Background: Why the Building Safety Act Was Introduced
The Building Safety Act 2022 is the most significant piece of building safety legislation in a generation. It was introduced in direct response to the Grenfell Tower fire of June 2017 and the subsequent Hackitt Review, which identified systemic failures in how tall residential buildings were designed, built, and managed.
The Act creates a new, more rigorous regulatory regime for what it calls "higher-risk buildings" — and fire doors sit at the heart of that regime because they are the primary means by which a building is compartmented to contain fire and smoke.
What Is a Higher-Risk Building?
Under the Act, a higher-risk building (HRB) is a residential building in England that is:
- At least 18 metres in height (approximately seven storeys), or
- Has at least 7 storeys
- Contains at least 2 residential units
The new regime applies to HRBs at all stages of their lifecycle — design, construction, and occupation. For existing occupied HRBs, the Act's occupation provisions came into force in October 2023.
The Accountable Person and Principal Accountable Person
The Act creates two new legal roles for occupied HRBs:
Accountable Person (AP)
An AP is any person who holds a relevant legal interest in a common part of the building — typically the freeholder, head leaseholder, or a company that owns common areas. A building may have more than one AP. Each AP is responsible for the safety of the parts of the building in which they hold an interest.
Principal Accountable Person (PAP)
Where there are multiple APs, one must be designated the Principal Accountable Person — the one with the most significant legal interest in the building's structure and exterior. The PAP has additional duties beyond the individual AP duties, including registering the building with the Building Safety Regulator (BSR).
Fire door obligations — including inspection, maintenance, and documentation — sit with the AP for the relevant common parts. In most buildings this means the freeholder or their managing agent.
Registration requirement: All HRBs in England must be registered with the Building Safety Regulator. Operating an HRB without registration is an offence. Registration requires providing information about the building's structure, fire safety systems, and the identity of the AP and PAP.
The Safety Case and the Golden Thread
Two concepts introduced by the Act have direct implications for fire door management in HRBs:
The Safety Case
APs must produce and maintain a Safety Case — a structured document that demonstrates how the building's fire and structural safety risks are being managed. Fire doors are a principal element of any residential building's fire safety strategy, and the Safety Case must demonstrate that they are appropriate for the building, properly maintained, and subject to a compliant inspection regime.
The Golden Thread of Information
The Act requires that a digital record of all building safety information — the "golden thread" — is created and maintained throughout a building's life. For fire doors, this means maintaining a continuous record of every door's specification, installation details, inspection history, defects identified, and remedial works completed. This is not a new concept in principle, but the Act makes it a legal requirement rather than best practice.
FDIS-certified inspection reports, issued digitally with door-by-door records and photographic evidence, directly support the golden thread requirement. A fire door inspection programme that generates this level of documentation is essential for HRB compliance under the Act.
How the Act Interacts with the Fire Safety Legislation
The Building Safety Act does not replace the RRO 2005 or the Fire Safety (England) Regulations 2022 — it sits alongside them. In practice, for an HRB, the obligations stack:
- The RRO requires that the Responsible Person maintains fire doors in working order (Article 17)
- The 2022 Regulations require quarterly communal checks and annual flat entrance checks
- The Building Safety Act requires that the AP maintains a Safety Case and a golden thread demonstrating how fire safety — including fire door compliance — is being managed
The Responsible Person and the Accountable Person may be the same entity, or they may be different parties with different legal interests. Establishing clearly who holds each role is the first step in designing a compliant management programme for an HRB.
Enforcement Under the Act
The Building Safety Regulator has enforcement powers that go beyond those of the fire authority under the RRO. These include requiring access to the building and its records, issuing compliance and improvement notices, requiring a change of Accountable Person in cases of serious non-compliance, and bringing criminal prosecutions.
The Act also creates a new route for leaseholders and residents to escalate concerns about building safety to the BSR directly, bypassing the AP. This makes robust documentation even more important — an AP who cannot demonstrate a compliant inspection and maintenance programme is vulnerable to regulatory intervention.
Key Takeaways
- The Building Safety Act 2022 applies to residential buildings over 18 metres (7+ storeys) with 2 or more residential units
- It creates Accountable Person and Principal Accountable Person roles with statutory fire safety responsibilities
- APs must maintain a Safety Case demonstrating how fire safety risks — including fire door compliance — are managed
- A digital golden thread of fire door information (specifications, inspection records, remedial works) is a legal requirement
- The Building Safety Regulator can enforce compliance independently of the fire authority
- FDIS-certified inspection reports support both the Safety Case and the golden thread requirement