Before the full suite of secondary legislation under the Building Safety Act came into force, one of the earliest and most important elements we encountered was the Transitional Provisions. These provided a temporary pathway for certain projects to follow the previous regime but with clear requirements.
What is a Transitional Project?
If your project involved a Higher-Risk Building (HRB) and you submitted an initial notice to Building Control during the transitional window, you could continue under the old process, provided certain conditions were met.
This transitional window ran approximately from 1 October 2023 to 6 April 2024. If your project was within scope and you issued that initial notice within this timeframe, you were then required to formally notify your local authority that your project was to be treated as transitional.
But that wasn’t all.
Competency Requirements for Building Control Professionals
To qualify, your Building Control professional also had to pass new competency assessments and be registered as a Registered Building Inspector (RBI). Only then could your project continue under the old-style building control pathway, now referred to as a traditional project.
The Advantage of Transitional Status
Projects that successfully achieved transitional status had one major benefit: They did not need to go through the full Gateway process introduced by the Building Safety Act. That meant no Gateway Two or Gateway Three requirements, a significant administrative and compliance burden avoided.
However, that doesn’t mean compliance ends there.
What Happens Now?
Fast forward to today, and many of those transitional projects are reaching completion. But here’s the catch: While they may have skipped the Gateway stages, they are not exempt from the ongoing obligations required at occupation and beyond.
These buildings now need to meet the requirements for registration with the Building Safety Regulator (BSR). Once registered, the client has 28 days to submit a range of critical information, from fire safety measures to building systems, to satisfy the BSR that the building is safe for occupation.
Until this information is accepted, it is illegal to occupy the building. This is a fundamental shift from the previous system.
What Should Clients and Project Teams Be Doing?
If you’re involved in a transitional project that’s nearing completion, early engagement is crucial. You need to be working closely with your:
- Principal Contractor
- Design Team
- Fire Engineer
…to ensure that you understand your obligations and are preparing the right documentation.
After Occupation: Ongoing Compliance
Once the building is occupied, your responsibilities continue.
The Principal Accountable Person (PAP) and managing agent must develop:
- A Building Safety Case
- A Safety Management System
- A Mandatory Occurrence Reporting system
- A Resident Engagement Strategy
- A Building Safety Risk Assessment
All of these elements feed into your Building Safety Case Report, which the Regulator can call in at any time. If accepted, you’ll receive a certificate confirming that the building is being safely managed allowing you to continue occupation legally and confidently.
Contact us
If you’re managing a transitional project or preparing for Building Safety Regulator registration, we can help.
From navigating your documentation requirements to ensuring you have the right safety systems in place, BSRM Consulting works with clients, contractors, and design teams to deliver full compliance and peace of mind.
Let’s make sure your project meets every requirement on time, and without unnecessary delays.