When the Building Safety Act received Royal Assent in April 2022, much of the public commentary focused on the structural and political changes it introduced — the creation of the Building Safety Regulator, thethree-stage Gateway approval regime, the requirement for an Accountable Person on every higher-risk building. For passive fire protection contractors and the Responsible Persons we work for, the more important change is quieter and more operational: the legal duty to assemble and maintain a golden thread of digital information that describes how the building’s fire safety was designed and built.
In practical terms, the golden thread requirement means that for any building defined as higher-risk — generally 18m or more in height, or 7+ storeys, with at least two residential units — the as-built evidence of every passive fire protection element must now exist as a structured, accessible, accurate digital record. That includes every penetration seal, every cavity barrier, every fire-rated doorset, every coated structural steel section, every compartment line and every interface between them. The record must include the location, the system reference, the operative, the date, and (in almost every case) photographic evidence of the work before and after installation.
For projects that began before April 2022 and have not yet been handed over, the practical implication is significant. A passive fire protection contractor who has been working in the old style — paper records, occasional photographs, handover packs assembled from email — will struggle to deliver an O&M; that satisfies the regulator at Gateway 3. That is the single biggest reason we hear from clients moving away from incumbent suppliers and adopting a contractor with a digital quality platform built around the new regulatory expectation.
Even for buildings outside the strict higher-risk definition, the direction of regulatory travel is unambiguous. Insurers, lenders, institutional investors and increasingly local authorities are aligning their procurement, due-diligence and risk-assurance processes with the Building Safety Act’s evidential expectations. “It’s not an HRB” is rapidly becoming a reason to start preparing, not a reason to relax.
Three practical actions any Responsible Person should be taking now: first, audit the documentation you already hold on your building’s passive fire protection — where it’s missing, accept that you have a gap to close; second, choose your future passive fire contractor on the strength of their data systems, not just their price; third, integrate the resulting golden thread into your ongoing fire risk assessment regime so that the next FRA builds on, rather than duplicates, what already exists.
