BSR’s New Approach to Higher-Risk Building Assessments: What It Means for Duty Holders

Earlier this month, the Building Safety Regulator (BSR) announced plans to update the approach on Building Assessment Certificates (BACs) for occupied Higher-Risk Buildings (HRBs).  

The proposed approach is intended to be more proportionate and targeted, while continuing to maintain high standards of building safety.  

The change follows feedback from Principal Accountable Persons (PAPs), financial institutions and other stakeholders on the implementation of the BAC regime under the Building Safety Act 2022.  

Why the change matters

Since the BAC process began in April 2024, the BSR has directed PAPs to apply for certificates for nearly 2,000 buildings.  

The BAC process has faced challenges: assessment times have been longer than expected (approximately 1 year on average2) and a significant proportion of applications have been refused;  

Catalyst raised a FOI with the BSR earlier this year; as of Jan 2026, only 34% of applications received had been assessed and of those assessed, roughly three quarters (73.2%) were rejected.

In their latest press release, the BSR noted that to date (9th July 2026); 66% of applications have been refused1. The BSR has indicated that refusals often arise where applications focus too heavily on process compliance, rather than demonstrating effective management of fire spread and structural safety risks. 

As part of our BSA Part 4 service offering, Catalyst have been undertaking peer reviews of existing Building Safety Case Reports (BSCRs); our observations reflect those of the BSR. Generally, BSCR focus on whether the design complies with building regulations, predominantly in relation to fire safety. We have reviewed reports where there is no reference to structural risk except for structural fire resistance.  

Furthermore, where risks have been identified within the BSCR, then the safety management section of the report falls short. Generally, there is insufficient detail and evidence as to how the risks identified have been actively managed and reduced.  

Our advice to clients is that evidence is required to demonstrate not only that procedures exist, but that these are being implemented. The BSCR should show that risks are being actively understood, managed and reviewed. This should be supported with evidence; copies of checks, extracts of CAFMs (computer aided facility management) etc.  

What is expected to change? 

Under the proposed approach, the BSR intends to call in new BAC applications only where necessary while improved processes are developed and communicated. It will prioritise applications already under assessment, consider proportionate fast-track reassessments for previously refused certificates once standards are met, and provide more targeted support for resident-led PAPs. 

The future processes the BSR are looking to implement include;   

• Refining the risk-based approach, with an initial focus on organisations responsible for multiple HRBs  

• Using risk- or intelligence-led sample interventions for buildings, organisations and duty holders  

• Giving smaller, volunteer-led resident management companies more time to prepare evidence  

• Supporting live applications and previously refused applicants completing required building safety actions 

Furthermore, the BSR is looking to provide updated guidance to the industry from September 2026.  

However, the BSR has been clear that the underlying legal duties remain in place for PAPs and APs. HRBs must be managed so that the building and occupants are safe. Building Safety Cases should be drafted and be constantly reviewed and updated to ensure that risks are being actively prevented, mitigated and monitored.  

The key takeaway

The direction of travel is positive: a more risk-based, targeted and supportive assessment process should make the BAC regime more workable without weakening its purpose.

As the BSR develops the foundation plan, PAPs and APs should use the opportunity to review their building safety case information, resident engagement arrangements and evidence of active risk managemnt.

The assessment process may be changing, but the expectation remains the same: safer buildings, clearer accountability and better outcomes for residents.

While new guidance is due to be released, the legislation (and therefore the duties) of PAPs & APs remains the same. The Catalyst team have successfully supported Clients in their Building Assessment Application Process under the current guidance; including with HRBs that had previously been rejected.

Want to learn how Catalyst can help? Get in touch.