The Blueprint for Safety: Building Safety Act
How the Building Safety Act 2022 Has Redefined Compliance for UK Contractors
The UK construction landscape is undergoing its most significant regulatory overhaul in decades. The introduction of the Building Safety Act 2022 (BSA 2022) is not just a tweak to existing rules; it is a fundamental reset that shifts the focus from simple compliance at the point of completion to continuous, demonstrable safety management throughout a building’s entire life cycle.1
For every contractor, sub-contractor, and specialist firm working in the built environment, particularly on higher-risk buildings, understanding this change is no longer optional—it is critical to your ability to operate, secure work, and manage long-term liability.
This guide summarizes the core pillars of the BSA 2022, focusing specifically on what the legislation means for you, the contractor, on the ground: your duties, the golden thread of information, the operational risks, and the clear opportunities that arise from strict adherence.
1. The New Regime: Scope and Statutory Duties
The BSA 2022 imposes its most stringent measures on Higher-Risk Buildings (HRBs), which are defined as buildings that are at least 18 metres tall or have at least 7 stories, and contain at least two residential units, or are classified as hospitals or care homes meeting the height/story criteria.3
The new operational duties, including the Duty Holder Regime, the Golden Thread, and the Gateway Process, came into force on October 1, 2023.5
Your Place in the Duty Holder Regime
The Act formalizes the Duty Holder Regime, which mirrors the roles established under the Construction (Design and Management) Regulations 2015 (CDM).7 Every individual and organisation involved, from the Client down to the lowest-tier sub-contractor (referred to as a ‘Contractor’ under the Act), now has clear, statutory responsibilities to ensure compliance.
For the general contractor or sub-contractor, your duties are focused on three core areas 3:
- Compliance: You must ensure that all building work carried out by you, or by any workers you manage, complies fully with all relevant building requirements.
- Supervision and Instruction: You must provide every worker you are responsible for with appropriate supervision, instructions, and sufficient information.
- Information Provision: You must provide sufficient information about the building work you complete to assist the Client, the Principal Contractor, the Principal Designer, and other contractors in complying with their own duties—a critical contribution to the Golden Thread.
Crucially, the Act mandates a new level of accountability: a contractor must not accept work if they are aware they do not possess the necessary general competency requirements at the time of appointment.8 This shifts accountability for competence verification down the supply chain.
2. The Golden Thread: Your Digital Fingerprint
For contractors, the single most impactful procedural change is the mandate to create, maintain, and hand over the Golden Thread (GT) of information for HRBs.6
The Golden Thread is the building’s “single source of truth” for all key building and fire safety information.9 Its purpose is to ensure that everyone responsible for the building—during design, construction, and occupation—has access to easily accessible, reliable, up-to-date, and accurate information needed to manage safety risks, such as fire spread or structural collapse.9
The Contractor’s Role in the Golden Thread
For the contractor on the ground, the GT requirements transform documentation from a retrospective project task into a continuous, active duty:
- Go Digital: The GT must be kept in an electronic format and capable of electronic transfer.6 This means paper-based records, photos stored on various phones, or siloed spreadsheets are non-compliant.
- Use the System: You are required to use the Client’s secure, digital record-keeping system, which is set up specifically for the GT.3
- Provide Evidence, Not Just Documentation: You must actively work with the Principal Contractor and Principal Designer to keep information updated.3 Your core task is to keep evidence that the actual building work meets the building regulations.3 This goes beyond simply submitting drawings; it includes quality assurance checks, product certifications, installation methods, and commissioning data.
- Version Control: The system tracks every change to the information, clearly showing who made the change and when it occurred.6 This creates an explicit audit trail of responsibility, making it easy to trace any future safety issue back to the original source.
In simple terms: If you complete a fire stopping installation, your contribution to the Golden Thread must prove, digitally and irrefutably, that the installation was done correctly, with the right products, by a competent person, and that this information has been captured securely with a timestamp.
