The Building Safety Regulator is changing how it assesses occupied higher-risk buildings, but the standard expected of dutyholders has not reduced. The organisations best placed to respond will be those that can connect competent people, reliable information and everyday decision-making to demonstrate that risks are controlled in practice.
A reset of assessment, not a reset of responsibility
In July 2026, the Building Safety Regulator announced a Building Assessment Certificate Foundation Plan to make the assessment of occupied higher-risk buildings more proportionate, targeted and intelligence-led. The regulator said that nearly 2,000 buildings had been directed to apply since the process began in April 2024, that assessment times were around twice those originally expected and that 66% of applications assessed in 2026 had been refused.
The reason for refusal is as important as the figure itself. The BSR identified that many applications described processes, policies and procedures but did not provide sufficient assurance that fire spread and structural safety risks were being managed effectively in practice.
The new approach will pause widespread call-ins while existing cases are progressed and revised processes are developed. It will give greater attention to risk, intelligence and organisations responsible for multiple higher-risk buildings, with targeted or sample-based interventions and additional support for resident-led principal accountable persons.
This is not a lowering of the bar. The continuing legal duties of Principal Accountable Persons and Accountable Persons remain in place. A building may not be called forward immediately, but its dutyholders must still be ready to explain what could go wrong, what controls are in place, how those controls are monitored and what evidence supports that judgement.
Competence is the link between information and safety
A strong safety case cannot be produced by assembling reports shortly before an assessment. It depends on people who understand the building, can evaluate the quality and limits of technical advice, recognise when information conflicts, and make proportionate decisions in response.
BSR guidance states that PAPs and APs must either possess the relevant competence or appoint competent people to assist them. For individuals, this means the appropriate skills, knowledge, experience and behaviours. For organisations, it means organisational capability: suitable policies, procedures, systems and resources, supported by clear accountability and effective oversight.
Appointment is not the end of the competence duty. PAPs and APs remain accountable and should continually monitor the competence and capacity of those they appoint. This requires an intelligent-customer capability within the organisation: enough knowledge to specify what is required, test whether advice is sound, integrate different disciplines and challenge work that does not answer the building’s real risk questions.
Competence must also be matched to the task and the building. A professional may be highly capable in one discipline or building type without having the experience needed for a complex high-rise residential building. Organisations therefore need to assess competence at the point of appointment, define any limitations, provide sufficient information and resources, and review performance as the building, risk profile and work programme change.
The 2026 Industry Task and Finish Group guidance on managing competence reinforces this point. Effective competence management is not simply a record of qualifications or completed training. It requires organisations to define the competence needed for roles and activities, assess and verify it, and ensure that it is monitored and maintained over time within a supportive culture and adequately resourced system.
The golden thread is a management system not an archive
The golden thread is often treated as a digital filing exercise. That misses its purpose. The legal framework requires prescribed building information to be kept, obtained where reasonably practicable, maintained and shared. BSR guidance describes information that is digital, secure, available when needed, usable, accessible and capable of acting as the building’s single source of truth.
A collection of documents is not a golden thread if users cannot tell which version is current, how one record relates to another or what decision followed from it. Nor is it effective if the information is technically complete but inaccessible to those managing work, responding to an incident or engaging with residents.
A functioning golden thread should help a competent person answer four practical questions:
- What do we know? The building’s construction, systems, hazards, dependencies, inspection findings and control measures are recorded clearly.
- How reliable is it? The provenance, status, assumptions, limitations and version of important information can be understood.
- What has changed? Alterations, maintenance, incidents, resident information and emerging risks trigger controlled updates across relevant records.
- What did we do? Decisions, actions, responsible owners, completion evidence and assurance checks can be traced from the original issue to a verified outcome.
Competence and the golden thread reinforce each other
Competent people create, interpret and challenge good information. Good information, in turn, enables people to make competent decisions. When either side is weak, the safety case becomes fragile.
Common warning signs include fire strategies or drawings that no longer reflect the building; risk assessments that are stored but not connected to actions; inconsistent building descriptions across reports; recommendations closed without evidence of completion; and work commissioned without a clear information handover requirement. These are not simply document-control problems. They often reveal unclear ownership, weak commissioning, insufficient technical challenge or poor organisational learning.
