Building Safety Act duties explained: Accountable Persons, the Golden Thread and what to do now

The Building Safety Act has reshaped how residential buildings are owned, managed, and maintained across England. If you own, manage, or operate residential premises, the duties are now more explicit, the evidence threshold is higher, and regulators expect a coherent story that links design intent to day-to-day fire safety management. Getting this right protects people and demonstrates that you are in control.

Safeguard Consultancy helps owners, managing agents, and facilities leaders translate the Act into practical actions. This briefing explains who must comply, what counts as a High-Rise Residential Building, how Accountable Persons work in practice, what the Golden Thread really looks like on the ground, and how routine fire safety activities interlock to show compliance.

Who must comply and what buildings are covered

The Building Safety Act applies across the built environment, but its highest duties focus on High-Rise Residential Buildings (HRRBs). Broadly:

• HRRBs are buildings in England that are at least 18 metres in height or have at least 7 storeys, and contain at least 2 residential units. These are subject to Building Safety Regulator oversight, Accountable Person duties, registration, and safety case principles.
• Residential buildings below 18 metres remain subject to the Fire Safety Order, Section 156 updates, and Building Regulations duties; some specific BSA provisions still apply, particularly around competence and information management in design and construction.

Typical duty holders include building owners, freeholders, superior landlords, right to manage companies, resident management companies, housing associations, local authorities, and anyone with repairing obligations for common parts. Managing agents and facilities managers are often appointed to deliver duties on behalf of the legal duty holder, but legal accountability remains with the body or person in control.

11 metres vs 18 metres, explained

Confusion often arises around the two thresholds:

• 18 metres or 7 storeys triggers the HRRB regime, which includes the Accountable Person framework, safety case approach, and registration with the Building Safety Regulator for occupied buildings that meet the criteria.
• 11 metres is a key trigger used elsewhere in the regulatory landscape, for example in guidance and standards for life safety systems and evacuation equipment, and for certain product or remedial expectations in medium-rise buildings. It does not, by itself, create HRRB status, but it can change what good practice looks like and can influence enforcement expectations.

In practice, you should assess your building against both thresholds, then align measures to Approved Document B and relevant British Standards such as BS 9999 and BS 9991. If you operate mixed portfolios, apply a risk-based approach that recognises medium-rise vulnerabilities even when the full HRRB regime does not apply.

Accountable Persons and the Principal Accountable Person

An Accountable Person (AP) is any organisation or individual with a legal obligation to repair or maintain any part of the common parts of a HRRB. There can be multiple APs in a single building. The Principal Accountable Person (PAP) is the AP responsible for the structure and exterior, or otherwise designated under the Act where multiple APs exist.

Key expectations for the PAP typically include:

• Identifying all APs and clarifying interfaces and boundaries.
• Registering the building (where applicable) and maintaining the safety case approach.
• Managing resident engagement on building safety information.
• Ensuring the Golden Thread is created, controlled, and kept up to date.

Other APs must cooperate and coordinate. Clear contracts and documented arrangements are essential so that evidence, inspections, and remedial works are not duplicated or, worse, missed.

The Golden Thread, in practical terms

The Golden Thread is not just a file repository. It is a controlled, accurate, and accessible set of information that explains how the building is designed, built, altered, operated, and maintained to keep people safe. It should be digital, structured, and version controlled.

A practical Golden Thread for residential buildings usually contains:

• A fire strategy that describes the design intent, compartmentation, means of escape, detection and alarm measures, and the management strategy. Where no clear strategy exists for legacy buildings, commission a retrospective fire strategy aligned with Approved Document B and BS 9999 principles.
• Fire Risk Assessments (FRAs) suitable for the premises. In general needs housing, this can include Type 1 to Type 4 formats depending on scope. Evidence from a competent fire risk assessor must be clear, prioritised, and actionable.
• Compartmentation and fire door evidence. Commission a targeted fire compartmentation survey for lines of defence and a routine programme of fire door inspections so defects, fire-stopping, and penetrations are identified and rectified. Photographic records with location references, product data sheets, and close-out photos help prove that repairs were correct.
• Maintenance and testing records. Keep test logs for alarms, emergency lighting, smoke control, sprinklers, and other systems, alongside certificates and corrective actions. Link these to asset lists and manufacturer information where possible.
• Evacuation plans and resident information. Your evacuation strategy must match the strategy stated in the fire strategy and the building’s condition. Keep accessible versions for residents, plus operational versions for building teams and the fire and rescue service.
• Change control. Record refurbishments, service penetrations, plant upgrades, and layout changes. Tie these updates back to compartment lines and evacuation assumptions.

Safeguard Consultancy supports the Golden Thread by integrating fire safety surveys, compartmentation evidence, and management documentation into a coherent, auditable package that stands up to regulator scrutiny.

