Tackling Delays in Gateway 2 Needs a Collective Effort

A backlog of applications at Gateway 2 is causing widespread frustration in the early stages of the new building regime. Much of the scrutiny has been focused on the Building Safety Regulator, but the wider industry can play its part in unclogging the system. Marisa Schofield, Project Lead at ITP, explains the steps that can be taken to ensure smoother approval of project applications.

Given the size and complexity of the task, even the most optimistic members of the construction industry expected a few bumps in the road in the implementation of the Building Safety Act. Sure enough, a major headache has emerged in the early stages of this regulatory shift, with growing complaints surrounding delays in Gateway 2 – the checkpoint that must be passed before construction can begin.

Since taking up its role as the Building Control Authority for all higher-risk buildings (HRBs) in England, the Health and Safety Executive (HSE) has experienced some setbacks in the rollout of the Gateway 2 process. They have been honest and transparent about the issues, acknowledging teething problems with the new digital portal used by the Building Safety Regulator (BSR) and a need to expedite the process of setting up the multidisciplinary teams needed to validate and assess applications. The BSR has also inherited a large number of partially built HRBs, many at inconsistent stages of construction.

To its credit, the BSR responded swiftly. In July 2024, it expanded its internal Building Control Unit, recruited new staff, and engaged more closely with industry stakeholders to improve the process. These changes reduced initial validation times to 3–4 days and cut the overall application timeframe from 25 weeks to around 16 weeks.

Having worked to address the issues, the BSR has drawn attention to persistent delays caused by those at the other side of the process. Gateway 2 is currently hampered by high rates of application invalidation and rejection —and many of the problems are avoidable.

Applicants are still coming to terms with the requirements of Gateway 2 and many are submitting applications with shortfalls that lead to invalidation or rejection.

The common issues include missing or incomplete compliance statements, absence of a Competence Declaration, failure to provide a detailed Construction Control Plan, poorly articulated or absent Construction Control Methods, and insufficient demonstration of how a building will comply, often in relation to life-critical elements.

These shortcomings are particularly acute when it comes to the area of risk which became the catalyst for post-Grenfell regulatory change: the design of external wall systems and façades.

According to the HSE, many submissions to Gateway 2 have no clear articulation of fire resistance performance, incomplete information on fire-stopping or cavity barriers and vague descriptions of materials used for cladding, breather membranes and their role in fire prevention.

Manufacturers and suppliers of materials for higher-risk buildings should demonstrate compliance with credible methodology: the minimum fire safety requirements for façade components – Euroclass A2-s1,d0 for cladding and Euroclass B-s3, d0 for breather membranes – must be independently tested to the EN 13501-1 industry standard. It’s important for applicants to understand that component-level compliance is no longer enough. The BSR requires evidence that the entire through-wall build-up functions as a cohesive system, meeting the requirements for fire resistance, thermal performance, structural integrity and weather protection.

Evidence should consider potential interrelationships between performance metrics. For instance, breather membranes with the highest fire safety classification (Euroclass A1) use a lighter coating to achieve this, which reduces their water tightness. While A1 membranes are ideal for closed facades, they cannot provide the highest (W1) water tightness recommended for partially open facades, potentially compromising long-term fire protection, so an A2 or B class membrane with a W1 rating is often a more suitable solution in such cases.

Gateway 2 applications should consider that level of detail in ascertaining building compliance that will stand the test of time. Submissions that rely on desktop studies or assumptions of equivalence face increasing scrutiny. Third-party testing, certification, and system-level validation are essential.

Navigating these complexities can be daunting, but resources are available to help. Industry bodies such as the Construction Leadership Council (CLC), Build UK, the Home Builders Federation (HBF) and Construction Industry Council (CIC) have published helpful guidance, templates and best-practice tools to aid compliance. These should be standard references for all project teams.

Engaging early with safety-driven manufacturers is invaluable. They can provide deep technical insight, certified system data and comprehensive evidence rooted in accurate and authentic performance declarations. That input can help applications to address any gaps in demonstrating compliance. Experienced manufacturers can often advise on the integration of approved fire protection measures and support better coordination between system specification and actual buildability,

Design teams must work more closely with fire engineers, façade consultants, and manufacturers from the earliest design stages. Compliance cannot be an afterthought—it must be part of the process from day one. This approach minimises the risk of omissions in documentation and ensures that detailing and interfaces are coordinated across disciplines.

Gateway 2 should not be viewed as a bureaucratic hurdle—it’s a vital safeguard that demands higher standards of clarity and accountability. Making it work is a burden that the BSR cannot bear alone. It requires a shift in mindset across the industry, from developers and contractors to architects and façade specialists. Every invalid or incomplete submission ties up regulatory resources, delays the project, and worsens the queue for everyone else.

At ITP, we’ve supported clients at every stage of façade and external wall design, from system selection to technical compliance and documentation. We’ve seen first-hand how early collaboration, evidence-based detailing, system-based thinking and proper understanding of Gateway 2 requirements can keep projects moving.

The bar has been raised. As an industry, it’s up to us to meet it—together.

For further guidance related to designing and specifying compliant façade systems, please contact our Building Team on 01347 285200 or info@itpltd.com