The connection is particularly important during refurbishment and maintenance. A seemingly minor change can affect compartmentation, means of escape, smoke control, structural loading or the assumptions underpinning the safety case. Competent change control should identify the relevant risk before work begins, ensure the design and installation are properly coordinated, verify the completed work and update the golden thread without delay.
From building files to portfolio capability
The BSR’s intention to use risk intelligence, sample interventions and an initial focus on organisations with multiple higher-risk buildings changes the assurance question. A weakness found in one building may indicate a wider issue in governance, procurement, competence management or information control across a portfolio.
Multi-building dutyholders should therefore combine consistent organisational controls with building-specific evidence. A central policy or software platform can provide a useful framework, but it cannot replace an accurate understanding of each building. Equally, excellent reports for individual buildings will not compensate for unclear executive accountability, inadequate resources or inconsistent follow-through.
What PAPs and APs should prioritise now
The pause in widespread BAC call-ins creates an opportunity to improve the system that produces the evidence, rather than waiting to polish an application. Six priorities stand out:
- Clarify accountability. Map PAP, AP, Responsible Person, managing-agent and contractor interfaces, including who owns each decision, record and action.
- Test competence and capacity. Use role and task-based competence criteria, verify evidence at appointment and monitor whether resources remain sufficient.
- Set information requirements. Define what must be created, approved, stored, updated and shared, by whom and at what point in the building lifecycle.
- Reconcile critical information. Resolve inconsistencies between plans, fire strategies, structural information, surveys, inspection records and the physical building.
- Connect evidence to control. Ensure every significant finding leads to a proportionate decision, named owner, timescale, completion record and effectiveness check.
- Assure the whole system. Use audits, inspections, performance indicators, resident feedback, occurrence reporting and management review to test whether arrangements work in practice.
Demonstrating control rather than describing process
The direction of travel is clear. Dutyholders will need more than compliant-looking documentation. They must be able to show that competent people use reliable, current information to manage risks, learn from change and maintain control over time.
That is the real value of the golden thread. It is not the end product of building safety management; it is the evidence base and communication system that makes good management possible. Competence gives that information meaning, while governance ensures that the resulting decisions are implemented and checked.
Organisations that build these elements into business-as-usual management will be better prepared for a BAC assessment, a targeted BSR intervention or an emergency. More importantly, they will be better able to provide residents with credible assurance that their building is being understood and managed safely.
How Tetra can help
Tetra supports PAPs, APs and managing organisations to move from fragmented compliance activity to coherent, evidence-led building safety management. This can include building safety gap analysis, competence and governance reviews, safety case and Safety Case Report support, golden thread information review, risk assurance, resident engagement and practical preparation for regulatory scrutiny.
Building Safety Readiness Review
As the BSR publishes its revised guidance and assessment approach, Tetra will offer a Building Safety Readiness Review for occupied higher-risk buildings.
For many organisations, it may now be several years since the safety case and Safety Case Report were first developed. Since then, buildings may have changed, further assessments completed, actions closed, new risks identified and the golden thread expanded. The BSR’s approach to assurance is also continuing to develop.
Our Readiness Review will provide an independent, proportionate assessment of:
- the current safety case and whether it still reflects how building safety risks are being managed in practice;
- the Safety Case Report and whether it remains current, coherent and supported by appropriate evidence;
- the quality, consistency and accessibility of the golden thread information underpinning the safety case;
- whether significant changes, assessments, works, incidents and completed actions have been properly incorporated;
- gaps, inconsistencies or outdated assumptions that should be addressed; and
- readiness to respond to a future Building Assessment Certificate assessment or targeted BSR intervention.
The purpose is not necessarily to rewrite an existing Safety Case Report. It is to determine whether it remains fit for purpose and identify proportionate updates where required, taking account of the BSR’s revised guidance once published.
Our focus is not simply on producing documents. It is on helping clients demonstrate that competent people are using reliable, current information to understand their buildings, manage risk and maintain control over time.