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Temporary Works Oversight Under the Building Safety Regime: London Implications

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

Temporary works have moved from a construction management concern to a regulatory risk under the Building Safety Regime. For London projects entering Gateway 2 in 2026, the Building Safety Regulator (BSR) increasingly expects evidence that temporary conditions have been identified, assessed and controlled as part of the overall safety case.

Where temporary works are treated as a contractor-only issue or deferred until post-approval, submissions are now being challenged. This is particularly true on London Higher-Risk Buildings (HRBs), where demolition, retention, constrained sites and occupied neighbours introduce stability risks long before permanent works are complete.

In London HRB submissions entering Gateway 2 in 2026, the Building Safety Regulator (BSR) increasingly expects temporary works to be acknowledged as part of the overall safety case, not treated as a post-approval construction detail. 

Submissions are now scrutinised for evidence that temporary stability-critical stages have been identified, that assumptions used during sequencing do not undermine permanent structural logic, and that interfaces with demolition, retention, fire strategy and adjacent assets are understood. 

Where temporary works are deferred entirely to contractor method statements, Gateway 2 approvals are more likely to be delayed or challenged, particularly on constrained London sites with third-party risk exposure.

1. Why Temporary Works Now Matter at Gateway 2

The BSR no longer assesses design safety in isolation from how a building will be constructed. At Gateway 2, the regulator expects confidence that:
  • Structural stability is maintained throughout construction
  • Temporary conditions do not introduce uncontrolled collapse risk
  • Interfaces with adjacent buildings and infrastructure are understood
  • Safety assumptions used in the permanent design remain valid during build-out

This reflects the regulator’s shift from theoretical compliance to delivery assurance.

2. Common Temporary Works Failures Seen by the BSR

Based on emerging enforcement patterns, the following issues are now routinely flagged:
 
Temporary Stability Not Defined

Submissions that describe the permanent structure only, without explaining how stability is achieved during sequencing, are considered incomplete. This is particularly critical where:
  • Load paths change during construction
  • Elements are installed out of final order
  • Propping or restraint is required temporarily
  • Demolition and Alteration Risks Ignored

On London sites involving partial demolition or retained structures, the BSR expects clarity on how residual elements remain stable during removal and modification works. Generic references to method statements are no longer sufficient.

Misalignment with Structural Design Evidence

Temporary works assumptions must align with the fixed structural design presented at Gateway 2. Where temporary conditions contradict the permanent stability strategy, the submission loses credibility.

👉 This issue directly connects with the requirements outlined in 
Structural Design Evidence the BSR Now Expects at Gateway 2, which sets out the expectation for auditable, fixed design logic at submission stage.
 
3. Fire Strategy and Temporary Works Are Not Separate

A frequent London failure point is the separation of fire strategy from temporary conditions. The BSR expects confirmation that:
  • Temporary layouts do not compromise fire separation
  • Temporary access routes do not invalidate evacuation assumptions
  • Structural fire resistance assumptions remain valid during phased works

Where temporary works alter compartmentation, escape routes, or structural fire performance, these impacts must be acknowledged and controlled.

👉 This overlap is a common cause of rejection, as explained in 
 
4. London-Specific Temporary Works Risks

Temporary works oversight is scrutinised more closely on London HRBs due to:
  • Party wall interfaces and shared structures
  • Proximity to TfL assets and third-party infrastructure
  • Limited working space and constrained logistics
  • Construction adjacent to occupied buildings

In these conditions, temporary instability is not hypothetical, it presents real public risk, which the regulator expects to be addressed early.

5. What the BSR Expects to See at Gateway 2

Successful submissions typically demonstrate:
  • Identification of temporary stability-critical stages
  • Clear assumptions documented in the structural design narrative
  • Alignment between permanent design, fire strategy, and construction sequencing
  • Evidence that temporary works are considered part of the safety case, not an afterthought

This does not require full temporary works design at Gateway 2, but it does require regulatory awareness and control logic.

6. Programme and Liability Implications

Failure to address temporary works at Gateway 2 can:
  • Delay approval and construction start
  • Trigger redesign late in the programme
  • Increase liability exposure for dutyholders
  • Undermine confidence in the overall safety case

In 2026, temporary works oversight is no longer optional, it is part of demonstrating competence and control.

How This Fits the Wider 2026 Regulatory Landscape

Temporary works oversight now sits alongside:
  • Gateway 2 structural evidence requirements
  • Fire strategy maturity expectations
  • Phased occupation constraints at Gateway 3
  • Competence obligations for Principal Designers
  • Enhanced scrutiny of London HRB delivery risk

Together, these changes reinforce a single message: safety must be demonstrable at every stage, not just at completion.

*London Construction Magazine provides independent editorial analysis of regulatory enforcement trends affecting London’s higher-risk buildings.
 
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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