IN Brief:
- The Industry Safety Steering Group has published its fifth report on culture change in the built environment.
- The report raises concerns over Gateway 2 and Gateway 3 applications under the higher-risk building regime.
- It also highlights continuing work on competence, product standards, insurance, retentions, and remediation.
Industry Safety Steering Group has warned that parts of the built environment sector are still failing to make the operational changes required by the post-Grenfell building safety regime.
The group’s fifth report to government examines progress across higher-risk buildings, competence, construction product reform, building occupation, insurance, and remediation. It also identifies continuing concerns over the quality of applications being submitted through the Gateway 2 and Gateway 3 processes under the Building Safety Act regime.
Gateway 2 applies before construction work starts on higher-risk buildings, while Gateway 3 applies before completion and occupation. The report raises concern that some submissions remain incomplete or poorly prepared, creating delays, rejections, and uncertainty for clients, contractors, designers, and building control teams.
The processes are intended to demonstrate that building safety has been properly considered before work begins and that completed buildings can be occupied with the necessary evidence in place. Poor submissions suggest that some project teams are still separating compliance from delivery, rather than embedding safety evidence into design coordination, procurement, construction records, and handover.
The report also reflects continuing work across the Construction Leadership Council’s building safety programme. Key workstreams include the new regulatory regime, competence, construction product reform, building occupation, and insurance. The Office for Product Safety and Standards has also been involved in activity around construction product standards, including PAS 2000:2026.
Higher-risk building projects now require stronger evidence management, earlier design coordination, clearer dutyholder responsibilities, and better records of product selection, change control, and installation. Delays at Gateway 2 or Gateway 3 can disrupt programmes, increase preliminaries, and create commercial friction between clients, designers, contractors, and specialist subcontractors.
Building safety reform also sits alongside wider pressure for construction payment and commercial change, including current debate around a potential ban on construction retentions. Technical reform becomes harder to embed when project teams are still operating under adversarial risk transfer, cash retention, and weak supply chain confidence.
The first phase of any regulatory change is often marked by inconsistent interpretation, uncertain documentation standards, and variable regulator expectations. Over time, the market develops stronger templates, clearer evidence requirements, and more reliable workflows. The current report indicates that too many teams are still discovering those requirements through delay, rather than preparing for them from the earliest design stages.
The product standards element is equally important. Safer buildings depend not only on design intent but on verified products, competent installation, and traceable records. The construction product system has been under scrutiny for years, and movement towards clearer standards and stronger oversight will increase pressure on manufacturers, merchants, specifiers, and contractors.
That pressure will be felt across procurement and site management. Lowest-price substitution, incomplete technical data, weak installation records, and informal change control all become higher-risk behaviours under the new regime. Contractors must be able to demonstrate why a product was selected, who approved it, how it was installed, and whether it matches the design intent.
The Building Safety Regulator continues to face scrutiny over capacity, process, and industry engagement, but the burden does not sit with the regulator alone. Clients need to fund compliance properly, designers need to resolve critical decisions earlier, contractors need stronger information control, and product suppliers need clearer technical evidence.
The report confirms that building safety reform is now moving from legislation into project delivery. Legal duties have changed, but the harder test is whether procurement, design management, product assurance, installation records, and handover information have changed with them.



