The Building Safety Act 2022 represents one of the most significant changes to building regulation in the UK construction industry for decades. Introduced to strengthen accountability, improve oversight and enhance building safety, the legislation has fundamentally changed how higher risk buildings are designed, approved and delivered.
At the centre of these reforms is the Gateway process, which introduces key regulatory checkpoints throughout the lifecycle of a project. While the intention is to improve safety and transparency, the new requirements are creating practical challenges for architects, contractors and developers who must navigate stricter documentation standards, clearer design responsibilities and more rigorous regulatory scrutiny.
For façade systems and external wall insulation (EWI) installations, the implications are particularly important.
Understanding the Gateway Process
The Building Safety Act introduces three Gateways that act as regulatory approval points overseen by the Building Safety Regulator.
Gateway 1 – Planning Stage
Gateway 1 applies during the planning stage and requires fire safety considerations to be addressed earlier in the design process.
Architects must submit a Fire Statement as part of the planning application. This document explains how fire safety has been considered within the design, including the building layout, evacuation strategy and access for emergency services.
Although Gateway 1 focuses largely on planning and fire strategy, it is also encouraging earlier consideration of façade design and external wall construction.
Gateway 2 – Before Construction Begins
Gateway 2 represents the most significant change for many projects.
Before construction can begin on higher risk buildings, the Building Safety Regulator must approve the detailed design. At this stage the design must be sufficiently developed to demonstrate compliance with building regulations.
This means project teams must submit detailed design information, construction methods and supporting technical evidence. Once approval is granted, design changes become far more difficult to implement.
For contractors and developers, this is shifting the industry towards earlier design certainty and greater collaboration between architects, engineers and specialist suppliers.
Gateway 3 – Completion and Occupation
Gateway 3 takes place at the completion of the project before the building can be occupied.
The project team must demonstrate that the building has been constructed in accordance with the approved design and regulatory requirements. This includes providing detailed documentation as part of the Golden Thread of information, ensuring that accurate building safety information is available throughout the building’s lifecycle.
Common Challenges Emerging Across the Industry
While the Gateway process is improving oversight, many project teams are encountering practical challenges when adapting to the new regulatory environment.
Late Design Changes
One of the most common issues occurs when façade systems or insulation specifications change late in the design process.
Under Gateway 2 requirements, significant design changes may require resubmission to the Building Safety Regulator, which can lead to delays and additional project costs.
For architects and contractors, this highlights the importance of finalising façade system specifications early in the design stage.
Documentation and Compliance Evidence
The Building Safety Act places strong emphasis on traceable documentation.
Project teams must now demonstrate clear evidence of product performance, system suitability and installation competence. In many cases this requires more detailed technical documentation than was previously expected.
Where product data or certification is difficult to obtain, it can slow down the approval process and create uncertainty for project teams.
System Performance and Design Responsibility
Another emerging challenge is the need to demonstrate that external wall systems perform as intended across multiple criteria.
This includes fire performance, structural suitability, thermal efficiency and moisture management. As a result, many specifiers are moving away from selecting individual products and are instead specifying complete façade systems that have been tested and assessed as a whole.
Supporting Compliance in EWI and Façade Systems
In response to these industry changes, system manufacturers are increasingly providing technical services that help project teams demonstrate compliance and reduce design risk.
Technical Specification Support
Providing project specific façade system specifications can help ensure that designs are compliant with building regulations and suitable for the project conditions.
Early engagement with manufacturers allows design teams to confirm system build ups, performance requirements and compatibility between components before Gateway 2 submission.
Building Physics Analysis
Technical analysis is becoming increasingly important in demonstrating façade performance.
Building physics assessments may include U value calculations, thermal bridge analysis, wind load calculations and WUFI modelling. These assessments can help designers understand how a façade system will perform in real world conditions and provide supporting evidence for regulatory approval.
Approved Installer Networks
Installation quality is another key consideration under the Building Safety Act.
Many manufacturers operate approved installer networks supported by training programmes and competency frameworks. This helps ensure systems are installed correctly and provides an additional level of accountability for the project.
For contractors and developers, working with trained and approved installers can help demonstrate competence and reduce the risk of installation related issues.
Clear Technical Documentation
Access to clear and reliable technical documentation is becoming increasingly important for maintaining the Golden Thread of information.
System build ups, certification, installation guidance and maintenance information all form part of the evidence required to demonstrate compliance and long term building safety.
Manufacturers that provide structured technical resources can help simplify this process for project teams.
Looking Ahead
The Building Safety Act represents a major cultural shift for the construction industry. While the Gateway process introduces additional scrutiny and documentation requirements, it is also encouraging better collaboration, clearer accountability and stronger design certainty.
For architects and contractors working with façade systems, success under the new regulatory framework will depend on early planning, robust system specification and access to reliable technical support.
By engaging with system manufacturers and technical specialists early in the design process, project teams can better manage Gateway requirements while delivering buildings that meet both regulatory expectations and long-term performance standards.