Navigating the Gateway 2 process

The introduction of the Building Safety Act’s new regulatory regime has unquestionably reshaped the UK construction landscape. Intended to enhance occupant safety on higher-risk residential buildings, the Building Safety Regulator’s Gateway 2 approval process has proven more complex and time-consuming than many in the industry anticipated. While statutory targets envisage decisions in 12 weeks for new build submissions, actual experience across the sector has seen Gateway 2 approvals extend well beyond this timeframe - averaging more than 30 weeks in practice and with some applications stretching close to nine months before meaningful engagement from the regulator.

Throughout 2025 the industry has seen hundreds of new-build applications and tens of thousands of homes move through the Gateway 2 system, with reforms including the establishment of a dedicated Innovation Unit helping to improve turnaround on many cases and achieve record volumes of determinations toward the end of the year.

Despite these positive shifts, the perception of risk and unfamiliarity with the new regime has slowed project starts, recalibrated investment strategies, and encouraged some developers and investors to pause or defer schemes rather than push forward under uncertainty.

In 2025, at Design Delivery Unit, we submitted five Gateway 2 applications – all validated first time within two weeks – and one further application was submitted in 2026, representing a total of 1,258 homes across six complex mixed-use residential developments. Four schemes have already achieved approval, with the remaining two significantly progressed through the Building Safety Regulator’s review. Our experience reinforces that delivery of modern higher-risk residential and mixed-use schemes demands clarity, communication, and strategy from day one.

One of the hardest lessons for many clients has been appreciating just how early compliance requirements influence design and delivery sequencing. For larger multi-phased developments, discussing project strategy before design starts has been critical - particularly around sequencing of buildings, shared basements, and centralised services like energy centres, which must be completed and commissioned ahead of residential occupation. Partial completion strategies are a viable alternative but require careful coordination and alignment across design, procurement and construction teams.

We’ve also seen that specialist design input must come in far earlier than in previous regulatory eras. Disciplines such as sprinkler systems, smoke and ventilation control, lifts and façades (especially unitised and precast) now play a central role in compliance statements - not simply as contractors tendering against a fixed design. Many of these specialists are not yet accustomed to early-stage multidisciplinary team engagement, and it’s been essential to foster iterative design collaboration rather than assume a traditional hand-off model.

Another recurring insight has been the need to distinguish between what is required to prove compliance and what is required to build the project. There’s a risk of clients being caught in over-resourcing their teams and producing documentation that isn’t needed at the point of a regulator review. Our view has become: less can indeed be more - but less should also be clear. Deliverables must be concise, targeted and aligned to regulatory checkpoints and construction sequencing. This is where a compliance statement document structure agreed at the outset across the design team can help serve as a storyboard on who needs to produce what, how it works with others and what evidence is required.

We remain optimistic though. The initial unknowns of the Gateway 2 regime are becoming better understood, and reforms such as the Innovation Unit and anticipated consolidation of compliance bodies point toward a more predictable process. As the Building Safety Regulator continues to evolve and the system moves into its next chapter, we approach 2026 with confidence in our ability to steer complex residential schemes to positive outcomes.

If you are working on higher-risk buildings, have a complex scheme you wish to discuss, or would like to hear more about how we can support your projects, please get in touch.