The Building Safety Act represents the most significant shift our sector has ever faced, with businesses across the industry still grappling with its implications. As we strive to design buildings that meet new requirements, the challenge is balancing the urgent need to deliver homes with the critical duty of ensuring safety.
In this new ACS Insights – David Brook, Technical Director at Hawkins\Brown, reflects on what the industry has learned.
A Slowing System That’s Under Pressure
Over the past 18 months, I’ve been at the forefront of grappling with the practical realities of the Building Safety Act. As a co-author of the RIBA Principal Designer course, I’ve helped shape around nine hours of new content that reflects this evolving legislative landscape, not just for compliance, but to guide meaningful best practice.
At Hawkins\Brown, we’re committed to helping the industry navigate this shift. We’re actively testing, refining, and implementing these changes in live projects, not just for our clients, but to support a wider understanding across the profession.
The numbers tell a difficult story: an article in Building Design this month stated just 10% of building safety applications are currently approved, and most of those are for relatively modest schemes. For larger projects, Gateway 2 delays are extensive, up to 40 weeks in many cases, surpassing even the typical planning timeline. The regime’s design is rigorous, and rightly so, but it’s clear that the system, as it stands, isn’t functioning efficiently.
The regulator can’t dilute the legislation, but there must be a way to move from intention to delivery with more clarity. Rejections are, ironically, more useful than silence as they at least give us feedback to work with. Right now, a lack of consistent precedent or structured guidance is leaving teams to interpret and gamble.
We’re All Learning
I was recently on a panel with Tim Galloway of the Health and Safety Executive, who made clear that the government doesn’t intend to offer templates; they want to avoid a one-size-fits-all approach. That’s understandable, but in the absence of reference points, design teams are being forced to take a trial-and-error approach.
At Hawkins\Brown, we’ve been analysing successful and unsuccessful submissions and learning on real examples like Dyecoats in Leeds. We’re learning from that scheme to draw insight and better close the gap between legislative expectations and practical delivery.
Collaboration is the Real Gamechanger
Learning from real world examples comes from an increasing openness of designers and developers; their willingness to share is one most encouraging shifts in our sector in a generation. This is backed up further by consortiums too – just like the one founded by architects Buckley Gray Yeoman whose group now includes more than 200 practices openly sharing experiences. It’s the sort of industry openness that’s essential in 2025.
We’re also bringing key suppliers in much earlier. For example, working with manufacturers like ACS from the outset has made a big difference. Their deep technical knowledge and robust product performance make compliance much more achievable, and it’s now part of our standard approach on complex schemes. Earlier collaboration improves everything — compliance, viability, and certainty. Of course, this can come with additional costs, so a new approach to funding models might be something the sector needs to explore.
One challenge is that procurement and funding often aren’t aligned, meaning many competent suppliers carry out the necessary gateway work without proper financial support, as design costs are typically recovered through product or system supply orders. When last-minute value engineering is introduced due to cost pressures, it places an unfair burden on suppliers striving to maintain compliance. Addressing this imbalance could be key to supporting suppliers and ensuring better outcomes across the board.
An Evolving Approach from the Regulator
We’re starting to see a change in stance from the regulator too – that’s not to say there’s any compromise on the commitment to safety at all, instead I mean that the Building Safety Regulator is leveraging ‘requirements’ to allow some level of detail to be provided after Gateway 2 approval. There’s more openness to phased information with ‘Approval with Requirements’ allowing teams to fill in some of the blanks where not related to safety critical items.
We’re also advising clients to better work within the existing rules and work within certain heights. Staying just below the 18m threshold (e.g., 17.8m) for example can avoid triggering the extensive delays of the new regime. There’s even talk of reducing the definition of “high-risk” buildings to 11m, which would align with current requirements for fire safety thresholds including non-combustible facades and sprinklers. We need to stay agile and plan for this longer term.
Long-term, we need evolution, in education, in practice, and in how we engage with complexity. We can’t keep doing things the way we did pre-Grenfell. Regulation is tighter, and rightly so. But with that must come support, consistency, and fair expectations – particularly when it comes to viability and affordability.
Margins, Support, and Smarter Working
Margins in construction are not what people imagine – 5–10% if you’re lucky. So, asking developers to absorb every new cost without compromise to programme or scope isn’t realistic. More government support, or greater flexibility around affordable contributions, could help redress the balance.
What matters most is that we’re working harder and smarter. There’s more scrutiny, more diligence, and ultimately, better-quality outcomes – not just for compliance, but for the people who will live and work in these buildings. At Hawkins\Brown, we’ll continue to lead by example by staying immersed in the regulation, refining our approach, and supporting the industry to move forward together.
We are reassured though to see the supply chain, and the likes of ACS, stepping up, giving assurance and adding rigour, to meet these new challenges head-on.
