Building Safety Act 2022 and the Golden Thread: What Dutyholders Must Have in Place Right Now

TL;DR

• The Building Safety Act 2022 places a legal duty on dutyholders to build and maintain a golden thread of digital building information.

• Higher-risk buildings -- those at least 18 metres high or 7 storeys with 2 or more residential units -- are in scope.

• Dutyholders include clients, principal designers, principal contractors, accountable persons, and the principal accountable person.

• The golden thread must be kept digitally, securely, and updated throughout the building's full lifecycle.

• Failure to comply can result in enforcement action, unlimited fines, and personal liability for named dutyholders.

The Grenfell Tower fire exposed a catastrophic failure in how building safety information was managed. The Building Safety Act 2022 was designed to fix that. At its centre is the golden thread: a secure, living digital record of everything that matters for the safety of a higher-risk building.

If you are a dutyholder under the Act, the golden thread is not optional. It is a legal obligation. And with the Building Safety Regulator actively scrutinising compliance, the question is no longer whether you need it in place. It is whether what you currently have meets the standard required.

This guide explains what the golden thread demands from each category of dutyholder, what information must be kept, how it must be stored, and what you need to have in place right now.

What Is the Golden Thread Under the Building Safety Act 2022?

The golden thread is a digital record of all the information needed to understand a higher-risk building and ensure it remains safe throughout its life. The term is not a management concept. It is a legal requirement under Section 88 of the Building Safety Act 2022.

The golden thread came into force on 1 October 2023. From that date, dutyholders have been legally required to create, maintain, and share this information. It covers the building's design, construction, ongoing maintenance, and all safety-critical changes made during its occupation.

At its simplest, the golden thread is how you prove you know your building, understand its risks, and can demonstrate how those risks are being managed.

Why Was the Golden Thread Introduced?

The Hackitt Review, commissioned after the Grenfell Tower fire, identified a fundamental systemic failure: nobody had a clear, complete picture of how the building had been designed, built, or modified over time. The golden thread was the review's central recommendation to prevent that from happening again.

The Act makes it a legal duty to ensure the information trail is never broken, from initial design through construction and into occupation for the life of the building.

Which Buildings Does It Apply To?

The golden thread applies to higher-risk buildings. Under the Building Safety Act 2022, a higher-risk building must be at least 18 metres high or have at least 7 storeys, and must contain at least 2 residential units or be a hospital or care home.

• At least 18 metres high or at least 7 storeys

• Contains at least 2 residential units, or is a hospital or care home

• Must be registered with the Building Safety Regulator before residents move in

Who Are Dutyholders Under the Building Safety Act?

The Act places specific duties on named parties at each stage of a building's life. These are referred to collectively as dutyholders. Each category carries distinct obligations and the duties cannot be delegated.

The Client

During design and construction, the client carries primary responsibility for establishing the golden thread. The client must set up a digital record-keeping system, define policies and procedures for managing information securely, and share building information with every designer and contractor on the project.

The client is also responsible for handing over the complete golden thread at the end of construction to the accountable person, or for non-residential buildings, to the Responsible Person under fire safety law.

Principal Designer and Principal Contractor

The principal designer must capture and keep all design information up to date. They must work with the principal contractor to ensure that design changes are recorded and evidenced throughout the construction phase.

The principal contractor must use the client's record-keeping system and keep building information current as work progresses. They must maintain evidence that work meets building regulations and manage change control in collaboration with the design team.

Accountable Persons and the Principal Accountable Person

Once a building is occupied, the duty to maintain the golden thread passes to the accountable persons (APs) and the principal accountable person (PAP). These are the individuals or organisations that hold a legal estate in, or have repairing obligations for, the common parts of the building.

Where more than one AP exists, the PAP coordinates safety management across all of them. The PAP must ensure all APs understand the policies in place for keeping and storing building information.

APs and the PAP must maintain the golden thread and be ready to provide it on request to the Building Safety Regulator, other accountable persons, and building residents.

What Information Must Be Kept in the Golden Thread?

The information required differs depending on whether the building is in the design and construction phase or already occupied.

During Design and Construction

During the design and construction phase, the client must ensure the following are captured and kept current:

• Drawings and plans

• Competence declarations

• Construction control plan

• Change control plan and log

• Building regulations compliance statement

• Fire and emergency file

• Client authorisation records

• Mandatory occurrence reporting plan

• Planning statement and partial completion strategy

During Occupation

Once occupied, accountable persons must maintain:

• The health and safety file

• The safety case report

• A residents' engagement strategy

• A mandatory occurrence reporting system

Additional records should also be held where available, including information about any refurbishments, historical records from previous owners, and documentation of the standards the building was built to.

How the Golden Thread Must Be Managed

The law is specific about how the golden thread must be kept. Holding the information is not enough. It must be:

• Kept digitally, with version control so that all changes are traceable

• Secured against unauthorised access

• Available when needed by authorised parties

• Presented in a usable format written in plain English

• Treated as the single source of truth for the building

• Compliant with GDPR

The Safety Case Report

The safety case is not a single document. It is a structured body of evidence showing how the principal accountable person is identifying, assessing, and managing building safety risks, primarily the risk of fire spread and structural failure.