Where Section 156 of the Fire Safety Order fits

Section 156 changes strengthened the Regulatory Reform (Fire Safety) Order 2005. In essence, they:

• Clarify that Responsible Persons must record more of their fire safety information in writing, including fire risk assessment findings and fire safety arrangements.
• Require cooperation and coordination between Responsible Persons sharing premises.
• Increase information sharing with residents and other relevant persons.

This dovetails with the BSA approach: more written evidence, clearer accountability, and better communication.

What happens if you do not comply

Non-compliance can lead to enforcement notices, criminal prosecution, and significant reputational harm. The Building Safety Regulator, local authority building control, and fire and rescue services have escalating powers. For HRRBs, failure to register, provide accurate information, or manage building risks can attract penalties. Even outside the HRRB regime, failing to comply with the Fire Safety Order can result in prosecution where risk is not controlled. Insurance consequences and civil liabilities are also real considerations.

How fire safety activities interlock to prove compliance

Think of compliance as an evidence chain:

• The fire strategy defines intent and constraints.
• The fire risk assessment tests real-world conditions against that intent.
• Compartmentation surveys and fire door inspections verify the passive fire protection backbone.
• Maintenance records demonstrate that active systems work when needed.
• Evacuation plans align with the building’s design and condition.
• Version-controlled records show a living system of management.

When each link is current and referenced, you can show both control and continuous improvement.

A practical action plan for 2026

• Confirm whether your building is a HRRB. If it is, confirm the PAP, identify all APs, and ensure registration and safety case arrangements are in place.
• Establish or refresh the fire strategy. Where gaps exist, commission a retrospective strategy aligned to Approved Document B and BS 9999.
• Commission a competent fire risk assessment and set a review cycle that reflects building risk and change.
• Programme fire door inspections and a targeted fire compartmentation survey, then close defects with properly specified fire-stopping, product data, and third-party certification where appropriate.
• Align evacuation plans with the strategy, update resident information, and document PEEPs or alternatives where applicable.
• Tighten your Golden Thread. Move to structured digital records with version control and change logs.
• Embed Section 156 requirements into contracts and management arrangements so information is consistently recorded and shared.

Safeguard Consultancy can deliver building fire surveys, set up the documentation backbone, and provide ongoing support to keep your evidence current and coherent.

FAQ

• Who needs to comply with the Building Safety Act?
  Duty holders across residential buildings are affected, with the highest duties applying to HRRBs. Owners, freeholders, housing associations, local authorities, and others with repairing obligations for common parts are typically Accountable Persons. Managing agents often deliver tasks, but legal accountability rests with the controlling body.

• Is the Building Safety Act about 11 metres or 18 metres?
  18 metres or 7 storeys defines HRRBs and triggers the enhanced regime. The 11 metre level influences certain guidance and expectations but does not create HRRB status on its own.

• Who is an Accountable Person and who is the Principal Accountable Person?
  Any party with repairing obligations for common parts in a HRRB can be an Accountable Person. The Principal Accountable Person is the AP responsible for the structure and exterior, or otherwise designated, and leads on registration, coordination, and the Golden Thread.

• What happens if I do not comply with building regulations and fire safety law?
  You may face enforcement, prosecution, financial penalties, and reputational damage. Insurers and civil liability exposures are additional risks.

• What is the Golden Thread in building safety regulations?
  A controlled, accurate, digital information set that explains design intent, construction, alterations, and ongoing management, including strategy, FRAs, surveys, maintenance records, and evacuation arrangements.

Helpful resources and how Safeguard Consultancy can assist

For owners and managers wanting to move quickly from uncertainty to control, Safeguard Consultancy provides:

• Competent fire risk assessment services for residential and commercial portfolios, linked to prioritised actions and evidence management. See our guidance on fire risk assessment and our page for a residential fire risk assessment to understand scope options for blocks of flats and HMOs.
• Targeted fire compartmentation surveying and fire door inspections with photographic evidence, product data, and installer sign-offs to support the Golden Thread. Explore how a fire compartmentation survey can underpin passive fire protection planning, and read about fire door inspections to build your programme.
• Regulatory guidance aligned to Approved Document B, BS 9999, and the Building Safety Act to strengthen your documentation and compliance posture.

Next step: if you operate a HRRB or a medium-rise residential building and need to establish the PAP role, build the Golden Thread, or schedule surveys, contact Safeguard Consultancy. We provide nationwide support and bring over 30 years of experience to help you move from obligation to demonstrable compliance.

Summary: Identify whether you are within the HRRB regime, clarify AP and PAP roles, and build a structured Golden Thread that links strategy, assessment, surveys, maintenance, and evacuation plans. Use Section 156 principles to strengthen record keeping and cooperation. Safeguard Consultancy can help you plan, evidence, and maintain compliance with confidence.

Internal links included for your convenience:

• Learn more about our fire risk assessment service: https://safeguardconsultancy.co.uk/fire-risk-assessment/
• Fire compartmentation surveying overview: https://safeguardconsultancy.co.uk/fire-compartmentation-surveying/
• Fire door inspections and surveys: https://safeguardconsultancy.co.uk/fire-door-survey/