What is “change control” under the Building Safety Act?
A practical definition
Under the Building Safety Act 2022, change control refers to the formal process for managing and approving changes to design, construction information or scope on Higher-Risk Building (HRB) projects once regulatory submissions have been made.
Change control is particularly relevant following Gateway 2 approval, where the Building Safety Regulator expects the approved design, fire strategy and compliance information to be built in accordance with what has been submitted.
The purpose of change control is not to prevent change, but to ensure that any change is understood, assessed and properly recorded before it is implemented.
Frequently asked questions
The following questions and answers summarise common queries relating to this topic.
Change control applies on Higher-Risk Building projects once a Gateway 2 submission has been approved and construction is underway.
In practice, this includes changes such as amendments to layouts, structure, materials or fire safety measures, particularly where those changes affect information previously agreed with the regulator.
Even relatively small changes can trigger change control where they impact fire strategy, compartmentation or compliance assumptions established at Gateway 2.
On non-HRB projects, design changes are often managed informally. Under the Building Safety Act, this approach is no longer appropriate for HRBs.
Uncontrolled changes can undermine approved compliance strategies, create inconsistencies within the Golden Thread, and lead to regulatory challenge or delay at completion.
Clear change control ensures that approved design intent, compliance information and constructed reality remain aligned throughout the project lifecycle.
Information developed for Gateway 2 and Gateway 3 submissions typically forms a key part of the Golden Thread and must be capable of being maintained and updated beyond handover. Early consideration of Golden Thread requirements helps avoid gaps or inconsistencies later in the project.Responsibility for managing change control sits across the project team but must be clearly defined.
In practice, designers identify proposed changes, while the Principal Designer (Building Regulations) plays a key role in coordinating and assessing their compliance impact.
Dutyholders must ensure changes are properly recorded and approved where required, with the client retaining responsibility for ensuring appropriate processes are followed.
During design and construction, responsibility is shared between the client and appointed dutyholders. Following completion, responsibility for maintaining the Golden Thread information typically sits with the building owner or Accountable Person. Clear allocation of responsibility is essential to ensure that information remains accurate, accessible and usable over time.Gateway 2 approval establishes a baseline of accepted information. Any deviation from this baseline must be identified, assessed and recorded within the Golden Thread.
Where required, changes must be submitted to the Building Safety Regulator to ensure regulatory oversight is maintained and information relied upon at completion remains accurate.
Our approach to managing change control on HRB projects
Management of change control follows a clear and structured approach to ensure changes are assessed, coordinated and properly recorded.
1. Identifying changes and compliance impact
We review proposed changes against approved Gateway 2 information to identify whether fire safety, structural or regulatory assumptions are affected.
2. Coordinating assessment and approvals
Where change control applies, we coordinate updated drawings, reports and compliance documentation to support proportionate review and approval.
3. Maintaining a clear audit trail
Changes are documented in a structured manner to support Gateway processes, Golden Thread requirements and future regulatory review.
Early coordination is recommended where change control requirements or responsibilities are unclear.
Why change control is often misunderstood
Change control is sometimes seen as an administrative burden. In reality, it is a risk-management tool intended to prevent late-stage redesign, regulatory challenge and programme delay. Most difficulties arise where change control is introduced too late or where changes are assumed to be resolvable informally.
Change control interacts closely with other HRB requirements, including Gateway 2 applications, Golden Thread information and High Risk Building Consultancy Services. If you are working on a Higher-Risk Building project and are unsure how change control should be applied, early advisory input can help reduce risk and avoid delay. To discuss a specific project or regulatory question, you can contact Folly Architects at hello@follyarchitects.com.
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.
