My Experience of Gateway 2, Change Control and Higher-Risk Building Delivery
Why Direct Industry Feedback to the Building Safety Regulator Matters
Over the past 18 months, I have been heavily involved in navigating the realities of the Building Safety Regulator (BSR) process across multiple Higher-Risk Building (HRB) projects in London. That experience recently led to being invited to provide direct professional feedback to the BSR itself regarding how the current system is functioning in practice and where the industry continues to face significant operational challenges.
At Folly Architects, our work increasingly sits at the centre of complex Higher-Risk Building consultancy , Gateway approvals, Principal Designer coordination and Building Safety Act compliance strategy. Through both our own live projects and wider industry advisory involvement, we have developed substantial practical experience dealing with Gateway 2 submissions, post-approval change management, technical coordination and regulatory interpretation.
That experience has not simply come from isolated projects. It comes from working across a growing portfolio of HRB developments, advising clients, supporting consultants and helping project teams recover from validation failures, rejected submissions and prolonged approval delays. As a result, we now regularly find ourselves assisting teams navigating some of the most difficult parts of the current regime.
The important point is that the industry does not fundamentally oppose the Building Safety Act or the principle behind the new Gateway system. In many ways, the regime is already producing better technical outcomes. However, there remains a major gap between the intention of the legislation and the practical reality of how the process currently operates.
Much of our work at Folly Architects’ High Risk Building consultancy now involves helping clients and consultants overcome exactly those barriers — bringing clarity, technical coordination and strategic leadership to projects that are increasingly shaped by uncertainty around Gateway approvals and compliance interpretation.
The BSR Invited Industry Feedback Because the System Is Still Evolving
One of the most important things to understand about the current regime is that it is still evolving operationally. The legislation may now exist, but the practical implementation of Gateway processes, change control procedures and compliance expectations continues to develop in real time.
That is precisely why direct industry feedback matters. The BSR is hearing from professionals who are actively delivering HRBs under the regime every day — architects, technical leads, consultants and project teams dealing with live approvals, contractor coordination and real-world construction sequencing.
Being invited into those conversations reflects the depth of practical experience Folly Architects has built across the HRB sector over a relatively short period of time. Our involvement is not theoretical. It comes directly from managing technically complex projects through Gateway processes while simultaneously helping clients navigate uncertainty around evolving compliance expectations.
Increasingly, our role extends beyond architectural design alone. Clients are relying on us to provide strategic regulatory guidance, technical leadership and practical interpretation of the Building Safety framework in situations where many teams are still struggling to understand how the system operates in practice.
The Regime Is Improving Building Quality
Despite the frustrations, there is no question that the Building Safety regime is forcing the industry towards better technical outcomes.
Projects are now being coordinated far more rigorously before construction begins. Fire strategy, structural coordination, services integration, escape planning and buildability are all being interrogated at a much earlier stage than historically seen across many residential developments.
At Folly Architects, we have always approached projects through a technically detailed and highly coordinated lens. The Gateway system effectively reinforces many of the principles that good architectural and technical practice should already have been delivering.
However, the scale of information now required at Gateway 2 is transforming project sequencing across the industry. Clients increasingly need to understand that substantial technical development, consultant coordination and compliance review now happens significantly earlier in the lifecycle of an HRB project.
This is closely linked to our wider work in Building Regulations coordination , Principal Designer services and complex project delivery strategy.
Where the Current System Still Breaks Down
The biggest issue across the industry is not the principle of scrutiny. It is the lack of clarity and consistency around what is actually expected.
Across numerous HRB projects, we have seen examples where information accepted on one Gateway submission is later rejected elsewhere. Construction Control Plans deemed acceptable on one project suddenly become invalid on another. Teams are left attempting to reverse-engineer what “good enough” means through fragmented guidance, inconsistent interpretation and trial-and-error submission strategies.
For experienced technical teams, this creates inefficiency. For less experienced teams, it can create complete paralysis.
This is one of the reasons clients increasingly seek out specialist practices with direct HRB experience. The ability to strategically structure Gateway submissions, anticipate technical concerns and navigate evolving expectations has become an enormous differentiator within the industry.
At Folly Architects, a substantial amount of our current advisory work now revolves around helping teams solve exactly these kinds of Gateway and Building Safety challenges.
Gateway 2 Has Become a Major Technical and Commercial Challenge
One of the clearest lessons from our own projects has been that Gateway 2 is no longer simply a Building Control approval stage. It is now a major technical, strategic and commercial milestone that reshapes the entire development programme.
