Weaving the Golden Thread: a detailed guide to HRB regulations for Accountable Persons

The Higher-Risk Buildings (Keeping and Provision of Information etc) (England) Regulations 2024 set out the requirements for providing information about a Higher Risk Building (HRB) known as the ‘Golden Thread’. CABE's Head of Technical Insight, Dr Hywel Davies, provides a guide for ‘Accountable Persons’ for an HRB and what they need to be doing now.

These regulations came into force in January 2024 and were the final piece in the set that introduced the new regime for the oversight of Higher Risk Buildings (HRBs) in occupation, enabled by Part 4 of the Building Safety Act. They prescribe what information and documents the principal accountable person (“PAP”) and any other accountable person (“AP”) responsible for an HRB must keep in relation to the building. They deliver on the call for a digital standard of record-keeping for HRBs contained in Dame Judith Hackitt’s 2018 review of fire safety and building regulations. 

The regulations require that those who are accountable for an HRB have a legal duty to have and to maintain – in electronic form – accurate, up-to-date and secure information about the HRB they are accountable for, so that they can discharge their duty to manage that building safely. If they already have up-to-date information and a full safety management plan for the building, there will not be a huge amount to do.

Who's responsible?

An AP is a dutyholder who is responsible for the safety of an occupied HRB under Part 4 of the Building Safety Act. If there is only one AP, that makes them the principal AP (PAP). Where there is more than one AP, the PAP is the AP responsible for the structure and exterior of the HRB. 

These ‘Golden Thread’ regulations should certainly not have come as a surprise to anyone responsible for an HRB. It is six and a half years since Dame Judith made her original recommendations and these requirements have been widely talked about for much of that time.

Many people have been working towards this new regime for several years. They have been identifying the key building safety risks in their buildings which could lead to catastrophic failure due to fire or structural failings with associated significant loss of life. 

They will have identified the information they already hold and brought it together, as well as updated the information where that was needed. There has been a particular focus on the legal requirement for this information to be held “electronically”, for it to be readily available to those who need it, and for it to be exchangeable, especially if management contracts or providers change, or HRBs change ownership. 

The regulations identify what information the PAP must provide to the Regulator, to other APs, to residents and to the fire and rescue authority. There is significant detail both in the main regulations and also in Schedule 1, which details the information that is prescribed for the Golden Thread under section 88(1) of the Building Safety Act. 

The key building information submitted at the time of registration of the HRB will also help the AP to assess the building’s safety risks when developing the safety case for the building. It will also help the Building Safety Regulator to determine which HRBs to prioritise when calling in safety case reports to consider granting Building Assessment Certificates. This process began in earnest in April 2024, with the first directions to submit applications for a Building Assessment Certificate sent out in that month. 

Building on the foundations

These new regulations build on the foundations laid by the HRB regulations published in 2023 [see box below]. They describe in detail what information must be held in the Golden Thread and set out the requirements relating to how that information is held, made available and maintained.

The required information covers both structural and fire safety management of the building, including assessment of ‘building safety risks’ as defined in the Building Safety Act. These are specifically fire and structural safety risks, and the PAP must assess the major safety risks and the measures in place to manage those risks. 

The assessment must also consider the evacuation strategy for the building, including details of the precautions to be taken by building occupants to reduce the likelihood of having to evacuate the building at all by knowing and following basic fire safety precautions. In particular, this may involve following agreed arrangements for the storage and charging of electric bikes and scooters in safe locations and not in common areas that serve as means of escape.  

The PAP also needs to consider how those who are unable to escape using the stairs are to be evacuated from the building, and make sure that those who require alternative means of escape are familiar with the provisions for them.

The Golden Thread should include details of all structural safety measures for the building, relevant reports and details of the design codes applied when the building was constructed as well as plans of the building. 

The Golden Thread should also include details of the assessment and management of maintenance and repair of the HRB on a day to day basis, and how that is undertaken in such a way that approval is obtained for building work before it is carried out and how that work is then recorded and the Golden Thread updated to reflect the work carried out. This needs to cover all aspects of work on the building and its systems. This will include systems such as lifts, that are not currently covered by Building Regulations, but are subject to other safety requirements and are also within the scope of the Fire Safety (Regulatory Reform) Order. Lifts require regular maintenance and this must be accurately recorded in the Golden Thread. 

The devil is in the detail

The provision of this information cannot be considered unreasonable. APs who find these requirements unduly onerous might want to consider whether they have been providing an appropriate standard of management until today. And they may be well advised not to make too much fuss about the new requirements, as it might only serve to draw attention to previous management standards.

The Construction Leadership Council has provided further industry-led guidance on the regulations and on how PAPs and APs can meet the new obligations in a safe, reasonable and proportionate manner. It is another step on the road to rebuilding trust in the construction and operation of our higher rise building stock and to building a safer future.

At a glance: the HRB Regulations

There are five sets of regulations specifically applying to Higher-Risk Buildings (HRBs), which define them, specify how to measure them and set out the legal duty to register them with the Building Safety Regulator and to provide key building information to the Regulator. They place new duties on accountable persons.

The Higher-Risk Buildings (Descriptions and Supplementary Provisions) Regulations 2023

These regulations determine which buildings are subject to the new, more stringent, safety regime. They tell you how to determine whether a building is an HRB or not, with a detailed measurement protocol, so you know whether it needs to be registered. They also define the types of buildings which are classed as “higher-risk building” at section 120D of the Building Act 1984 (which is inserted into the 1984 Act by section 31 of the 2022 Act) and in section 65 of the 2022 Act.

The Building Safety (Registration of Higher-Risk Buildings and Review of Decisions) (England) Regulations 2023

These regulations implement the register of HRBs held by the Building Safety Regulator and the process for making an application to register an HRB. They set out the detailed requirements to register HRBs with the building safety regulator. Details of the registration process are available here.

The Higher-Risk Buildings (Key Building Information etc) (England) Regulations 2023

Once a building is registered, accountable persons must then provide key building information. These regulations set out what constitutes ‘key building information’ in respect of HRBs; the duties and provisions in relation to submitting key building information; and how to determine for which parts of an HRB an AP is responsible for under Part 4 of the Building Safety Act. They describe the further information that must be provided within 28 days of registration.

The Higher-Risk Buildings (Keeping and Provision of Information etc) (England) Regulations 2024

These regulations specify the information and documents that the principal accountable person and accountable persons must keep and share with those who have an interest in relation to an HRB. These are the regulations that set out the main requirements of the Golden Thread and they are described in some detail in the CLC guidance.

The Higher-Risk Buildings (Management of Safety Risks etc) (England) Regulations 2023

These regulations make the administrative provisions in relation to the ongoing management of safety risks in HRBs and they set out the requirements for the ongoing management and mitigation of risks in an HRB. They include the requirements for Safety Case Reports. It is worth stressing that you are most likely to be able to comply with these requirements without an accurate and up to date Golden Thread. There is some further guidance on this here.  

Dr Hywel Davies is Head of Technical Insight at CABE. He chaired the BRAC Golden Thread working group and the Construction Leadership Council working group that developed the CLC guidance.