Registering a higher-risk building, and getting it right first time

Registration is the moment a higher-risk building formally enters the regime, and on paper it looks like the simplest of the Accountable Person's duties: identify the building, identify who is accountable, and submit. In our view that framing is exactly why it goes wrong. A registration treated as a form gets filled in to the minimum standard, and the gaps it papers over surface later, when the safety case is being assembled or the Regulator asks a question the registration quietly got wrong.

What registration is, and when it bites

Under the Building Safety Act 2022, the Accountable Person must register an occupied higher-risk building with the Building Safety Regulator before it is occupied, and keep the registration accurate. A higher-risk building here is one at least 18m tall or with at least 7 storeys, whichever comes first, with at least two residential units. The Regulator became the Building Control Authority for higher-risk buildings in England in October 2023, and registration is the front door to its occupation-phase oversight.

The duty to keep it accurate is the part we think gets underweighted. Registration is not a one-time event you can forget. If the accountable parties change, or the building's relevant details change, the record has to follow. A registration that was right on day one and never touched again becomes wrong by neglect.

Where we see registrations go wrong

Three problems recur, and all of them trace back to treating registration as paperwork rather than as the first assertion of the building's golden thread.

• The classification is shaky. The height or storey count was estimated rather than determined, so the very basis for registering, or not, rests on an approximation. A building near the line deserves a documented measurement before anyone submits.
• The accountable parties are unclear. Where the structure and common parts are split across several owners, each is an Accountable Person for their part and one must be the Principal Accountable Person. A registration that fudges who is who creates a duty gap that no one owns.
• The supporting information is thin. Registration is the moment to confirm the building's basic record exists, and a submission made without the plans, the external wall position and the safety information behind it is a registration without foundations.

We think the right mindset is that registration is the first test of whether the golden thread exists, not a precursor to building it. If you cannot register confidently because the underlying facts are not settled, that is the registration doing its job: telling you the record is not ready.

Getting the classification settled first

The classification decision deserves its own moment before anything is submitted. As covered in higher-risk buildings: who counts, and what changes at 18 metres, the threshold is precise but applying it to a real building takes care, and the difference of a few centimetres or a single storey changes the regime entirely.

Our view is to record the determination properly: the measured height, the storey count, the basis of measurement, and the count of residential units, with the date and the person who determined it. That record is cheap to make once and expensive to reconstruct later under question. It also means a future manager inherits a settled fact rather than re-running the measurement.

A first-time-right checklist

We would not submit a registration without being able to answer each of these honestly.

• Classification: the height, storeys and unit count determined and dated, not estimated.
• Accountable parties: each Accountable Person identified, and a Principal Accountable Person named where there are several.
• Building record: the plans and external wall information held.
• Safety information: the basis of the safety case actually exists.
• Maintenance: someone owns keeping the registration accurate after submission.

The last point is the one we would press hardest. Someone has to own keeping the registration accurate after submission, or the duty to keep it current has no home and the record drifts.

Why first-time-right is worth the friction

It is tempting to register quickly to clear the duty and tidy up the detail afterwards. We think that gets the order wrong. The detail is the duty. A fast, thin registration does not make the building compliant; it makes the building registered, which is not the same thing, and it leaves the real work to be done later under more pressure, often by someone who inherited a record they did not build.

A registration done properly, by contrast, forces the building's basic record into order at the start, which is the cheapest time to do it. Everything downstream, the safety case, the resident engagement system, the standing duties, draws on that record. Get it settled at registration and the rest is built on solid ground.

The practical close

Registration is the regime's first ask, and in our reading it is best treated as the first assembly of the golden thread rather than a form to be cleared. Settle the classification, name the accountable parties, confirm the record exists, and decide who keeps it accurate. Do that, and registration stops being a hurdle and becomes the foundation the rest of the duties sit on.

SAMRISK holds the classification, the accountable parties, the plans and the safety information against one building record, so a registration is drawn from settled facts and stays accurate as the building changes. You can see how buildings are organised on the buildings page and how the safety case builds on the same record on the safety case page. This is our reading of good practice and general information rather than legal advice, and a specific registration should be prepared with your own advisers and checked against the Regulator's current requirements.