Day 11

Building Safety Act 2022: High-Risk Buildings, the Golden Thread, and Accountable Persons

The Building Safety Act 2022 is arguably the most significant piece of housing and property safety legislation in a generation.
Born from the lessons of the Grenfell Tower tragedy, it establishes a new, more accountable system for how residential buildings are designed, constructed, and managed — with clear duties, stricter oversight, and greater protection for residents.

Even landlords of smaller buildings need to understand its implications.
If you own, let, or manage apartments, converted buildings, or multi-occupied dwellings, this Act affects you — directly or indirectly.


Why the Building Safety Act 2022 matters

This Act represents a cultural shift in housing safety and management. It introduces:

  • A new Building Safety Regulator (BSR) within the Health and Safety Executive (HSE).

  • The “Golden Thread” of information — accurate, up-to-date data about a building’s safety throughout its life.

  • Clear legal duties for “Accountable Persons” and “Principal Accountable Persons”.

  • A new safety regime for high-rise residential buildings.

  • Tougher enforcement powers and criminal penalties for non-compliance.

The focus is not only on construction quality but also on ongoing building management and resident safety.


What buildings are covered?

The most stringent duties apply to Higher-Risk Buildings (HRBs) — defined as:

  • At least 18 metres or seven storeys in height, and

  • Containing at least two residential units.

However, parts of the Act also affect:

  • Smaller blocks of flats.

  • HMOs and converted buildings.

  • Landlords whose properties form part of larger developments.

In short, even if your building isn’t classed as “high-risk”, you should still know what’s required — because the expectations of professional management now extend throughout the sector.


The new regulator: HSE Building Safety Regulator (BSR)

The Act established the Building Safety Regulator inside the HSE, responsible for:

  • Overseeing the safety and performance of all buildings.

  • Implementing the new high-risk building safety regime.

  • Holding dutyholders and Accountable Persons to account.

  • Promoting competence across the built environment.

This means landlords can now face inspection or enforcement directly from the HSE, not just from local councils or fire services.


The “Accountable Person” and “Principal Accountable Person”

Every higher-risk building must have one or more Accountable Persons (APs) — the individuals or organisations responsible for ensuring fire and structural safety is properly managed.

Key responsibilities include:

  • Registering the building with the BSR.

  • Preparing and maintaining the Safety Case Report — evidence that all major safety risks are identified and controlled.

  • Establishing and maintaining the Golden Thread of information.

  • Engaging with residents about safety.

Where multiple APs exist (for example, freeholder and managing agent), one is designated as the Principal Accountable Person (PAP) — the main dutyholder responsible for the entire building’s compliance.

Failure to register or maintain a Safety Case is a criminal offence.


The “Golden Thread” of information

The Golden Thread is the backbone of the Building Safety Act. It’s a digital record that tracks key safety information about the building across its entire lifecycle — from design and construction to management and maintenance.

It must:

  • Be accurate, up to date, and accessible.

  • Include structural and fire safety data.

  • Be updated after any refurbishment or significant change.

  • Be available to regulators, contractors, and residents as needed.

For landlords, this means maintaining strong documentation and record-keeping systems — including plans, inspections, maintenance logs, and safety certifications.


Resident engagement and complaints

Accountable Persons must create a Resident Engagement Strategy and a Complaints Policy so that residents can raise concerns about safety and receive responses within reasonable timeframes.

Failure to listen or act on safety complaints could attract regulatory intervention or fines.


Enforcement and penalties

The Building Safety Act introduces serious penalties for breaches:

  • Criminal prosecution for non-compliance with registration or safety duties.

  • Unlimited fines and/or imprisonment.

  • Stop notices halting occupation of unsafe buildings.

  • Cost recovery powers for the regulator.

Developers, landlords, and managing agents can also face enforcement for misleading information or non-cooperation with investigations.


Retrospective liability and remediation

One of the most controversial aspects of the Act is the extension of liability for building defects.

Developers and landlords can now be pursued for up to 30 years retrospectively (15 years prospectively) under the Defective Premises Act 1972 and the Building Act 1984, where buildings are found to be unsafe or substandard.

Landlords involved in past conversions, refurbishments, or developments should review records to identify potential exposure.


Compliance checklist for 2025

✅ Identify whether your property qualifies as a Higher-Risk Building.
✅ If so, ensure it’s registered with the Building Safety Regulator.
✅ Establish who your Accountable Person and Principal Accountable Person are.
✅ Prepare and maintain a Safety Case Report.
✅ Create and update your Golden Thread of safety information.
✅ Engage with residents — provide clear information and feedback channels.
✅ Review fire and structural safety documentation annually.
✅ Conduct internal audits and ensure competent professionals are appointed for inspections and works.


Key takeaway

The Building Safety Act 2022 represents the biggest shift in landlord responsibility in decades.
It demands transparency, accountability, and continuous safety management.

Even landlords outside the “higher-risk” category should treat the Act as a blueprint for best practice — because the expectations it sets are fast becoming the industry standard.


Disclaimer: NetRent does not provide legal advice. These articles represent our understanding of rental property law.

Contact NetRent
Telephone: 01352 721300
Email: support@netrent.co.uk

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