Two Years On: How Is the Industry Adapting to the Building Safety Act?

The introduction of the Building Safety Act 2022 marked the most significant reform of building safety regulation in a generation.

Since its implementation in October 2023, the conversation has shifted. The question is no longer what the Act requires, but how well the new system is working in practice.

As part of our ongoing engagement with dutyholders across planning, design and construction, we recently gathered feedback through both a structured survey and a LinkedIn poll. The findings reveal steady progress, but also that clear operational pressures remain.

Why the Building Safety Act was introduced

The Act’s introduction followed the Grenfell Tower tragedy and Dame Judith Hackitt’s review, which identified fragmented accountability, inconsistent competence and weak oversight, particularly in higher-risk residential buildings.

In response, the legislation established clearer statutory dutyholder roles, stronger competence expectations and the concept of a “golden thread” of safety information. At the centre sits the Building Safety Regulator (BSR), overseeing higher-risk buildings and operating the Gateway approval process.

More than a procedural change, the Act represents a cultural shift: responsibility must now be demonstrable, documented and maintained throughout a project’s life.

What has changed in practice?

The Act has reshaped project delivery in several key ways:

• Defined dutyholder roles – Clients, Principal Designers and Principal Contractors now carry explicit statutory responsibilities.
• Gateway 2 and 3 hold points – Formal regulatory approval is required before construction and occupation.
• Enhanced documentation – Greater emphasis on information management, competence and change control.
• Increased scrutiny – Submissions require clearer justification and structured evidence.

The direction of travel is clear: compliance must be proactive and evidenced, not retrospective.

How the industry is finding it two years on

Two years in, the industry has largely moved beyond uncertainty about the legislation itself and is now focused on embedding it and how to deliver it consistently in practice.

Our survey respondents, representing a mix of roles, including Clients, Principal Designers, Designers, Planning professionals, and Principal Contractors, generally reported strong confidence in their understanding of their duties, particularly around planning and monitoring work, competency requirements and coordination responsibilities.

Importantly, experience of Gateway submissions appears to build clarity. Those who had progressed through Gateway 2 and 3 submissions described the requirements as clear and the approval process as mostly manageable. For them, the regime is operational rather than theoretical. By contrast, those yet to undertake a Gateway submission reported only partial clarity, suggesting practical experience remains key to building confidence.

Progress — but not without pressure

While overall understanding is strong, implementation is not without strain. The most commonly cited challenges are:

• Time and resource pressures
• Gathering and structuring required compliance information
• Coordinating multiple designers, contractors and dutyholders
• Evidencing competence across teams
• Navigating Gateway submissions

Importantly, these challenges were typically described as manageable rather than prohibitive, but respondents highlighted that the regulator changes demand significantly more structured preparation and cross-team alignment than previous frameworks.

While the golden thread principle is understood, maintaining disciplined information systems, particularly across complex supply chains, represents a significant operational shift.

Respondents also identified areas where interpretation remains less straightforward, including the interface between CDM and BSA duties, emergency works, Cat B fit-outs and certain higher-risk building scenarios. These grey areas highlight a need for more practical, scenario-based clarity.

Is there enough guidance?

When asked whether sufficient clear guidance is available, most respondents selected “yes, to some extent” rather than “yes, definitely.” That nuance matters.

Many dutyholders shared that they rely on consultants, Building Control and professional networks to supplement formal guidance. Respondents indicated that further support would be beneficial in the form of:

• Practical case studies
• Clearer guidance on grey areas
• Consistent interpretation across regulators
• More accessible communication when updates are introduced

Respondents also highlighted concerns about new changes being introduced without a sufficiently clear explanation. There was also a strong call for collaborative working across the industry, reinforcing that cultural change is still evolving alongside regulatory change.

Building Control’s role within the new regime

Alongside our survey, we ran a LinkedIn poll asking how well professionals understand Building Control’s role under the Building Safety Act. Encouragingly, 77% selected “well” or “very well,” reflecting strong awareness of Building Control’s enhanced role and its interaction with the Building Safety Regulator on higher-risk buildings.

However, the remaining 22% reporting only partial understanding is significant. Given Building Control’s central role in Gateway approvals and compliance oversight, even small clarity gaps can affect programme certainty and submission quality. The priority now is targeted, practical engagement, clearer communication, shared expectations and real-world examples, to ensure understanding is consistent across the sector.

Looking ahead: from adaptation to operational excellence

Two years on, the picture is one of measured progress. The industry understands the intent of the Building Safety Act and broadly supports its objectives. Gateway processes are being navigated with increasing competence, and Building Control’s enhanced role is largely understood.

As reflected in our survey findings, progress now depends less on legislative change and more on operational maturity.

The industry has made significant strides in a relatively short period of time. Our respondents were clear that the focus now should be on embedding best practice, sharing learning and reducing friction in the system so that compliance becomes streamlined rather than burdensome.

In practical terms, this means:

• Standardising information management systems that genuinely support the golden thread and reduce duplication across project teams.
• Resourcing compliance realistically at programme stage, ensuring time and budget reflect the demands of Gateway submissions and regulatory engagement.
• Providing practical, scenario-based guidance on grey areas such as emergency works, Cat B fit-outs and the CDM–BSA interface.
• Improving consistency of interpretation across regulators and projects to reduce uncertainty and programme risk.

Addressing these areas would improve clarity and consistency while reducing cumulative pressure on project teams.

At Harwood, we continue to support clients and project teams in navigating Gateway submissions, clarifying dutyholder responsibilities and strengthening information management processes. As the BSA matures, proactive planning, early regulatory engagement and structured documentation remain the foundations of confident delivery.

The transition is well underway. The opportunity now is to move beyond adaptation and into operational efficiency, ensuring the Building Safety Act works not only in principle, but consistently and effectively in practice.

Are you working under the Building Safety Act? Share your experience and help shape the conversation by completing our short survey here.