What the Building Safety Act 2022 Means for Facilities Managers in 2026

TL;DR

• The Building Safety Act 2022 introduced new legal duties for anyone responsible for managing buildings in England.

• Facilities managers of higher-risk buildings (18m or higher, or 7 or more storeys, with at least two residential units) have formal obligations under the Act.

• Key requirements include maintaining a Golden Thread of building information, registering with the Building Safety Regulator, and producing a Building Safety Case.

• Non-compliance carries serious legal consequences, including prosecution and unlimited fines.

• Proactive passive fire protection, fire risk assessments, and building documentation are essential for compliance in 2026.

Four years after receiving Royal Assent, the Building Safety Act 2022 continues to reshape how buildings are managed across England. For facilities managers, the Act is not a distant regulatory update. It is a direct set of legal obligations that affects day-to-day operations.

In 2026, many of the Act's requirements are now fully active. The Building Safety Regulator (BSR) is operational, higher-risk building registration is mandatory, and enforcement activity is increasing. Facilities managers who have not yet reviewed their responsibilities are running a significant risk.

This article explains what the Building Safety Act 2022 requires, who it applies to, and what facilities managers must do to remain compliant in 2026.

What Is the Building Safety Act 2022?

The Building Safety Act 2022 was introduced following the Grenfell Tower fire in 2017 and the subsequent Hackitt Review, which identified systemic failures in how buildings were designed, constructed, and managed.

The Act created a new regulatory framework with three core goals:

• To give residents of higher-risk buildings more rights, stronger protections, and a louder voice.

• To create clear lines of responsibility for building safety throughout a building's lifecycle.

• To improve the standard of buildings so that they are safer to live and work in.

The Act established the Building Safety Regulator (BSR), operating under the Health and Safety Executive (HSE), as the central oversight body for higher-risk buildings.

Which Buildings Does the Act Apply To?

The Building Safety Act applies most intensively to higher-risk buildings (HRBs). These are defined as buildings that are:

• 18 metres or higher (or 7 or more storeys), and

• Contain at least two residential units.

This definition covers a broad range of property types, including purpose-built blocks of flats, mixed-use developments, and some student accommodation. For facilities managers operating within this scope, the full suite of obligations under the Act applies.

What Are the Key Duties for Facilities Managers?

The Accountable Person and Principal Accountable Person

The Act introduced two specific legal roles: the Accountable Person (AP) and, where there are multiple APs, the Principal Accountable Person (PAP). The AP is the person or organisation responsible for repairing and maintaining the common parts of a higher-risk building. In practice, this is often a facilities manager, building owner, or managing agent.

As an AP, you are legally required to:

• Register the building with the Building Safety Regulator.

• Assess and manage building safety risks on an ongoing basis.

• Produce and maintain a Building Safety Case Report.

• Prepare a Residents' Engagement Strategy.

• Establish and maintain a complaints process for residents.

• Designate a Building Safety Manager (BSM) to manage day-to-day safety matters.

Facilities managers who are not formally identified as the AP should still be aware of these requirements, as they will likely be the person delivering compliance in practice.

The Golden Thread of Information

One of the most significant practical requirements introduced by the Act is the Golden Thread. This is a structured, up-to-date digital record of key information about a higher-risk building.

The Golden Thread must include:

• The original building design and any subsequent changes.

• Structural and fire safety information.

• Records of inspections, assessments, and remediation works.

• Details of all competent persons and contractors involved in building work.

For facilities managers, maintaining the Golden Thread means keeping accurate records of every fire safety intervention, electrical inspection, structural change, and compliance activity. If your documentation is fragmented or out of date, closing that gap is a priority.

Fire Safety Obligations Under the Act

The Building Safety Act works alongside the Fire Safety Act 2021 and the Regulatory Reform (Fire Safety) Order 2005. Together, these three pieces of legislation form the backbone of fire safety compliance for commercial and residential buildings in the UK.

Under this combined framework, facilities managers must ensure:

• A current, written fire risk assessment is in place and reviewed regularly.

• Fire compartmentation, including fire doors, fire stopping, and fire dampers, is maintained and documented.

• Any deficiencies identified in inspections are remediated promptly and recorded.

• The building's fire safety strategy is reflected in the Golden Thread.

Facilities managers overseeing multi-occupied buildings should note that the Fire Safety Act 2021 extended the scope of the Regulatory Reform (Fire Safety) Order to include the structure, external walls, and flat entrance doors of residential buildings. This places additional inspection and maintenance duties on the responsible person. Our fire risk assessment services and passive fire protection services are designed to help building managers meet these obligations.

Passive Fire Protection: A Core Compliance Obligation

Passive fire protection (PFP) refers to the physical elements built into a building's structure to contain fire and smoke, slow its spread, and protect escape routes. It is a critical component of building safety compliance under the Act, and a key area of ongoing maintenance responsibility for facilities managers.

Fire Doors

Fire doors must be inspected regularly and any defects remediated without delay. The Regulatory Reform (Fire Safety) Order and the Building Safety Act both place obligations on the responsible person to ensure fire doors are fit for purpose. For a detailed breakdown of what to look for during inspection, see our fire door inspection service.

Fire Compartmentation

Compartmentation is the system of fire-resistant walls, floors, and ceilings that divide a building into fire-tight sections. Breaches, whether caused by building works, service penetrations, or deterioration, can undermine a building's entire fire strategy. Our fire compartmentation services identify and address these issues.

