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The duty holder regime, Gateway process and golden thread requirements introduced by the Building Safety Act 2022 do not just change paperwork — they change who carries legal liability when things go wrong. Here is what every fire alarm contractor working on UK buildings needs to know.
For most of the history of the UK fire alarm industry, legal liability was relatively simple to locate. If a building burned and the alarm failed, investigators looked at the responsible person — the building owner or manager who had obligations under the Regulatory Reform (Fire Safety) Order 2005. The installer designed, built and commissioned the system, handed over the certificate, and moved on. Accountability, in theory at least, transferred with the documentation.
The Building Safety Act 2022 began to dismantle that arrangement. Through its duty holder regime, Gateway process and golden thread requirements, it introduced a chain of accountability that runs from the earliest stages of design to the moment a building is occupied — and beyond. Fire alarm installers and contractors working on higher-risk buildings are now named participants in that chain. Not observers. Not subcontractors who can point elsewhere. Participants with documented, enforceable obligations.
This article explains what the Act means in practice for fire alarm companies — what has changed, what is required of them, and what the direction of travel signals for the sector. It focuses primarily on higher-risk buildings, but notes where the Act's reach extends further.
The Building Safety Act defines a higher-risk building (HRB) as a building that is at least 18 metres in height or has seven or more storeys, and contains at least two residential units. These are the buildings subject to the most extensive new requirements — the Gateway regime, the duty holder roles, and the golden thread obligations described in this article.
However, it is a mistake to assume the Act only matters for companies working on landmark high-rise schemes. The scope is broader than many contractors realise:
Mixed-use developments with residential above commercial — a block with flats above ground-floor retail — may meet the HRB threshold if the residential element reaches the required height
Refurbishment and remediation works to existing HRBs are subject to the Gateway regime from 1 October 2023, not just new builds
Section 156 of the Act, which tightened Fire Safety Order duties on responsible persons, applies to all buildings regulated by the Fire Safety Order — not just HRBs. This affects the due diligence expected of every building manager appointing a fire alarm contractor, regardless of building height
For fire alarm companies, the practical starting point is straightforward: if you are working on, or tendering for work in, any residential building of significant height, establish its HRB status before assuming the standard regulatory framework applies.
Definition: A higher-risk building under the Building Safety Act 2022 is a building of at least 18 metres in height or with 7 or more storeys, containing 2 or more residential units. The Gateway regime for HRBs came into force on 1 October 2023.
One of the most significant structural changes introduced by the Act is the formal duty holder regime for design and construction work on HRBs. The regime creates defined roles with specific legal obligations:
Principal Designer — appointed by the client to plan, manage, monitor and coordinate health and safety during the pre-construction phase. Must ensure the design complies with building regulations
Principal Contractor — appointed to plan, manage, monitor and coordinate construction phase health and safety. Responsible for ensuring building work complies with building regulations
Contractor — any business or individual who carries out or manages building work. This is where most fire alarm installers working as subcontractors will sit
The contractor duty holder role is not honorary. Under the Act, contractors working on HRBs must cooperate with the principal designer and principal contractor, follow their instructions in relation to building regulations compliance, and not carry out work that contravenes building regulations. They must also share information relevant to the golden thread with those above them in the duty holder chain.
The critical shift is in accountability. Previously, a fire alarm subcontractor could, in practice, argue that design decisions made above them in the supply chain were not their responsibility. The Act changes that by requiring every duty holder to actively discharge their obligations — not simply follow instructions and assume compliance lies elsewhere.
Key change: For the first time, individual contractors — not just the companies they work for — can carry personal liability under the building safety framework. The Act places duties on persons, not only organisations. Sole traders and individual directors of fire alarm companies working on HRBs should understand this.
The duty holder structure also affects how appointments are made and documented. Clients must appoint principal designers and principal contractors before work can proceed. Those appointments must be in writing. Competence must be assessed before appointment. For fire alarm subcontractors, this means that the question of who appointed them, under what terms, and with what competence assessment on record, is now a matter of legal significance — not just commercial practice.
The Gateway regime is the most operationally disruptive element of the Act for companies working on HRB projects. It creates three mandatory checkpoints — Gateways 1, 2 and 3 — through which an HRB project must pass before it can proceed to the next stage.
For fire alarm contractors, Gateway 2 is the one that changes day-to-day practice most immediately. It is the checkpoint before construction begins, and it requires the developer to submit a full building control approval application to the Building Safety Regulator (BSR). That application must demonstrate that the design complies with building regulations. Crucially, no work can start on site until Gateway 2 approval is granted — and the BSR must approve any major change to the design before work relating to that change can proceed.
