance routes, and change control mechanisms is considered unenforceable. In 2026, the BSR assumes that unowned risk becomes unmanaged risk.
What This Means for London Projects in 2026
Fire strategy rejection at Gateway 2 is no longer an isolated technical issue, it is a programme, liability and commercial risk. Failed submissions can:
For London HRBs, the fire strategy is now the regulatory linchpin of Gateway 2 approval.
How This Connects to Wider 2026 Compliance Risk
Fire strategy failures rarely exist in isolation. They are closely linked to:
Fire strategies often fail to clearly identify:
- Who owns ongoing fire safety risk
- Who validates changes during construction
- How deviations are controlled and recorded
Why the BSR Rejects It
The Building Safety Act regime is accountability-driven. A fire strategy without named responsibility, governance routes, and change control mechanisms is considered unenforceable. In 2026, the BSR assumes that unowned risk becomes unmanaged risk.
What This Means for London Projects in 2026
Fire strategy rejection at Gateway 2 is no longer an isolated technical issue, it is a programme, liability and commercial risk. Failed submissions can:
- Delay construction by months
- Invalidate procurement strategies
- Trigger redesign and consultant reappointment
- Increase professional indemnity exposure
For London HRBs, the fire strategy is now the regulatory linchpin of Gateway 2 approval.
How This Connects to Wider 2026 Compliance Risk
Fire strategy failures rarely exist in isolation. They are closely linked to:
- Gateway 2 evidence thresholds
- Structural design substantiation
- Temporary works oversight
- Façade fire performance and product liability
- Phased occupation and Gateway 3 conditions
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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.
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