Tim Shepperd

BoonBrown has significant experience in the management and delivery of Higher Risk Residential Buildings, including the preparation, coordination and successful approval of Gateway 2 applications by the Building Safety Regulator (BSR). As Architect, Lead Consultant and Principal Designer, BoonBrown has led multidisciplinary teams on complex residential developments comprising private sale, affordable rent and shared ownership homes, maintaining a rigorous focus on compliance, information management and stakeholder coordination.

Gateway 2 begins earlier than many think

One of the biggest misconceptions about Gateway 2 is that it starts when the application is submitted. In reality, the submission itself is the culmination of months, and often years, of planning, coordination and governance activity. Success is determined long before the application reaches the Building Safety Regulator.

The foundations are laid through the establishment of clear project governance, defined roles and responsibilities, coordinated design development, assessing competency and managing robust compliance tracking. While the design of the building is obviously fundamental, an equally important aspect is the planning and management of the information that demonstrates how compliance has been achieved and how decisions have been controlled throughout the design process.

A successful Gateway 2 submission requires the project team to be thinking well beyond simply producing drawings and specifications. Considerable preparation is needed to establish the information management processes that will underpin the application. This includes identifying what compliance evidence will be required, defining responsibilities for its production, implementing systems for recording design decisions and ensuring there is a clear audit trail demonstrating how regulatory requirements have been addressed.

Our role extends beyond design coordination to managing the processes and procedures that support the submission. This includes coordinating the information required for the application, establishing and monitoring compliance trackers, competency assessments, reviewing consultant deliverables and ensuring that all supporting documentation is aligned, consistent and sufficiently detailed to satisfy the Building Safety Regulator’s requirements.

An important aspect of this preparation is ensuring that design risks, assumptions and compliance matters are identified and addressed at the earliest possible stage. This requires regular multidisciplinary design reviews, structured workshops, ongoing engagement with consultants and specialist subcontractors, and rigorous checking procedures. The objective is to ensure that compliance is embedded within the design as it develops, rather than retrospectively evidenced immediately prior to submission.

Gateway 2 also requires teams to demonstrate that suitable arrangements are in place for managing design changes, maintaining the Golden Thread of information and providing assurance that those undertaking design work are competent to do so. This means establishing governance structures, document control procedures and information management strategies early in the project lifecycle, as these cannot be effectively created retrospectively once a submission is imminent.

Design maturity matters

A key lesson from our first Gateway 2 project under the new regime was the importance of achieving the right level of design maturity before submission.

Traditional procurement routes have often relied on specialist subcontractors developing aspects of detailed design during construction. Under the Gateway regime, this can create challenges where significant design evolution is required after approval, which could in some instances lead to notifiable or major changes which themselves incur delays to the build.

The more certainty that can be achieved before submission, the smoother the process becomes. Early engagement with specialist designers and contractors can significantly improve coordination and reduce the need for subsequent design changes.

Compliance and warranty requirements are not always aligned

Another important learning point was understanding the relationship between Building Regulations compliance and warranty provider requirements.

Although a design may satisfy the requirements of the Building Regulations, warranty providers can impose additional expectations. In our experience, this resulted in some design modifications that needed to be managed through the Building Safety Regulator’s change control process after approval.

This reinforced the importance of engaging warranty providers early and aligning requirements wherever possible before submission.

Managing change in a new regulatory landscape

Our first project was submitted during the early stages of the Building Safety Regulator’s implementation, when both processes and industry understanding were still developing.

Although the scheme was approved following its initial submission without the need for resubmission, the determination period extended significantly beyond the statutory period. The experience highlighted the importance of programme planning and stakeholder communication when operating within a developing regulatory environment.

Our experience highlighted the value of clear and timely communication throughout the post-submission review process, allowing requests for clarification to be addressed efficiently. Opportunities for greater direct engagement between the review team and the project team, together with enhanced application tracking, could further support transparency and programme certainty.

Looking beyond the paperwork

The most important lesson from our Gateway 2 experience is that successful approvals are achieved through leadership, coordination and design certainty rather than documentation alone.

Gateway 2 is ultimately a test of how effectively a project team has managed compliance, competence and risk throughout the design process. The strongest submissions are not those with the greatest volume of information, but those that clearly demonstrate a coordinated, accountable and safety-focused approach from the outset.

As the regulatory landscape continues to evolve, these principles remain at the heart of helping clients navigate the delivery of Higher Risk Buildings with confidence.

Looking ahead to Gateway 3

Whilst much attention has been placed on achieving Gateway 2 approval, the industry is increasingly recognising that the foundations for Gateway 3 are established long before completion. Guidance highlights the importance of maintaining live compliance records, proactive change management and continuous development of the Golden Thread throughout the construction phase. Our experience has reinforced the value of treating compliance as an ongoing process rather than a milestone activity. As our first project moves towards Gateway 3 in 2027, we are focused on ensuring that design decisions, approved changes, inspection records and as-built information remain fully aligned, creating a comprehensive record of how compliance has been achieved in practice. This not only supports the Completion Certificate application but also provides building owners and operators with the information needed to manage the building safely throughout its operational life.