What Gateway 2 is
Gateway 2 is building control approval for a higher-risk building, granted by the Building Safety Regulator rather than by a local authority or an approved inspector. It is a hard stop: work cannot start until approval is granted, and there is no equivalent of starting on site while the details are resolved.
That single change is what makes it different from everything that came before. The design has to be complete, coordinated and justified up front, and the fire strategy is the document that carries most of that burden.
Which buildings
A higher-risk building in England is one that is at least 18 m in height or has at least seven storeys, and contains at least two residential units, or is a care home or hospital meeting the same height test. Our higher-risk building checker applies the test, including the storey counting rules that catch people out.
What the data shows
Published Building Safety Regulator data to 28 June 2026 shows an approval rate of around 77%, so roughly 23% of decided applications are not approved. Median determination times are about 22 weeks for new build and about 35 weeks for remediation, against a statutory target of 12 weeks.
On a stalled residential scheme, holding costs run into thousands of pounds per week. The cost of a rejected or invalidated application is almost never the resubmission fee; it is the programme.
Invalidation is not rejection, and it is the more common failure. An application is invalidated when it is incomplete: a document missing, a declaration absent, a drawing that does not match the report. It never reaches technical assessment. Rejection is a substantive finding that the design does not demonstrate compliance. Most applications that fail, fail on completeness.
What has to be in the application
- Plans and drawings showing the work in sufficient detail to demonstrate compliance
- The fire and emergency file: the fire strategy, in practice, plus the fire strategy drawings
- A statement of how the work will comply with the applicable requirements, with every departure from guidance justified
- Competence declarations for the principal designer and principal contractor
- The construction control plan
- The change control plan
- The mandatory occurrence reporting procedure
- The strategy for maintaining the golden thread of information
Our Gateway 2 readiness checker works through the package item by item and tells you what is missing before the Regulator does.
Why applications fail
- Incomplete submission. A required document simply not there. Entirely avoidable and entirely common.
- Design not developed far enough. Details left as "to be confirmed by specialist" that the Regulator expects to see resolved.
- Departures not justified. Every deviation from the Approved Documents or from BS 9991 needs an explicit written justification. Silence reads as an oversight.
- Drawings inconsistent with the strategy. A compartment line on the drawing that the report does not describe, or a fire resistance period that differs between the two.
- Competence not demonstrated. Declarations that assert competence without evidencing it.
- Fire strategy that is generic. Boilerplate that could describe any building of that type reads as a template, and invites scrutiny of everything else.
- Slow responses to requests for information. The determination clock is not the only thing that matters; the applicant's own turnaround is often the longer part.
- Unmanaged change during design. The submitted package no longer describes the scheme by the time it is assessed.
Change control after approval
Approval fixes the design. Changes after it are categorised: some are notifiable, some require a fresh application, and some can be recorded and carried on. Getting that categorisation wrong is a compliance failure, and it is the reason change control has to be a live process with named responsibility rather than a document written for the application and never opened again.
Practical preparation
- Start the application package at Stage 3, not Stage 4. The process documents take longer to produce than anyone expects.
- Keep a departures schedule from day one. Retro-fitting justifications at the end is how justifications end up thin.
- Cross-check drawings against the strategy formally. Every compartment line, every fire resistance period, every door rating, in both directions.
- Resource the RFI responses. Assume requests for information will come, and decide in advance who answers them and how fast.