Building Safety Act Duties for Freeholders: 2026 Update

A July 2026 update on AP and PAP duties, registration, safety case reports, the golden thread and Part 4 enforcement for occupied higher-risk residential buildings.

Regulatory UpdateJuly 2026Building Safety
Overview

The new regulatory landscape

The Building Safety Act 2022 represents the most significant reform of building safety regulation in a generation. For freeholders and building owners of higher-risk residential buildings, the Act introduces mandatory registration, ongoing safety management obligations, and the requirement to maintain a golden thread of building information. Non-compliance carries serious penalties including criminal prosecution.

Registration with the Building Safety Regulator

An occupied higher-risk residential building must be registered with the Building Safety Regulator (BSR) before occupation. The principal accountable person (PAP) registers the building and keeps registration and key building information current. On 27 January 2026 BSR moved from HSE to a standalone executive non-departmental public body sponsored by MHCLG.

The safety case report

The PAP prepares and keeps the safety case report up to date. It summarises the fire-spread and structural-failure risk assessments carried out by each accountable person (AP), and the steps each AP takes in the parts for which it is responsible. The PAP sends the report to BSR when BSR directs it to apply for a building assessment certificate or whenever BSR asks for a copy.

The golden thread

APs and the PAP must keep and manage relevant building information as an accurate, accessible and up-to-date digital golden thread. This includes the original design and construction information, records of all subsequent building works, fire risk assessments, fire compartmentation surveys, maintenance records, and the safety case report itself. The information must be stored digitally, kept up to date, and made available to the BSR on request.

Resident engagement

The PAP prepares, reviews and acts in accordance with the resident engagement strategy and operates the building-safety complaints system. Other APs cooperate on the strategy and distribute its current version to residents in the parts for which they are responsible. Prescribed building-safety information must be shared in accordance with the regulations.

Compliance Steps

Key actions for freeholders

Register the building

Confirm the occupied-building scope and identify the PAP. The PAP must register the building before occupation and keep the required registration and key building information current.

Identify the accountable person

Identify every organisation or individual that owns, or has a legal obligation to repair, any common part. If there is more than one AP, identify the PAP responsible for the structure and exterior.

Prepare the safety case

The PAP should assemble the building-specific report. Each AP must assess and manage risks in its own part and supply the PAP with relevant evidence; commission competent specialist input where the building and evidence gaps require it.

Establish the golden thread

Collate all existing building safety information into a digital format. Implement systems to ensure ongoing maintenance and building works are recorded and the information kept current.

FAQ

Frequently asked questions

Which buildings fall under the higher-risk regime?

Residential buildings at least 18 metres or 7 storeys high with at least two residential units. This includes purpose-built flats, converted houses with flats, and mixed-use buildings with residential above the threshold.

What is the golden thread of building information?

A requirement to maintain accurate, up-to-date digital records of all building safety information, including design, construction, maintenance and safety management records, accessible to the BSR on request.

What is an accountable person?

An organisation or individual that owns, or has a legal obligation to repair, any common part of the occupied higher-risk building. Each AP assesses and manages building-safety risks in the parts for which it is responsible; the PAP prepares the safety case report.

What are the penalties for non-compliance?

Under Part 4 BSR can issue a compliance notice, designate it an urgent action notice where a contravention creates imminent danger, prosecute applicable offences and apply to the First-tier Tribunal for a special measures order. The statutory consequences depend on the provision and the facts.

Source context

Primary sources and further reading

Links checked 18 July 2026. These primary sources provide general context; a competent specialist should confirm how the guidance applies to the building concerned.

About the author

Savas Bulduk

BSc (Hons) MRICS, Director & Chartered Building Surveyor.

Writes on Building surveying, Fire safety and facade, External wall systems, Technical due diligence, Contract administration. See the full team profile.

BSc (Hons) MRICS