The BAC regime reset explained: Your questions, answered

As standard, it is recommended that a Type 3 FRA is completed, which covers the common areas of the property, and this risk assessment considers the arrangements for means of escape and fire detection (i.e. smoke alarms) within a sample of the tenant’s demises.

Within the demises, the inspection is non-destructive, but the fire resistance of doors to rooms is considered. The inspection of the building(s) is non-destructive/non-intrusive in nature.

As well as considering the arrangements for means of escape and so forth, the fire risk assessment includes examination of (within a multi-tenanted building) at least a sample of tenants’ entrance doors and, where applicable, balconies.

It also considers within a multi-tenanted building so far as reasonably practicable, the separating construction.

If there are concerns regarding compartmentation, a Type 4 FRA should be undertaken. The inspection of the building(s) is semi-destructive in nature.

As part of the application, mandatory documents that must be submitted include:

• A resident engagement strategy
• Information about the mandatory occurrence reporting system
• A Safety Case Report

The Building Safety Act guidance doesn’t prescribe a specific survey methodology, but our fire assessors evaluate compartmentation as one of the criteria, alongside description, risk assessment, protective measures, and management arrangements when reviewing a BAC application.

There is no mandated “standard” or fixed survey scope, but it is outcome-based, not a prescribed methodology. The Building Safety Regulator’s structural criteria (S1–S11) are clear about what evidence is needed.

Further information can be found here.

Discrepancies at the 18m mark usually come from definition, not measurement error — different datum points, or whether roof plant/parapets are included. We recommend:

• Getting both surveyors’ methodology in writing (datum, inclusions, standard used)
• Joint on-site remeasurement, using the same equipment and agreed datum
• If still disputed, independent RICS-chartered third surveyor, agreed upfront as binding (expert determination)
• Making sure everything is documented

An Accountable Person (AP) is an organisation or individual who owns or has a legal obligation to repair any common parts of the building. Common parts are used by residents, such as:

• The structure and exterior of the building
• Corridors
• Lobbies
• Staircases

An AP can be a:

• Freeholder or estate owner
• Landlord
• Management company
• Resident Management company
• Right to Manage company
• Commonhold Association

Source: GOV.UK

Building Manager (Appointed) — someone appointed to manage the building day-to-day.

The law requires a unified point of accountability. It designates the entity that holds a legal estate in possession in the structure and exterior of the building – or carries a relevant repairing obligation for those parts – as the Principal Accountable Person (PAP).

Having several Directors named on the portal doesn’t mean liability is shared equally or automatically among all of them. The company (PAP) still holds the primary legal responsibility.

Each individual Director would only be personally liable if it’s shown they specifically knew about an issue and allowed it or were negligent – this is assessed person by person, not as a group.

For example, naming two Directors doesn’t automatically double liability – it just means both are potential contacts, and each would need their own involvement examined separately if something went wrong. The Building Safety Regulator can be asked to determine the PAP, or legal advice sought to interpret overlapping lease/freehold arrangements.

Once the entity is identified, that entity registers and appears on the portal — the named Director is just their nominated contact, not the PAP itself.

Your resident engagement strategy should be specific to the building and take account of the needs and preferences of the residents. If you manage more than one building, the resident engagement strategy for each building may be similar in many areas. However, each strategy should be specific to that building’s residents and their needs.

Further information can be found here.

There is no fixed statutory timescale for the Building Safety Regulator (BSR) to respond after you submit evidence following an Enforcement Notice, as it is discretionary.

Recommended action: Chase BSR formally in writing, referencing your Enforcement Notice and evidence submission date and request a timeline. Keep evidencing ongoing compliance regardless (duties don’t pause).

We are monitoring updates via the Building Safety Regulator. The Regulator stated in its July 2026 announcement that initial updated resources, including simplified assessment criteria and guidance, are expected from September 2026, as part of a shift to a more proportionate, risk-based approach following industry feedback on delays and high refusal rates.

It is recommended that you continue to strengthen your safety case, structural/fire evidence, and resident engagement records in readiness.

The Building Safety Regulator (BSR) is actively calling higher-risk buildings in for Building Assessment Certificate (BAC) applications. When your building is called in, you have 28 days to submit a complete application under section 79 of the Building Safety Act 2022.

We cannot advise how much notice you will get ahead of a call-in; however, Section 85-86 of the Building Safety Act 2022 emphasises the importance of timely compliance with these duties, including preparation.

Threshold trigger: Section 20 (Landlord & Tenant Act 1985) consultation is required if the cost of “qualifying works” recoverable from any individual leaseholder exceeds £250.

Long-term agreements: If you’re engaging surveyors under an agreement running more than 12 months, the lower £100/leaseholder/year threshold applies instead (qualifying long-term agreement, not qualifying works).

Further information can be found here.