Public Policy and Planning

The Building Safety Bill: Occupation phase and the 'Golden Thread'

Building Safety Bill requires creation of a digital trail of information

Who is responsible for the building?   

The accountable person(s) will have over-arching duties to ensure building safety within occupied buildings.  An accountable person is someone who:  

  • Holds legal estate in any part of the common parts; and 
  • A person who is under a repairing obligation in relation to the common parts  

The common parts includes the structure and exterior of the building and parts of the building provided for the use, benefit and enjoyment of the residents of more than one dwelling. 

The principal accountable person is the person who has responsibility for the structure and exterior of the building.  


  • Risk of additional costs impacting ability to meet funding requirements  
  • Risk of non-compliance   
  • Viewing the sector as less attractive for investment or tightening the funding requirements   


  • Different legislation in different countries of the UK.  Impact on business consistency  
  • Complications and challenges of appointing new suitably qualified duty holders with potential increased cost to developments  
  • Level of competencies demonstrated will vary – need to ensure qualification route is also strengthened.  Time for this to flow back into the work force  
  • Each building will have a requirement for over 100 live safety documents that will need to be maintained  
  • Cost of bringing in more “higher-risk buildings” into the Bill.  Impact not just on the Build to Rent sector but on others.   Knock on to the property management side of buildings if they have operators with diverse business models who provide services to other types of accommodation  
  • Possible delays for legislation to be implemented but requirement to prepare systems and processes is needed now  


  • Understanding rights and responsibilities as a resident and how this may differ if you move to or from a higher-risk building   
  • Potential increased rental cost to absorb additional costs to providers  

Building Safety Manager  

The principal accountable person must appoint a competent building safety manager who has day-to-day responsibility for the management of safety and engagement with residents   

Where the building safety manager is an organisation, there must be a nominated individual with responsibility for the building.  They will need to be registered with the Health and Safety Executive (HSE) .


Residents are at the heart of the new building safety regime.  The principal accountable person must have a resident engagement strategy, including a complaints procedure, with ultimate recourse to HSE.  Residents will have powers to request building safety information from the principal accountable person    

Residents will also have duties to allow access to their homes for building safety purposes, and not to do anything within their homes (for example, alternations) which might compromise building safety  

The Golden Thread will be a set of key documents about the building

The Golden Thread  

Under the Bill all “higher-risk buildings” will be required to maintain and update a Golden Thread of information demonstrating that the building complies with building safety requirements. 

The Golden Thread will be a set of key documents about the building, held digitally to be accessible to all duty holders in respect of the building (including any designers, contractors or sub-contractors working on the building). 

Many of these key documents will be created during the design and construction phases and they will include all items required to pass through the Gateways.  

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