What developers, designers and contractors delivering HRBs need to do now.
The Building Safety Regulator (BSR) has published updated GOV.UK guidance on staged building control applications for new Higher-Risk Buildings (HRBs), alongside new industry guidance from the Construction Leadership Council (CLC) covering staged applications and the critical steps between Gateway 2 and Gateway 3.
The updates reflect closer collaboration between the regulator and industry and respond directly to practical challenges currently affecting HRB delivery (including programme sequencing, funding constraints and regulatory bottlenecks) while maintaining the legal requirement for safe, compliant buildings.
Below, we explain what has changed, why it matters, and what project teams should do differently in practice.
What has changed in the BSR guidance
1. Staged applications now apply to single-tower HRBs
BSR has confirmed that staged building control applications at Gateway 2 are now accepted for all new HRBs, including single-tower projects, not just complex multi-tower developments.
For single-tower HRBs, staged applications allow projects to separate:
Stage 1: Groundworks, basements (if applicable), foundations and structure of the ground floor level
Subsequent stages: Construction above ground level
This update is intended to help projects progress in a controlled way while maintaining regulatory oversight.
👉 Important:
BSR reiterates that no work can start on any stage until the building control application for that stage has been approved.
2. Clearer definition of commencement
One of the most significant clarifications relates to the definition of commencement, which differs depending on whether a building is classed as complex or non-complex.
For single-tower HRBs, Stage 1 must include, as a minimum:
- Foundations
- Any basement level
- The structural construction of the ground floor slab or plinth
This definition is critical for:
- Programme planning
- Contractor mobilisation
- Funding drawdowns
- Avoiding unintentional non-compliance
3. Stronger expectations around staged information
The updated GOV.UK guidance also reinforces what information must be prepared and submitted for each stage of a staged application, including:
- Stage-specific design information
- Clear staged work statements
- Partial completion strategies (where applicable)
- Change control arrangements aligned with the golden thread
BSR assesses staged applications case by case, and approval timelines depend heavily on the quality and clarity of the information submitted.
New CLC guidance on Gateway 2 to Gateway 3
Alongside the BSR updates, the Construction Leadership Council (CLC) has published new practical guidance developed in partnership with BSR, focusing on:
- Staged applications: approach and baseline information
- Gateway 2 to Gateway 3: key steps for dutyholders during construction
- Maintaining the golden thread of information
- Progressive assurance, rather than retrospective evidence gathering
- Preparing early for a smooth Completion Certificate application
The CLC guidance makes clear that Gateway 3 success is determined by decisions and behaviours established from Gateway 2 onwards, not at the end of the build.
What project teams should do now
For clients and developers
- Decide early whether a staged application strategy is appropriate
- Align funders, programme milestones and procurement with Gateway approvals
- Ensure dutyholders are resourced to manage evidence-led compliance, not post-completion fixes
For principal designers
- Prepare stage-specific, submission-ready design information
- Coordinate structure, fire and compliance narratives early
- Avoid design deferrals that create Gateway 3 risk
For principal contractors
- Embed golden thread evidence capture into site processes from day one
- Maintain a live change control log
- Treat Gateway 3 as a continuous process, not a final hurdle
For the supply chain
Expect increased scrutiny of:
- Product data and certification
- Installation records
- Competence evidence
- Delays or gaps now directly affect approval and occupation timelines
Why this matters
The updated BSR and CLC guidance is designed to:
- Improve the quality of applications
- Reduce avoidable delays
- Increase confidence for investors and funders
- Support the delivery of safe, compliant and occupiable HRBs
Staged applications are now a formal regulatory route, not an informal workaround, but they only function where projects respect sequencing, approval points and information requirements.
Stay informed: BSR eBulletin
BSR publishes a free monthly eBulletin providing updates on:
- New and updated GOV.UK guidance
- Regulatory changes
- Articles and campaign material relevant to HRBs
HSE BSR eBulletin service here: https://public.govdelivery.com/accounts/UKHSE/signup/15087
Industry professionals can subscribe via the HSE BSR eBulletin service to stay informed of future updates.
Key takeaway
Staged applications offer flexibility, not reduced scrutiny.
Projects that succeed under the updated regime will be those that:
- Plan staged submissions properly
- Maintain a live golden thread throughout construction
- Treat Gateway 2 to Gateway 3 as a continuous compliance journey
For teams delivering Higher-Risk Buildings in London and across England, this guidance is now essential operational reading, not background policy.
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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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