Building assessment certificates, and the duties that do not pause

On 9 July the Building Safety Regulator published what it calls a building assessment certificate foundation plan. The short version is that the regulator has stopped directing new applications while it rebuilds the process, and will only call one in where there is a reason to.

The figures behind that decision are worth reading carefully. Since April 2024 the BSR has directed nearly 2,000 buildings to apply for a certificate. Assessments have taken around twice as long as expected. And 66% of applications have been refused so far this year (BSR, July 2026).

Two thirds. That is not a story about unsafe buildings, and reading it as one would be a mistake.

What a refusal actually means

A building assessment certificate is the regulator's confirmation that the accountable persons for an occupied higher-risk building are meeting their duties under the Building Safety Act 2022. The heart of the application is the safety case report: the document that sets out the building's fire and structural risks and the evidence that they are being managed.

A refusal is a judgement on that submission. In most cases it means the evidence did not demonstrate what the applicant believed it demonstrated. The fire strategy was there but the maintenance records supporting it were not. The resident engagement strategy existed as a document but not as a practice with a trail behind it. The building's own history was distributed across a managing agent, a contractor, a consultant and a filing cabinet, and the version submitted was the version somebody could find in the time available.

The regulator has effectively conceded that the process asked more of duty holders than the process itself made possible, particularly for the smaller, volunteer-run resident management companies who carry the same statutory weight as a national landlord with a compliance department. Those buildings get named contacts, pre-application advice, and more time to prepare their evidence. Simplified assessment criteria and updated technical guidance are expected from September.

The duties did not pause

This is the part that will get lost. The certificate has paused. Nothing underneath it has.

Principal accountable persons must still prepare and maintain a safety case report, a duty that has been enforceable since January 2024. They must still operate a mandatory occurrence reporting system, and still have a resident engagement strategy that works. The Regulatory Reform (Fire Safety) Order 2005 and the Housing Act 2004 sit alongside all of it, untouched by any of this. The BSR is clear that a certificate is a snapshot of a point in time rather than a standing state of grace, and that it intends to reassess buildings roughly every five years.

So the accurate reading of July's announcement is not "we have longer". It is "the assessment will come, later, against clearer criteria, and the evidence you can produce on the day is still the whole test".

What the next two months are for

The gap between now and September is the most useful stretch of time a principal accountable person has had since the regime started, precisely because nothing is due in it.

The questions are narrow and the answers are either in your records or they are not.

Is the safety case report current, or is it the version written for a submission and not touched since. Have the risks in it changed, and does the document say so. When a fire door inspection or a lift examination is cited as a control, can you produce the last four rounds of it without asking anyone. Does the mandatory occurrence reporting route exist as a named person and a defined path, or as a paragraph. Can you show a resident raising a safety concern, and what happened next, with dates.

None of that is new work invented by the regulator. It is the work the duties already describe. The certificate was only ever the moment someone asked to see it.

Records, not documents

The reason two thirds of applications failed is worth being blunt about. Most of these buildings are managed competently by people who know them well. What failed was the record, not the management.

A safety case is not a document that gets written. It is a document that gets assembled, from a safety case record that has been accumulating since the last one. The controls it relies on are risk assessments with dates and owners, fire safety checks that were logged when they happened rather than reconstructed afterwards, maintenance with a history attached, and documents held in versions so the certificate you are relying on is the current certificate. Incidents close the loop, because an occurrence reporting system is only real if you can show what was reported and what followed.

Assembled from that, a safety case report takes an afternoon and says something true. Written from scratch under a 28 day deadline, it takes weeks and says whatever could be evidenced in the time.

The regulator has given the sector a pause. The buildings that use it on the record rather than the submission will be the ones that find September straightforward.

Source: Building Safety Regulator, "BSR to introduce more proportionate and targeted approach for higher-risk building assessments", 9 July 2026.