The Building Safety Act 2022 marked a defining shift in how the built environment approaches safety, accountability and performance. While key elements of the new regime, including duty holder responsibilities and gateway approvals, have been in force since October 2023, the industry is now approaching a critical milestone.

The transitional period for projects already underway is due to end on 6 April 2026, after which all applicable developments will be required to fully comply. This moves the industry from a period of adjustment into full implementation.

While much of the focus has been on fire and structural safety, the implications for the building controls sector are significant. For BEMS, BMS and BACS specialists, the Act introduces new expectations around competence, data, coordination and compliance.

At the Building Controls Industry Association, this shift is not only recognised, but is informing a co-ordinated industry response.

 Competence moves centre stage

The BCIA has been tasked with being the responsible organisation for the building controls and automation sub-sector, including developing a sector-specific competence framework.

This comes at a time when competence must be clearly defined, evidenced and maintained.

“There is now a significant focus on competency and, importantly, the demonstration of that competency. It’s no longer enough to assume capability - it has to be evidenced at multiple stages of a project,” says Andy Thorn, BCIA Management Committee Member who brings more than 30 years’ experience in the BEMS industry.

Following industry consultation, BCIA is progressing work on how competency should be demonstrated and revalidated in practice, aligning building controls with other recognised professions. As the transitional period ends, this requirement will become increasingly visible across regulated projects.

 A changing regulatory landscape

The impact of the Act is most evident through the Higher Risk Building (HRB) regime and gateway approvals.

“The Higher Risk Building regime will impact members working on larger projects,” Andy notes. “It brings additional layers of oversight that our sector needs to understand and plan for.”

The introduction of duty holder roles also brings new responsibilities, particularly around design coordination and accountability. “The Principal Designer role carries a lot of responsibility on controls-dominant projects, which could sit with one of our members, and the implications are significant.”

As projects move beyond transitional arrangements, clarity around roles, responsibilities and interfaces will be essential.

Building controls and life safety

The Act is a direct response to the Grenfell Tower fire and is fundamentally focused on life safety. While building controls may not always be the primary safety system, their role is growing as systems become more integrated.

“Our industry isn’t as directly impacted as fire or lifts, but Building Management Systems (BMS) can be central to many integrated systems such as smoke control,” Andy says. “Members need to be aware of the additional compliance and coordination required.”

This places building controls more firmly within the wider safety ecosystem, with greater expectations around system performance and integration.

 Data, evidence and the golden thread

The requirement for a golden thread of information is one of the most significant changes introduced by the Act and, for building controls, this is a key strength.

As Andy explains; “Data will be critical. The BMS will have information logged from inception, and members may be involved in providing that data during sign-off to support compliance with the regulator.”

As full compliance approaches, this data will play a central role in evidencing performance, testing and ongoing compliance, reinforcing the value of BEMS across the building lifecycle.

 Gateways, timelines and uncertainty

Gateway approvals, aligned broadly with Royal Institute of British Architects (RIBA) stages, are already impacting project delivery, but there remains uncertainty around how they operate in practice.

“There is still a lot of confusion around how the gateway stages work in practice”, reflects Andy. “The current JCT contract doesn’t align with Gateway 2, which can take up to 18 weeks to sign off. Gateway 3 also raises questions around inspections and testing. Greater clarity is needed on what inspections will involve in practice, particularly given that buildings cannot be occupied or pre-let before final sign-off, with potential delays and additional costs becoming a growing concern.”

The role of the Building Safety Regulator continues to evolve, and as transitional arrangements fall away, consistency in interpretation will become increasingly important.

Time, cost and the road ahead

The Act introduces additional time, cost and process requirements across projects.

“Time and cost will increase, that’s inevitable. And if it leads to safer buildings, that’s the right outcome,” Andy says, “But more clarity is needed to avoid inconsistencies, particularly during tender stages.”

For building controls companies, this means adapting both technically and commercially, with a sharper focus on defined scope, compliance and coordination.

Supporting members through change

BCIA has been delivering targeted workshops for the building controls sector, with strong engagement from members seeking clarity on how the Act applies in practice.

Led by Building Safety Act expert John Joyce, these sessions focus on real-world application, covering:

• Duty holder roles and responsibilities

• Gateway processes and submissions

• Golden thread requirements

• Competency expectations

“Our sector needs to be able to demonstrate competence at every stage of the process,” Andy says. “These workshops are an important step in helping members understand what that looks like in practice.”

With the end of the transitional period approaching, the focus is now firmly on readiness.

Whether you are already involved in Higher Risk Buildings or preparing for future projects, BCIA will be delivering future workshops to help members build confidence, strengthen understanding and ensure your organisation is aligned with the new regulatory landscape.