15th December 2025
“Gateway 2 under the Building Safety Act marks a fundamental shift in how higher-risk building projects must be designed and presented. The Building Safety Regulator (BSR)[1] now expects you to present a fully resolved, technically robust and demonstrably compliant design before you can begin construction, bringing an end to the long-established practice of developing safety-critical elements during the build.”
Recent Construction Leadership Council (CLC) guidance, together with rising numbers of BSR information requests and rejections, confirms that you must front-load design detail, supporting evidence and coordination to avoid your projects being delayed.
This article outlines the regulator’s expectations, highlights the pitfalls most commonly leading to rejection or delay, and shares our practical advice to make sure your Gateway 2 submissions meet the required “sufficient level of detail”.
Gateway 2 is not just a technical check; it is a regulatory permission point. The regulator now expects risks to be designed out before you begin construction, rather than addressed reactively on site. This places significant emphasis on the completeness, coherence and auditability of the design at the point of submission. Every request for information from the BSR can add weeks to the programme, and delays often arise from unclear or incomplete submissions rather than from any inherent design flaw.
If you’re under pressure to meet contractual dates, you may be tempted to submit your design prematurely. However, this can trigger prolonged clarification rounds. Against this backdrop, it’s crucial to understand what the regulator actually means by “sufficient detail” at Gateway 2.
It’s particularly important to understand what the regulator means by a “sufficient level of detail”. Although the CLC has confirmed that you do not always need to specify final products or provide fully completed construction drawings, your design must nonetheless reach a point where compliance with the Building Regulations can be confidently confirmed.
In practice, this creates a distinction between the minimum threshold described by the CLC and the best-practice standard that consistently results in timely approvals.
The following sets out what that best-practice standard looks like and how it aligns with the BSR’s published reasons for rejection.
While the CLC recognises that detailed product selection isn’t always essential, the BSR continues to reject submissions that rely on conceptual sketches, incomplete “contractor design portions”, placeholders such as “TBC”, or generic labels like “non-combustible insulation”.
A best-practice submission therefore presents a technically resolved design, broadly equivalent to RIBA Stage 4, in which all life-safety-critical elements are properly developed and coordinated. You need to include clear general arrangements, elevations, sections and junction details that show how interfaces work in practice, together with sufficiently detailed specifications for fire-stopping, cavity barriers, penetrations, means of escape and structural fixings.
Even where final products have not yet been selected, the design should still be accompanied by an appropriate level of technical justification – such as structural calculations, fire and smoke modelling, or thermal analysis where relevant – to demonstrate that the proposed approach is capable of complying with the Building Regulations (BR).
In short, the design and supporting information must together reach a point where the regulator can confirm compliance with confidence, without needing to rely on later design development or unresolved assumptions.
The regulator expects evidence that corresponds precisely with the proposed design and the building in question. Generic brochures or mismatched test data are frequently rejected.
You need to make sure that all fire classifications, test reports (including BS 8414 where relevant) and technical assessments align with the build-up illustrated in the drawings and are clearly signposted so the compliance narrative is unmistakable.
The Construction Control Plan is central to the application. You must explain how works will be sequenced and managed, how resident and worker safety will be maintained, and how installation of safety-critical elements – such as cavity barriers and fire-stopping – will be inspected and recorded, often with photographic evidence.
Where residents remain in situ, the CCP should also set out the interim fire safety and emergency arrangements.
Your submission must evidence the competence of all dutyholders. This includes the formal declarations required from the Principal Designer and Principal Contractor, together with supporting information demonstrating the competence of fire engineers, façade specialists and other key contributors.
A project-specific dutyholder matrix should clearly show who is responsible for what, and how oversight and challenge have been built into the design process.
Many rejected submissions suffer not from technical failings but from presentation issues – they’re hard to navigate, poorly indexed or padded with large amounts of irrelevant material.
You need to make sure your Gateway 2 application is coherent, easy to follow and tightly focused on Building Regulations compliance. The regulator must be able to locate and verify key information without unnecessary cross-referencing or interpretation.
The issues below most frequently lead the BSR to reject or delay Gateway 2 submissions, and they appear consistently across published regulator guidance, industry feedback and observed practice.
The BSR is rejecting statements such as: “We will comply with Building Regulations.”, “Final products to be selected.” and “Details to follow post-approval.”
Fix: Demonstrate how the submission complies with BR requirements through drawings, specifications and evidence.
Applicants often submit drawings without a narrative tying them to the relevant regulatory requirements.
Fix: Provide a concise compliance statement explaining precisely how the proposed design satisfies each relevant part of the Building Regulations.
A frequent sticking point is inadequate justification of the existing structure, particularly for recladding or increased loading.
Fix: Include structural calculations, load paths and a clear statement confirming adequacy of the existing structure.
Some applications contain multiple inconsistent versions of documents, poorly structured files and/or mixed content from other projects (copy-paste errors). This forces the regulator to “decipher what has not been said.”
Fix: Ensure a single, accurate and consistent document set with strict version control.
Submissions sometimes contain cosmetic or marketing materials unrelated to Building Regulation compliance.
Fix: Include only relevant, appropriate information and signpost it clearly.
A significant proportion of submissions are made prematurely due to programme pressure or contractual obligations.
Fix: Gate submissions internally – no Gateway 2 filing until an independent reviewer confirms readiness.
Where different parties prepare packages, the submission lacks coherence.
Fix: Require the Principle Designer (PD) or an independent reviewer to ensure the entire design “hangs together” end-to-end.
Gateway 2 represents a fundamental shift in how you must prepare and present projects. Successful applications are those that offer a frozen, technically resolved design, supported by a clear and auditable narrative demonstrating precisely how the proposal complies with the Building Regulations.
You should include building-specific evidence, present information in a way that is clear, concise and coherent, and set out robust construction controls together with transparent dutyholder competence. Crucially, strong submissions also benefit from an independent pre-submission review, ensuring the information is complete, consistent and ready for regulatory scrutiny.
With careful preparation, disciplined organisation and early challenge of design assumptions, Gateway 2 approval becomes a predictable regulatory milestone rather than a risk to your programme.
If you have any questions about the Building Safety Act or need support to submit a successful Gateway 2 application, please contact Inam Hasan.
[1] The BSR is due to transition from within the HSE to a standalone public body in January 2026; this structural change does not affect its Gateway 2 functions or expectations.