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Delivering through Gateway 3

Calls to scrap building safety regulation are not the answer, writes Leanne Beirne, from BTP Architects – we must find a way to make the system work better

The way we deliver high-rise buildings continues to make headlines.

BTP has always welcomed the need for regulation on building safety. There needs to be a guarantee that buildings are designed to be safe – and then delivered in the way they were designed using the right materials. These are simple demands from the public.

Yet the tragedy at Grenfell, and investigations that have followed, showed that any assurance in this process had been lost.

Calls to scrap or row back on new regulations that embed the lessons from that night – and the many incidents that have gone before it – are not the answer.

Developing a system for building regulation that stands up to contact with the realities of delivering homes is.

What Gateway 2 has shown us

The Gateway system was the government’s answer. But delays in the system have brought a different kind of scrutiny as the new rules run headlong into a wider government demand to rapidly speed up development.

Much of the sector’s attention has so far been on Gateway 2 – securing approval to start on site. But as more projects move through the system, the real test is becoming clear.

Gateway 3 is where compliance must be proven in practice. It is the point where what was promised at Gateway 2 must be evidenced in full, and where weak processes, poor records and late decisions are exposed.

Gateway 2 has been a steep learning curve, even as the government has increased the pace of its decision-making, making 92 remediation decisions in the first three months of this year compared to 228 across the whole of 2025.

Early frustrations around delays and rejections were well documented, but over time, a clearer picture has emerged.

Too many applications were based on outdated approaches. Large volumes of drawings were submitted with little context. Compliance was stated but never explained.

It is no longer enough to say that a design complies. Teams must demonstrate how and why. Every decision must be clearly set out, justified and evidenced. In short, you must show your working out.

Those who have adapted by refining their processes, structuring their information and taking ownership of compliance are seeing the benefits. At BTP, we have obtained 16 Gateway 2 approvals so far.

Gateway 3 is the real test of delivery

That lesson carries directly into Gateway 3. If Gateway 2 is about proving the design, Gateway 3 is about proving the delivery.

The Building Safety Regulator (BSR) describes it as the “moment of truth” – the point where you must demonstrate that the building has been constructed in accordance with the approved design, alongside any necessary changes made along the way.

There is no opportunity at this stage to fill in gaps or revisit decisions. The evidence must already exist. That is why Gateway 3 cannot be treated as a final step. It is the product of decisions, inspections and change control throughout the project.

Projects that approach Gateway 3 as an end-of-job exercise will struggle, because success relies on a robust and continuous record of what was designed, what was approved, what changed and what was ultimately built.

Change control is a critical part of this. Every project will experience change, particularly when working on existing buildings. The difference now is that every change must be assessed, justified, recorded, and, where necessary, approved.

On one of our first projects to obtain Gateway 2 approval, three notifiable changes have already had to be managed during delivery. Without a clear record of information in place, those changes could easily have become a major barrier to progress.

Trying to reconstruct that information at the end of a project is not realistic. It has to be captured as you go.

What good preparation looks like

In our case, design team meetings held at least monthly have been essential in reviewing contractor-logged changes on site, evaluating them with the principal contractor and ensuring everything is clearly reported to the relevant BSR case officer.

It also requires regular engagement across the project team. Designers, contractors, the registered building inspector and the BSR all have a role to play. Open dialogue and early discussion of issues can prevent delays later on and help ensure occupation goes ahead as scheduled.

Site presence is equally important. Regular inspections, supported by photographic evidence and clear reporting to case officers, create a reliable record of what has been built.

A common mistake we are seeing across the sector is underestimating the time required for Gateway 3. The BSR is already backed up with applications and taking longer than expected to assess them.

That is why we recommend clients submit Gateway 3 at least eight weeks before planned occupation, giving the BSR time to consult and review what has been submitted. By completion, Gateway 3 should be a confirmation exercise, not a scramble.

Making the system work better in practice

One of the more positive developments in the new regime has been the increased level of collaboration it has driven through this more rigorous approach to evidence gathering.

Where there was once limited visibility, there is now more engagement between project teams, registered building inspectors and the BSR. This creates opportunities to resolve issues earlier and build shared understanding.

Gateway 3 is where that confidence is won or lost. The teams that treat it as an end-stage administrative hurdle will continue to struggle. The teams that build it into the project from the beginning will be the ones best placed to deliver safely, avoid delay and give clients confidence that their buildings are ready for occupation.

Leanne Beirne

BTP Director

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