3. Navigating the Gateways
For HRBs, the new Gateway Process introduces three statutory “hard stops” where the Building Safety Regulator (BSR) must approve the project before it can proceed.10
While the Principal Contractor (PC) and Client submit the applications, the quality of your work directly determines whether these gateways are passed:
| Gateway | Phase of Project | Relevance to Subcontractor |
| Gateway 1 | Planning Stage | Ensure early designs (which you may contribute to) meet fire safety standards.4 |
| Gateway 2 | Before Construction Starts | Crucial. This hard stop prevents work until the PC submits a Construction Control Plan and Change Control Log.1 Your work methods and quality assurance systems must align with this approved plan. |
| Gateway 3 | Before Occupation | Final hurdle. The Completion Certificate relies on evidence that the building was constructed exactly according to the approved design.4 If your work deviates or your Golden Thread evidence is incomplete, occupation is unlawful, leading to project delays and penalties.4 |
The BSR scrutinizes not just the design, but the Construction Control Plan detailing how compliance will be managed on site.4 Subcontractors must integrate their own processes—quality checks, competence assessments, and information capture—into the PC’s approved plan.
4. Risks, Opportunities, and Required Actions
The BSA 2022 fundamentally alters the risk-reward profile for contractors. While the duties are demanding, compliance offers a clear competitive advantage.
The Risks: The 30-Year Shadow
The most serious risks stem from the extended legal liability under the Defective Premises Act 1972 (DPA 1972), as amended by the BSA 11:
- Extended Liability: The limitation period for new defective works has been extended to 15 years from completion.11
- Retrospective Cladding Claims: For claims related to cladding products completed before June 28, 2022, an extraordinary 30-year retrospective liability period now applies.11
This means a claim could be filed against your firm for substandard work or materials decades after the project closed. A lapse in quality or information capture today creates a legal risk that could outlive your current contracts.
Furthermore, the Act allows direct claims against manufacturers and suppliers of defective products, circumventing the need for a direct contractual relationship (privity of contract).11 While this may shift some burden off the main contractor, it equally exposes subcontractors and material suppliers to direct legal action if their work or products are the cause of safety defects.
The Opportunity: Competence as a Competitive Edge
The rigorous new standards for competence offer a significant opportunity to professionalize and gain an edge in the market:
- Professional Recognition: The BSR encourages the use of established specifications, such as PAS 8672:2022 for Principal Contractors.12 While this standard applies to the PC, the entire supply chain is expected to demonstrate competence aligned with these high benchmarks. Firms that proactively formalize their internal competence frameworks—demonstrating the Skills, Knowledge, Experience, and Behaviour (SKEB) of their teams—will become the preferred suppliers.
- De-risked Partner Status: Because the Principal Contractor and Client are statutorily responsible for appointing competent duty holders 8, a firm that can easily and robustly evidence its competence and history of digital compliance becomes a low-risk, high-value partner in the supply chain.
- Operational Efficiency: An organized, digital Golden Thread system, though costly to implement initially, ensures consistent quality assurance and drastically reduces the time and expense associated with future maintenance, defect resolution, and dispute management.
Your Required Actions: Compliance Checklist
To ensure your firm is compliant and positioned for the future, you must take these steps:
| Action Area | Requirement for the Contractor/Subcontractor |
| Competence | Immediately review and formalize internal training and certification records for all specialist work. You must be able to verify and evidence the SKEB of your workers upon request.8 |
| Information Management | Mandate the use of the Client/PC’s designated digital Golden Thread platform for all information submission, version control, and change management.6 |
| Record Keeping | Capture comprehensive evidence—not just completion photos—that your work meets the regulations before moving to the next stage. This evidence must be recorded in the GT system.3 |
| Contract Review | Review all contracts and collateral warranties to ensure your professional indemnity (PI) insurance and indemnity clauses align with the new 15- and 30-year statutory liability periods.11 |
| Site Procedures | Fully integrate your quality assurance and compliance monitoring procedures with the Principal Contractor’s Construction Control Plan to ensure project work aligns with the Gateway 2 approval.4 |
The Building Safety Act 2022 is the new reality of UK construction. By viewing the new duties—especially the rigorous demands of the Golden Thread and demonstrated competence—not as bureaucratic burdens but as opportunities for operational excellence, contractors can mitigate long-term risk and establish themselves as leaders in the high-stakes, safety-critical building sector.