The safety case report is the formal summary of that evidence. It must be kept live, updated whenever significant changes occur, and made available to the Building Safety Regulator on request or as part of the Building Assessment Certificate process.

The safety case report does not replace a fire risk assessment, but it draws on it. Ensuring your fire safety evidence is accurate, current, and audit-ready is essential for meeting your safety case obligations.

Mandatory Occurrence Reporting

Mandatory occurrence reporting (MOR) is a specific legal duty under the Building Safety Act 2022. Accountable persons must operate a system that identifies, records, and reports safety occurrences to the Building Safety Regulator.

A mandatory occurrence is any fire or structural safety event that could put residents at risk. When one occurs, it must be reported to the BSR promptly, with a written report submitted within 10 days.

Dutyholders must have a written mandatory occurrence reporting plan in place before the building is occupied. This plan forms part of the golden thread and must be shared with the BSR on request.

What Dutyholders Must Have in Place Right Now

If you are a dutyholder for a higher-risk building and the golden thread is not yet fully in place, you are already behind. Here is what must be in place.

For clients and contractors still in design or construction:

• A digital record-keeping system with version control and access controls

• Defined policies for secure information management

• A complete golden thread for the current project stage

• A change control plan capturing every design and construction change

• A mandatory occurrence reporting plan ready for handover

For accountable persons managing occupied buildings:

• A live, up-to-date digital golden thread

• A current safety case report

• An active residents' engagement strategy

• A functioning mandatory occurrence reporting system

• A clear process for sharing information with the BSR, other APs, and residents

If your building has passive fire protection elements that have been modified or repaired, those changes must be reflected in your golden thread. Fire compartmentation surveys and fire stopping records are key supporting documents in any safety case.

Fire door inspection records, maintenance logs, and remediation reports all form part of the evidence chain that the golden thread must capture.

For a broader overview of your obligations under the Act, our guide on the Building Safety Act 2022 for facilities managers covers the compliance picture in practical terms.

The Consequences of Getting It Wrong

The Building Safety Regulator has enforcement powers and has signalled that it intends to use them. Failure to comply with golden thread requirements can result in:

• Improvement notices requiring specific actions within a defined timeframe

• Prohibition notices preventing occupation of parts of the building

• Prosecution under the Building Safety Act, which carries unlimited fines

• Personal liability for named dutyholders and accountable persons

For any dutyholder managing a higher-risk building, the question is not whether to comply but how quickly you can close the gap between where you are and where the law requires you to be.

Frequently Asked Questions

What is the golden thread under the Building Safety Act 2022?

The golden thread is a digital record of all the information needed to understand a higher-risk building and manage its safety throughout its life. It is a legal requirement under Section 88 of the Act, in force since 1 October 2023. It must be kept digitally, securely, and updated whenever significant changes are made to the building or its use.

Who is responsible for the golden thread?

Responsibility shifts depending on the building's lifecycle stage. During design and construction, the client holds primary responsibility. Once the building is occupied, the duty passes to accountable persons and the principal accountable person. Each category of dutyholder has specific, distinct obligations that cannot be delegated to others.

What buildings must have a golden thread?

Higher-risk buildings must maintain a golden thread. Under the Building Safety Act 2022, this means buildings that are at least 18 metres high or have at least 7 storeys, and contain 2 or more residential units, or are hospitals or care homes. All applicable buildings in England must comply.

What information must be included in the golden thread?

During design and construction, this includes drawings, compliance statements, change control logs, competence declarations, and a mandatory occurrence reporting plan. Once occupied, accountable persons must also maintain a safety case report, a residents' engagement strategy, and a mandatory occurrence reporting system. Historical records from previous owners should also be held where available.

What is a safety case report and how does it relate to the golden thread?

The safety case report is a formal document summarising how the principal accountable person is managing building safety risks, primarily fire spread and structural failure. It must be kept live, updated when significant changes occur, and provided to the Building Safety Regulator on request. It draws on information held in the golden thread, including fire risk assessments, inspection records, and maintenance logs.

What is mandatory occurrence reporting under the Building Safety Act?

Mandatory occurrence reporting (MOR) is a legal duty requiring accountable persons to operate a system for identifying, recording, and reporting safety events in higher-risk buildings to the Building Safety Regulator. Any fire or structural safety incident that could put residents at risk is a mandatory occurrence. It must be notified promptly, with a written report submitted within 10 days.

What happens if a dutyholder does not comply with golden thread requirements?

The Building Safety Regulator can issue improvement notices, prohibition notices, or pursue prosecution under the Building Safety Act. Unlimited fines can be imposed on organisations, and named individuals including accountable persons can face personal liability. The BSR has made clear it will use its enforcement powers actively.