The Building Safety Act 2022: What Facilities Managers Need to Know

The Building Safety Act 2022 is the most significant reform of building safety law in England in a generation. Introduced in response to the Grenfell Tower fire and the independent review that followed, it created a new regulator, a new regime for managing higher-risk residential buildings, new duties on everyone who commissions or carries out building work, and stronger expectations about the information that must be kept about a building throughout its life.

For facilities managers, the Act can feel like it was written for developers and freeholders rather than for the people who actually run buildings day to day. In practice, a great deal of what the Act requires is delivered by facilities teams: commissioning works, managing contractors, keeping records, maintaining fire safety systems and reporting problems. This guide sets out what changed, who is responsible for what and the practical steps that help you support your clients or your organisation.

The Act in brief, and who regulates it

The Building Safety Act 2022 is a large piece of legislation, much of which is brought into effect through secondary regulations. For facilities managers, the most important parts are:

• Part 2, which established the Building Safety Regulator;
• Part 3, which reformed the building control system, including a stricter regime for building work on HRBs and new dutyholder and competence requirements for all building work;
• Part 4, which sets out the duties for managing occupied HRBs;
• provisions amending the Regulatory Reform (Fire Safety) Order 2005, which apply to a much wider range of buildings.

The BSR was originally set up within the Health and Safety Executive. On 27 January 2026 it became a standalone arm’s-length body sponsored by the Ministry of Housing, Communities and Local Government, as a step towards the single construction regulator recommended by the Grenfell Tower Inquiry. In practical terms, the BSR acts as building control authority for HRBs, oversees the safety of occupied HRBs and oversees the building control profession. If you have older documents that refer to “HSE’s Building Safety Regulator”, the duties are the same; the organisation is now separate.

Is your building a higher-risk building?

For the occupation regime under Part 4, a building is a higher-risk building if it is in England, is at least 18 metres in height or has at least 7 storeys, and contains at least two residential units. The regulations set out how height and storeys are measured and list certain buildings that are excluded during occupation, such as hospitals and care homes. A different, wider definition applies during design and construction.

Mixed-use buildings can be HRBs. A tower with retail on the ground floor, offices above and flats on the upper floors may meet the definition, which means the commercial occupiers’ facilities managers may find themselves working alongside an Accountable Person regime they had not previously encountered.

Occupied HRBs must be registered with the BSR. Existing buildings had to be registered by 1 October 2023, and new HRBs must be registered before they are occupied. After applying, the Principal Accountable Person has 28 days to give the BSR detailed key building information. Several of the categories are directly relevant to building services teams, including fire and smoke control equipment, lifts used for firefighting or evacuation, energy supplies, on-site generation and energy storage.

Accountable Persons and the Principal Accountable Person

An Accountable Person is an organisation or individual that owns, or has a legal obligation to repair, the common parts of an HRB. There can be more than one, for example where a freeholder is responsible for the structure and a management company is responsible for internal common parts.

Every HRB must have one Principal Accountable Person. Where there is only one Accountable Person, they are the Principal Accountable Person. Where there are several, it is the one who owns or is responsible for repairing the structure and exterior. The Principal Accountable Person carries extra duties, including registration, the safety case report and mandatory occurrence reporting.

The core duties for occupied higher-risk buildings

The table below summarises the main duties under Part 4 and what they mean in practice for building operations.

Duty	Who holds it	What it means for the FM team
Assess building safety risks	Each Accountable Person, for their parts	Risks of fire spread and structural failure must be assessed and kept under review. Building services condition data feeds directly into this.
Manage building safety risks	Each Accountable Person	Take all reasonable steps to prevent a major incident and reduce its severity. Planned maintenance of fire and life-safety systems is central.
Safety case report	Principal Accountable Person	A report showing how risks have been identified and are being managed. Maintenance records and test certificates are typical supporting evidence.
Mandatory occurrence reporting	Principal Accountable Person	A system for capturing and reporting safety occurrences that could cause significant loss of life or serious injury. FM teams are often the first to spot these.
Golden thread information	Accountable Persons	Keep prescribed building information accurate, digital and up to date.
Resident engagement	Principal Accountable Person and Accountable Persons	A residents’ engagement strategy, information for residents and a complaints process.
Building assessment certificate	Principal Accountable Person	Apply when the BSR requires it, and display the certificate once issued.

The golden thread: making your records work

The golden thread is the information about a building that allows people to understand it and keep it safe, held and maintained throughout its life. The BSR’s guidance on keeping information about a higher-risk building says that the information should be kept digitally, be secure from unauthorised access, be available when needed, be presented in a usable and accessible format, be kept up to date and act as a single source of truth for the building. For Accountable Persons it includes the health and safety file, the safety case report, the residents’ engagement strategy and the mandatory occurrence reporting system, as well as inspection and maintenance records where available.