Early on, our approach was deliberately conservative. We produced highly detailed coordinated Gateway packages because the industry understanding at the time suggested designs needed to be substantially resolved before approval could realistically be obtained.
That approach helped secure approvals and strengthened technical coordination, but it also revealed a second challenge: over-submission creates long-term administrative burden.
The more information formally approved at Gateway 2, the greater the volume of material that subsequently enters the change control process during construction. In practical terms, projects can unintentionally create enormous downstream administration for themselves.
Developing the judgement to understand what must be fully resolved, what should remain proportionate and how to strategically structure Gateway submissions is now becoming a specialist skillset in itself.
That strategic understanding is increasingly where experienced HRB architects can add enormous value to clients navigating the regime.
Communication Remains the Weakest Part of the Process
When speaking to both clients and fellow industry professionals, the single most consistent frustration remains communication.
Across live projects, teams often experience prolonged periods of silence after submissions, change notifications or requests for clarification. Emails frequently go unanswered. Programme certainty becomes difficult. Contractors struggle to sequence works around unclear approval timelines.
Construction projects operate commercially. Uncertainty has direct cost implications.
One of the key pieces of feedback I provided directly to the BSR was that communication alone could dramatically improve industry confidence in the system. Even basic transparency around likely timescales, submission status or expected delays would significantly improve how the regime functions operationally.
Importantly, most of the industry is not asking for reduced scrutiny. What professionals are asking for is clarity, consistency and communication.
Frequently asked questions
The following questions and answers summarise common queries relating to this topic.
Why Experience Matters More Than Ever Under the Building Safety Act
The Building Safety regime is creating a growing divide between teams with direct HRB experience and those still learning the system.
Architects and consultants who have repeatedly navigated Gateway submissions, technical coordination and change control processes are now operating with a very different level of practical understanding compared to teams approaching the regime for the first time.
This is one of the reasons practices with genuine Higher-Risk Building expertise are increasingly becoming involved not only in project delivery, but also in strategic advisory and regulatory feedback discussions.
At Folly Architects, our experience across HRB projects, Principal Designer duties and Building Safety coordination increasingly places us in a position where we are helping clients, consultants and wider project teams overcome barriers that many parts of the industry are still struggling to navigate independently.
That expertise is becoming particularly valuable on technically complex refurbishment projects, occupied residential buildings and schemes involving substantial consultant coordination under live Gateway conditions.
Gateway 3 Is the Next Major Industry Unknown
While Gateway 2 has dominated attention so far, many project teams are now increasingly focused on the uncertainty surrounding Gateway 3 completion approvals.
The concept itself is understandable. The regulator requires evidence that the completed building aligns with approved information, that changes have been managed correctly and that the wider golden thread has been properly maintained.
However, there remains relatively little operational clarity around exactly how Gateway 3 submissions will be assessed in practice. As a result, many teams are currently compiling extensive commissioning information, certificates, inspection records and change logs without complete confidence in what the regulator will ultimately prioritise.
Once again, this is where practical experience and structured technical leadership become critical.
Our approach across HRB delivery increasingly involves helping clients establish compliance strategies early so that Gateway 3 evidence gathering becomes embedded throughout the construction process rather than treated as a last-minute exercise at completion.
The Industry Needs Better Guidance — Not Weaker Regulation
Despite the difficulties, I remain strongly supportive of the wider direction of travel under the Building Safety Act.
The industry needed stronger accountability, clearer coordination and better technical oversight. In the long term, the regime should absolutely improve the quality and safety of buildings being delivered.
However, the system now needs to mature operationally. The current burden placed on applicants trying to interpret evolving expectations while managing live construction projects is not sustainable.
That is why ongoing dialogue between the regulator and experienced industry professionals is so important. Real-world project delivery experience matters. Technical understanding matters. Practical construction knowledge matters.
The fact that the BSR is actively engaging with professionals delivering these projects daily is a positive sign. It demonstrates recognition that industry expertise has an essential role to play in helping the regime evolve into something clearer, more practical and ultimately more effective.
At Folly Architects, we expect Building Safety and HRB advisory work to continue forming a major part of our practice as the industry adapts further to the realities of the Gateway system.
Contact us
If you would like to discuss a project, clarify regulatory requirements, or understand how our experience may be relevant to your work, you are welcome to get in touch.
