Structural Design Evidence the BSR Now Expects at Gateway 2

Status 2026 Regulatory Update
Regulator Building Safety Regulator (BSR)
Applicability London Higher-Risk Buildings (HRBs) – Design & Pre-Construction
Compliance Window Active (Immediate Application)
Introduction

Gateway 2 is no longer a planning checkpoint; it is a technical approval gate where the Building Safety Regulator expects structural safety to be fully demonstrated, not described in principle.

In 2026, London HRB submissions are routinely delayed or rejected where structural design evidence lacks clarity, traceability, or coordination with fire and construction-stage risks. The regulator is no longer accepting assumptions, outline strategies, or deferred justification. Structural intent must be fixed, justified and auditable at the point of submission.

This guidance sets out what the BSR now expects to see as minimum structural evidence at Gateway 2 for London projects.

1. What Has Changed at Gateway 2 for Structural Design

The most significant shift is that Gateway 2 now tests control, not competence in isolation. The BSR expects structural submissions to demonstrate:
  • A materially complete structural design
  • Explicit consideration of construction-stage and temporary conditions
  • Clear alignment between structure, fire strategy, and occupation assumptions
  • Evidence that residual structural risks are identified and controlled

This is particularly critical on London HRBs, where dense surroundings, party wall interfaces and constrained access amplify structural risk.

2. The Structural Evidence the BSR Now Expects to See
 
Fixed Structural Design (Not Outline)

Structural information must extend beyond load paths and sizing. The regulator expects:
  • Defined structural systems (primary and secondary)
  • Confirmed stability strategy
  • Explicit load transfer logic, including robustness provisions
  • No reliance on design development to resolve safety-critical elements

Outline schemes or reserved matters language are now a frequent cause of rejection.

Construction-Stage Structural Risk

One of the most common Gateway 2 failures in London is the absence of construction-stage structural logic. The BSR expects evidence that:
  • Temporary works requirements are identified
  • Stability during demolition, alteration or partial retention is addressed
  • Sequencing risks adjacent to occupied assets are understood

If construction-stage risk is not explicitly discussed, the submission is considered incomplete.

Interface with Fire Strategy

Structural design cannot be assessed in isolation. The BSR expects alignment between:
  • Structural fire resistance assumptions
  • Fire compartmentation and loadbearing elements
  • Progressive collapse mitigation in fire scenarios

Where fire strategy assumptions contradict structural logic, Gateway 2 approval is unlikely.

👉 This issue frequently overlaps with the failures outlined in
Fire Strategy Failures at Gateway 2: Common Causes of Rejection on London HRBs, and both documents should be read together when preparing a compliant submission.

3. London-Specific Structural Constraints the BSR Scrutinises

For London HRBs, the regulator applies heightened scrutiny to:
  • Party wall and shared structure interfaces
  • Proximity to TfL assets and third-party infrastructure
  • Legacy concrete frames and retained elements
  • Structural interventions within occupied buildings

Generic UK structural narratives routinely fail when these London realities are not explicitly acknowledged.

4. Evidence Format Matters

The BSR is not only assessing what is provided, but how it is presented. Successful Gateway 2 submissions typically include:
  • Clear, indexed structural design reports
  • Explicit cross-referencing to drawings and calculations
  • Plain-language explanation of safety-critical decisions
  • Demonstrable coordination with fire and architectural strategies

Ambiguous reports or overly academic submissions increase rejection risk.

5. Gateway 2 Programme Risk for London Projects

Structural rejection at Gateway 2 does not result in partial approval. A failed submission can:
  • Delay construction start by several months
  • Invalidate procurement and sequencing assumptions
  • Trigger commercial exposure and contractual risk

In 2026, Gateway 2 structural compliance is a programme-critical milestone, not a formality.

How This Fits Within the Wider 2026 Regulatory Landscape

Structural evidence at Gateway 2 does not operate in isolation. It sits alongside:
  • Fire strategy maturity requirements
  • Phased occupation and Gateway 3 constraints
  • Competence obligations for Principal Designers
  • Product liability exposure under the Single Construction Regulator
  • Increasing scrutiny of legacy structure remediation

Together, these changes signal a regulatory environment where structural safety must be proven, not inferred.
 
image: constructionmagazine.uk
Mihai Chelmus, founder of London Construction Magazine
Expert Verification & Authorship:
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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