For most facilities teams, the biggest challenge is not understanding the principle but getting existing records into a state that meets it. Electrical and life-safety information is a good place to start, because it is often scattered across contractors, paper logbooks and email attachments. Useful records to bring together include:

• Electrical Installation Certificates and Electrical Installation Condition Reports, with evidence that C1 and C2 observations were resolved;
• emergency lighting test records and certificates, as described in our guide to emergency lighting testing to BS 5266;
• fire detection and alarm system records, covered in our article on fire alarm maintenance to BS 5839-1;
• up-to-date schematics, distribution board schedules and an accurate asset register;
• records of changes, including who approved each change and why.

A structured maintenance specification, such as one built on SFG20, makes this far easier because tasks, frequencies and evidence follow a consistent format. Our SFG20 guide explains how to set one up.

Building work: dutyholders, competence and BSR approval

Dutyholder and competence rules for all buildings

Since 1 October 2023, a dutyholder regime has applied to building work in England that is subject to the Building Regulations. The person or organisation commissioning the work, the client, must make suitable arrangements for planning, managing and monitoring the project so that it complies, and must provide building information to designers and contractors. Anyone appointing a designer or contractor must take reasonable steps to check that they are competent, and those accepting an appointment must only do so if they are competent to carry it out.

This applies to commercial buildings, offices and schools as much as to residential towers. When a facilities manager commissions a rewire, a new distribution board or a lighting upgrade that falls within the Building Regulations, the organisation they act for is the client and carries these duties. In practice that means checking accreditations, insurance and experience, and keeping a record of how you did so. Our guide to choosing an NICEIC-approved electrical contractor sets out what to check.

Work in existing higher-risk buildings

Most building work to an existing HRB now needs building control approval from the BSR before it starts. The BSR’s guidance on building control approval for higher-risk buildings lists the main exceptions:

• exempt work, which includes most repairs, replacements and maintenance, though not the replacement of fuse boxes (consumer units), heating systems, oil tanks or glazing units;
• work carried out under a competent person scheme, provided the scheme covers HRB work, which you should confirm with the scheme provider;
• emergency repairs, which must be notified to the BSR by the end of the first working day after work starts and then regularised.

Changes that reach beyond higher-risk buildings

Even if you manage no HRBs, the Act still affects you. Section 156 amended the Regulatory Reform (Fire Safety) Order 2005 from 1 October 2023. Among other changes, Responsible Persons must now record their fire risk assessment in full, record the identity of anyone engaged to help carry it out, and co-operate and share information with other Responsible Persons in the same building.

Separately, the Fire Safety (England) Regulations 2022, which came into force on 23 January 2023, placed duties on Responsible Persons for multi-occupied residential buildings. These include fire safety instructions and fire door information for residents in all such buildings, quarterly checks of communal fire doors and annual checks of flat entrance doors in buildings over 11 metres, and further duties for high-rise buildings, including monthly checks of firefighting lifts and other firefighting equipment and the provision of a secure information box.

Taken together, these measures raise the bar for record-keeping and contractor competence across the whole built environment, and they make planned maintenance of electrical and life-safety systems harder to treat as optional.

A practical action plan for facilities managers

Whether you manage a single block or a mixed estate, the following steps will put you on a firm footing:

• Confirm which of your buildings are HRBs and who the Accountable Persons and Principal Accountable Person are.
• Agree in writing which Building Safety Act tasks your team carries out on the duty holder’s behalf.
• Bring electrical, fire and life-safety records together in a single, searchable digital system.
• Check that all C1 and C2 observations on recent EICRs have documented remedial work.
• Review planned maintenance for fire alarm, emergency lighting, smoke control and firefighting lifts.
• Set up a clear route for reporting safety occurrences to the Principal Accountable Person.
• Build a competence check into every contractor appointment and keep the evidence.
• Plan any HRB building work early, allowing time for BSR approval where required.

How JKS London can help

JKS London is an NICEIC approved contractor and facilities management partner working across London and the South East since 2004, including residential, retirement living and public sector buildings. We help duty holders and their managing agents keep electrical and life-safety systems compliant and well documented, from EICRs and emergency lighting testing to asset registers, schematics and change-control support that feed into the golden thread.

Explore our facilities management and electrical compliance services, read about our work in retirement living, or contact us to arrange a free, no-obligation site visit and discussion of your buildings.

Frequently asked questions