The implication for fire alarm design is significant. In the pre-Act world, fire alarm specifications were commonly developed and refined during construction — adjusted as layouts changed, as other trades made decisions, as the building evolved from drawing to reality. That approach is no longer compatible with the Gateway regime. A fire alarm design submitted as part of a Gateway 2 application needs to be sufficiently developed that it can withstand BSR scrutiny and anchor the approval. Changes to it after Gateway 2 approval may require a formal change control application.
Gateway 3 creates a hard stop at the end of construction. A completion certificate from the BSR is required before the building can be occupied. Without it, the building sits empty — and delays at Gateway 3 have real consequences for every contractor on the project, including fire alarm companies awaiting final payment.
Gateway 2 in numbers: The BSR was required to determine Gateway 2 applications within 12 weeks for new builds. The reality has fallen well short of that target. Average determination times reached 22 weeks in early 2025, and later data from Q3 2025 indicated averages of around 36 weeks for new builds. In 2025, some projects fell 12 to 18 months behind schedule as a result. Between October 2023 and September 2024, only 146 of 1,018 Gateway 2 applications were approved — an approval rate of around 14%. Approximately 75% of rejections were attributed to missing or inadequate information in submissions.
These delays have direct commercial consequences. Fire alarm contractors working on HRB schemes need to factor Gateway 2 timelines into project programmes and contract terms. A programme that assumes an 8- or 12-week Gateway 2 determination is, based on recent BSR performance, likely to be wrong. The BSR introduced an Innovation Unit in mid-2025 and began meeting its 12-week target for the applications it manages directly — but the overall picture across all application types remained one of significant delay throughout 2025.
The practical implication for fire alarm companies is a structural change in how they need to engage with HRB projects: appointed earlier, with design finalised earlier, and with change management processes that can accommodate the formal constraints of the Gateway regime.
The golden thread of information is one of the Act's most consequential concepts for those who install and maintain fire alarm systems. It refers to the complete, structured body of information about a building — its design, construction, systems and safety measures — that must be created during construction, kept up to date throughout the building's life, and passed to whoever takes over responsibility for the building.
For fire alarm contractors, the golden thread obligation means that everything relevant to the fire alarm system must be documented and handed over in a form that can be maintained and accessed by the accountable person for years or decades after the installer has left site. The Act is explicit that this information must be stored securely, kept up to date, and made available to the BSR, the fire and rescue service, and residents on request.
In practice, fire alarm contractors working on HRBs should ensure the golden thread for their scope of work includes:
The fire alarm design documentation — category of system, zone layout, detector types and locations, panel specification, interface points with other systems
Installation records — cabling schedules, test results, commissioning certificates
Any changes made during installation, with the rationale for those changes
Handover documentation — operating manuals, maintenance schedules, contact details for the installing company
A record of the system as built, not as designed — because these often differ
The 'as-built' requirement is worth emphasising. It is common practice in the fire alarm industry for systems to be adjusted during installation — a detector relocated because of a structural obstruction, a zone boundary revised because of a layout change. Under the golden thread obligation, those adjustments must be documented. An undocumented change made on site creates a discrepancy between the approved design and the installed system that can have serious consequences at Gateway 3 and in any subsequent enforcement or investigation.
Undocumented changes: Any change made to the fire alarm system during installation that is not recorded in the golden thread is a compliance risk — and, in the event of a fire, a potential liability issue. 'We adjusted it on the day' is no longer a defensible position. Changes must be documented, regardless of how minor they appear at the time.
The Act's competence requirements are both its most widely discussed and most practically significant provisions for fire alarm companies. The duty holder regime requires that all those performing duty holder roles on HRB projects must be competent to fulfil them. Clients must assess competence before appointing duty holders. Duty holders must not accept appointments they do not have the competence to fulfil.
For fire alarm contractors, competence has always been expected — but the framework for demonstrating it has tightened considerably. Two developments are particularly relevant:
BAFE SP203-1, updated August 2023. BAFE's third-party certification scheme for fire alarm companies was revised to require nominated Lead Individuals to hold a Level 3 regulated qualification in fire detection and alarm systems working to BS 5839-1. This is a significant change: for the first time, a specific regulated qualification is required for key individuals in certified companies, not just demonstrated experience. Companies registered to SP203-1 whose Lead Individuals do not hold a qualifying credential need to address this.
Section 156 of the Building Safety Act 2022 (in force 1 October 2023). This tightened the Fire Safety Order's requirements on responsible persons when appointing people to carry out fire safety work. Responsible persons must now be confident in their choice of 'competent person'. Government guidance is explicit that third-party certification by a UKAS-accredited body — such as BAFE SP203-1 registration — provides the clearest evidence that due diligence has been exercised. Choosing an uncertified company is not illegal, but it places the responsible person in a more exposed position if something subsequently goes wrong.
