* Review of relevant project documentation
* On site inspection of the various building cladding types
* Produce Fire Risk Assessment External Walls (FRAEW) in accordance with PAS 9980 guidelines
Find out more
The Building Safety Regulator (BSR) is changing the way it assesses occupied higher-risk buildings after revealing that assessment times have been twice as long as expected and 66% of Building Assessment Certificate (BAC) applications have been refused so far in 2026.
So, why are so many applications being refused and what does it mean for those responsible for higher-risk buildings?
The Building Assessment Certificate (BAC) process forms part of the regime for occupied higher-risk buildings introduced under the Building Safety Act 2022. These are buildings that are at least 18 metres high or have seven or more storeys and contain at least two residential units.
The Principal Accountable Person, usually the organisation responsible for the building’s structure and exterior, must apply for the certificate and provide multiple pieces of information about how the building is managed, including its safety case report.
The BSR then uses this information to assess how the building’s fire and structural safety risks are being managed.
Refusal does not automatically mean the building is unsafe, or that residents must leave; it means the BSR was not satisfied that the relevant legal duties were being met at that point. The applicant will be told what needs to be addressed and may be asked to provide further information or take action before applying again.
According to the BSR, applications often concentrate on process compliance rather than the effective management of safety.
That does not necessarily mean the right work has not been done. Managing agents and building owners may already hold a considerable amount of information, from fire and structural assessments to inspection reports, maintenance records and details of previous work.
But while individual reports may be technically sound, they can still leave gaps when viewed as part of the complete building record. One report may identify a concern, another may recommend further investigation and a contractor may later carry out repairs. If the records do not clearly connect those stages, it can be difficult to establish what was found, what was done about it and where the building stands now.
Findings can also sit with different consultants, contractors or managing agents, making it harder to follow the line from the original concern to the action taken.
At the same time, the BSR has acknowledged that the process itself needs to improve. It plans to publish simpler assessment criteria and clearer technical guidance so applicants and assessors have a better shared understanding of what is required.
Managing building safety involves several different areas of expertise. A fire engineer, structural engineer, façade consultant, managing agent and contractor may all contribute information about the same building.
Each report may have been prepared for a different reason and at a different stage in the building’s life. The challenge is making sure those separate pieces of information connect.
A problem with the façade could have implications for fire safety, structural stability and weather resistance. Work carried out to address one concern may also change the building in a way that needs to be reflected in other reports and assessments.
Bringing the relevant expertise together helps identify gaps, conflicting information and assumptions that could otherwise remain hidden across separate documents.
External walls provide a useful example of why this joined-up approach matters.
External walls are only one part of a building’s fire and structural safety, but their design, materials and condition can affect both.
Questions can arise where there is:
Different forms of specialist investigation provide different evidence. A Fire Risk Appraisal of External Walls, or FRAEW, assesses the risk of fire spreading over or within the external wall. A façade survey records the type and condition of the visible façade, while more targeted façade inspections can provide evidence about deterioration, damage, workmanship or completed repairs.
The type and extent of investigation needed will depend on the building and the information already available. Existing documents can provide a useful starting point, but they may not show later alterations or confirm that the wall was built exactly as designed. A visual survey also has limits when important elements are hidden from view.
The aim is to build a reliable picture of the external wall using the available evidence, while being clear about any assumptions or gaps that remain.
Identifying a concern is only the beginning. The building record should also show how it was investigated, what conclusions were reached and what happened as a result.
This is where the golden thread becomes important. The information about a higher-risk building should be accurate, up to date and available to the people who need it, but it also needs to connect. Someone reviewing the external wall information should be able to follow the original concern through to the investigation, action taken and current position.
This is particularly important during façade remediation because much of the work will eventually be concealed. Independent façade remediation monitoring can provide a record while the work remains visible, including the materials used, important installation details, defects identified and how those defects were addressed.
The information should then feed back into the wider building record. If remediation has changed the external wall or reduced an identified risk, the safety case report and other relevant assessments may need to be updated to reflect the building as it now stands.
The BSR plans to make its approach more proportionate, targeted and led by the available information about individual buildings and duty holders. Updated resources are expected from September 2026, and these should provide more detail on how the new assessment process will work.
What is not changing, however, is the legal responsibility to manage building safety.
Principal Accountable Persons must continue to manage fire and structural safety risks, maintain the required building information and update the safety case report when the position changes.
Obtaining a certificate is not the end goal. The certificate is part of the regulatory process – the real objective is to make sure that risks are understood and properly managed throughout the life of the building.
Read the Building Safety Regulator’s full announcement. You can also learn more about our Façade Quality Control service on our dedicated page.
©2021 Barry Jubb Associates. All Rights Reserved | Made by JKE Web Design