Fire Stopping

Any service penetration through a fire-resisting element must be correctly fire stopped. Poor or missing fire stopping is one of the most common deficiencies found during building safety surveys. If you manage a building that has undergone refurbishment, reviewing fire stopping compliance should be a priority.

Fire Dampers

Fire dampers sit within ductwork systems and close automatically to prevent the spread of fire and smoke through ventilation systems. The BS 9999 standard requires fire dampers in higher-risk buildings to be tested and maintained annually, or more frequently where the risk demands it.

Electrical Safety Compliance

Electrical compliance is closely linked to building safety under the Act. Facilities managers must ensure that all electrical installations within higher-risk buildings are safe and properly maintained. This includes having a current Electrical Installation Condition Report (EICR) in place and acting on any remedial recommendations. Our electrical services compliance team works with facilities managers to plan and deliver structured EICR programmes across single and multi-site portfolios.

Building Safety Cases and Registration

All higher-risk buildings in England must be registered with the Building Safety Regulator. Registration was mandated from April 2024, and buildings that were not registered by the deadline have been subject to enforcement action.

In addition to registration, higher-risk buildings require a Building Safety Case, a structured set of documents and evidence demonstrating that building safety risks are being effectively managed. The Building Safety Case Report is a summary of this case, provided to the BSR on request.

Facilities managers should ensure that the Building Safety Case is a live document, updated as inspections are completed, works are carried out, and building information changes.

What Happens If You Are Not Compliant?

Non-compliance with the Building Safety Act 2022 carries serious consequences. The BSR has enforcement powers including:

• Prohibition notices preventing occupation of the building.

• Compliance notices requiring specific remediation works.

• Prosecution, with unlimited fines and up to two years' imprisonment for individuals.

Residents also have new rights under the Act to raise concerns directly with the BSR if they believe their building is not being managed safely. This means non-compliance is not only a regulatory risk, but a reputational one.

How Protest ES Ltd Supports Building Safety Compliance

Protest ES Ltd provides a range of services that directly support facilities managers in meeting their obligations under the Building Safety Act 2022. Our capabilities include:

• Fire risk assessments

• Passive fire protection surveys and remediation

• Fire door inspection, installation, and remedials

• Fire compartmentation surveys

• Fire stopping surveys and works

• Fire damper testing and maintenance

• Electrical installation condition reporting (EICR)

• Electrical remedial repairs

We work across all sectors including healthcare, education, retail, leisure, property, and council and local authority estates. For a no-obligation consultation, visit our facilities management page or get a quote.

Frequently Asked Questions

Does the Building Safety Act 2022 apply to commercial buildings?

The Building Safety Act 2022 applies most intensively to higher-risk buildings, defined as residential buildings of 18 metres or more in height, or 7 or more storeys, containing at least two residential units. Commercial buildings that do not fall within this definition are not subject to the full requirements of the Act, but are still subject to fire safety legislation including the Regulatory Reform (Fire Safety) Order 2005 and the Fire Safety Act 2021.

Who is the Accountable Person under the Building Safety Act?

The Accountable Person (AP) is the legal entity responsible for repairing and maintaining the common parts of a higher-risk building. This could be a building owner, a leaseholder, a managing agent, or a facilities management company. Where multiple parties share responsibility, a Principal Accountable Person must be designated to oversee the overall building safety obligations.

What is the Golden Thread and what does it mean for facilities managers?

The Golden Thread is a structured digital record of key building safety information that must be created, maintained, and kept up to date throughout a building's life. For facilities managers, this means keeping accurate, retrievable records of all fire safety inspections, building works, compliance certificates, contractor details, and remediation activities. It ensures that building safety information does not get lost or fragmented over time.

What is a Building Safety Case and do I need one?

A Building Safety Case is the body of evidence that demonstrates a higher-risk building's safety risks are being effectively managed. All higher-risk buildings must have one, and a Building Safety Case Report must be submitted to the Building Safety Regulator. If you manage a higher-risk building and do not yet have a Building Safety Case in place, this should be addressed as a matter of urgency.

What passive fire protection checks does the Building Safety Act require?

The Act does not prescribe a specific inspection schedule for passive fire protection elements, but requires the Accountable Person to manage building safety risks on an ongoing basis. In practice, this means regular inspection and maintenance of fire doors, fire stopping, fire compartmentation, and fire dampers, with all findings and remedial works recorded in the Golden Thread. Frequency of inspection should be risk-based and informed by the specific building type, use, and condition.

What should facilities managers do if they find a passive fire protection defect?

Any passive fire protection defect identified during inspection should be risk-assessed to determine urgency. Critical defects that pose an immediate risk to life should be remediated without delay. Other defects should be prioritised, programmed, and completed within a reasonable timeframe, with all actions recorded. Leaving known defects unaddressed without a documented remediation plan is likely to be considered a failure to manage building safety risks under the Act.

Are facilities managers personally liable under the Building Safety Act 2022?

Individual liability under the Building Safety Act depends on the specific role held. If a facilities manager is formally designated as the Accountable Person or Building Safety Manager, they carry direct legal responsibilities under the Act. Even where formal liability sits with a building owner or managing agent, facilities managers who knowingly fail to carry out safety-critical tasks may face personal liability under wider health and safety legislation. Professional advice should be sought where liability is unclear.