BAFE registration itself remains voluntary — there is no statutory requirement to hold SP203-1 in order to install fire alarm systems in the UK. However, the practical effect of the Section 156 changes is that responsible persons are increasingly being advised by legal counsel, fire engineers and insurers to use certified companies. For fire alarm businesses not registered to SP203-1, the pipeline of HRB and commercially significant work is likely to narrow over time.
Opportunity: Companies that achieve or maintain BAFE SP203-1 registration with compliant Lead Individual qualifications are in a stronger commercial position as the market tightens. Responsible persons advised to demonstrate due diligence will increasingly specify third-party certification as a prerequisite. This is not just compliance — it is a competitive differentiator.
The compliance overhead of the Building Safety Act falls disproportionately on smaller businesses. Earlier design engagement, more detailed documentation, formal Gateway processes, and structured competence requirements all represent costs — in time, in staff training, and in the investment required to achieve or maintain certification.
The risks for smaller companies that do not adapt include:
Being excluded from HRB projects where principal contractors require evidence of third-party certification and formal duty holder capability
Taking on HRB subcontract work without understanding the documentation obligations, creating golden thread gaps that surface at Gateway 3 or in subsequent enforcement action
Exposure to personal liability for individual directors or sole traders who act as contractor duty holders without understanding their obligations
At the same time, the market is rewarding adaptation. Building owners and developers who have experienced Gateway 2 rejections due to poor-quality submissions are increasingly looking for supply chain partners who understand the process and can contribute to compliant applications from the outset. A fire alarm company that can produce gateway-ready design documentation, golden thread records, and evidence of Lead Individual qualifications is meaningfully more valuable on an HRB project than one that cannot.
Practical steps for fire alarm contractors assessing their position:
Check your BAFE SP203-1 registration status and whether your Lead Individuals hold a Level 3 regulated qualification in fire detection and alarm systems to BS 5839-1. If not, understand the pathway to compliance
Review your design documentation processes — does your current practice produce the level of detail required for a Gateway 2 submission?
Review your installation record-keeping — are changes made on site captured in real time and passed back to the design record?
Review your handover documentation — does it constitute a golden thread contribution, or a certificate with limited accompanying information?
If you are routinely working on projects that may include HRBs, consider whether your contract terms address the duty holder obligations you are taking on
The Building Safety Act 2022 is not the final word. The Grenfell Tower Inquiry Phase 2 report, published in September 2024, recommended mandatory licensing for contractors working on higher-risk buildings — a regime under which it would be unlawful to carry out such work without a licence. The government's December 2025 consultation document on a single construction regulator signals that mandatory licensing remains on the policy agenda, with an independent review of the building safety regulatory regime expected by April 2027.
The direction of travel is unmistakeable: accountability will continue to tighten, the documentation burden will continue to increase, and the distinction between certified and uncertified companies will continue to matter more. The companies best placed to navigate what comes next are those that have already adapted to what the Act requires now.
For fire alarm installers and contractors, the Building Safety Act has created a framework in which the quality of your design, the completeness of your records, and the credentials of your people are not administrative concerns. They are the evidence of your competence — and increasingly, the basis on which you will win or lose work.
LFS works with installers, contractors and building owners across the UK fire alarm sector. If you have questions about how the Building Safety Act affects your projects or your business, the LFS team is available to advise, click here to contact us.
Key sources and further reading
Building Safety Act 2022 — legislation.gov.uk/ukpga/2022/30
The Building (Higher-Risk Buildings Procedures) (England) Regulations 2023 — legislation.gov.uk
Building Safety Regulator — Gateway 2 guidance and performance data (HSE) — hse.gov.uk/building-safety
Fire Safety Act 2021 — legislation.gov.uk
Section 156, Building Safety Act 2022 — Fire Safety Order amendments and competence requirements
Check your fire safety responsibilities under Section 156 of the Building Safety Act 2022 — GOV.UK
BAFE SP203-1 Scheme Document (updated August 2023) and Lead Individual qualification requirements — bafe.org.uk
Is BAFE Registration a legal requirement? — BAFE guidance (bafe.org.uk)
Gateway 2 delay risk analysis — Trowers & Hamlins (February 2025 and December 2025)
Higher-risk buildings Gateway regime delays — HKA (Fire & Risk Management, May 2025)
Latest developments under the Building Safety Act 2022: Q3 2025 update — DAC Beachcroft
What can the latest BSR figures for Gateway 2 applications tell architects? — RIBA (October 2025)
Grenfell Tower Inquiry Phase 2 Report (September 2024) — grenfelltowerinquiry.org.uk
Single construction regulator prospectus: Consultation document — MHCLG (December 2025)
This article is for general guidance only and does not constitute legal advice. Fire alarm contractors should seek professional advice specific to their projects and circumstances.