Building Safety Act 2022 Compliance
What the Act now requires of principal contractors on competence, dutyholders and the golden thread, and how digital workforce readiness tracking turns a legal duty into evidence you can produce on demand.
The Building Safety Act 2022 is the most significant change to building safety regulation in England and Wales in a generation. It followed the Grenfell Tower fire and the independent review of building regulations and fire safety led by Dame Judith Hackitt, which concluded that the regulatory system had allowed competence to be assumed rather than evidenced, and accountability to be diffused across a supply chain nobody could see end to end.
The Act reframes that. It puts named dutyholders in charge of building work, requires them to take all reasonable steps to ensure competence across the supply chain, and holds a golden thread of information that follows a higher-risk building from design through construction to occupation. For principal contractors, the practical effect is a new legal duty to evidence competence, not just to describe a process that should produce it.
This guide sets out what the Act requires, where the competence duty bites, and how digital workforce readiness tracking helps a principal contractor meet it with evidence rather than paperwork.
What the Building Safety Act Changed
The Act received Royal Assent in April 2022, with its core duties and the higher-risk building regime commencing from October 2023. It made four structural changes that bear directly on how a principal contractor runs a construction phase.
The Act established the Building Safety Regulator. Since 27 January 2026, the BSR has operated as a standalone body sponsored by the Ministry of Housing, Communities and Local Government, independent of the Health and Safety Executive. The regulator oversees the safety and performance of buildings, runs the gateway approval and registration regime for higher-risk buildings, and leads industry-wide work to raise competence and building safety standards.
For building work, the Act introduces dutyholder roles that mirror the CDM 2015 model: the client, the principal designer and the principal contractor. Each has legal responsibilities for managing building safety, and the principal contractor is accountable for the construction phase, including the competence of the people who carry out the work.
Buildings in England that are at least 18 metres or seven storeys high and contain two or more residential units are higher-risk buildings. They are governed across their whole life cycle through three gateways: Gateway One at planning, Gateway Two before construction begins, and Gateway Three before occupation. Each gateway requires Building Safety Regulator approval, and an occupied higher-risk building must be registered and hold a Building Assessment Certificate.
The Act requires the creation and maintenance of a golden thread of information for higher-risk buildings: the accurate, up-to-date information needed to manage the building safely across its whole life cycle. For the principal contractor, that means the construction phase must produce a live, evidenced record, not a file assembled at handover.
The Competence Duty on Principal Contractors
The centre of the Act for a principal contractor is the competence duty. As a dutyholder for building work, the principal contractor must take all reasonable steps to ensure that anyone appointed, at any tier of the supply chain, has the skills, knowledge, experience and behaviour to carry out their work safely and to the standard the building requires.
Two things about that duty matter in practice. The first is that it extends through the supply chain, not only to the subcontractor you have a direct contract with. The second is that it widens the definition of competence beyond the CDM 2015 standard of skills, knowledge and experience to include behaviour. That is the SKEB standard: Skills, Knowledge, Experience, Behaviours. It recognises that how people work on site, whether they follow process, report defects and cooperate, is part of being competent, not a separate concern.
The competence duty is enforced through the Building Regulations etc. (Amendment) (England) Regulations 2023, which brought the dutyholder and competence requirements into building regulations for building work generally, not only higher-risk buildings. The golden thread and gateway requirements are specific to higher-risk buildings, but the expectation that a principal contractor manages and can evidence competence runs across building work.
Where the Duty Bites on Site
The duty starts at appointment. A principal contractor must take all reasonable steps to ensure a subcontractor, at any tier, is competent before they start work. A PQQ or SSIP certificate at tender is a start, not the end. The Act expects you to be able to evidence the competence of the organisation and the individuals it sends to site.
Site-specific induction is where generic competence becomes site-specific. The Act's behaviour requirement means attendance is not enough. A principal contractor needs evidence that a worker attended the induction and understood the hazards specific to that site and that day.
Competence is time-limited. A CSCS card, an NPORS card or a specialist certification proves a test was passed at a point in the past. The duty is to verify those credentials are current for the people on site now, and to hold the evidence.
The duty runs through the chain. If your visibility stops at the subcontractor you appointed, you are evidencing the tier you can see and relying on hope for the rest. The Act expects reasonable steps across every tier, which requires visibility past the first.
How Workforce Readiness Tracking Meets the Duty
The gap the Act exposes is the gap between a competence process and competence evidence. Most principal contractors can describe how they manage competence. Far fewer can produce, on demand, evidence that a specific worker on a specific site was inducted, understood the briefing, held a valid credential, and was checked at the tier they were working at. That is the gap digital workforce readiness tracking closes.
LUMA1 holds the competence, induction and attestation evidence the Act expects against every worker, on every site, across every tier of the supply chain, and turns it into a single Cleared or Not Cleared status backed by a timestamped audit trail. It does four things that map directly to the duty:
- It evidences competence at the individual, not just the organisation. A subcontractor's company-level accreditation does not prove the person at your gate this morning was inducted and holds a valid card. LUMA1 holds that evidence per worker.
- It checks understanding, not just attendance. The Act's behaviour requirement means induction must be understood, not just sat through. LUMA1 checks understanding and records the result against the worker and the site.
- It verifies credentials and flags expiry. Card validity is checked and tracked over time, so a credential that lapses mid-project surfaces as Not Cleared before the worker returns to site, not after an audit asks for it.
- It extends visibility past the first tier. The duty runs through the supply chain. LUMA1 holds the readiness record per worker rather than per session, so the same standard applies to the tier your subcontractor brought in beneath them.
The result is evidence the golden thread and competence duties require: who is on site, whether they were inducted and understood it, whether their credentials are valid, and whether the tier beneath them was ever checked. The status is one word. The evidence is one link.
For a fuller treatment of the underlying standard, our guide to workforce readiness in UK construction sets out the SKEB standard in full, and our guide to managing subcontractors covers the supply chain competence regime the Act reinforces.
Common Questions
What is the Building Safety Act 2022?
The Building Safety Act 2022 is the principal piece of legislation reforming building safety in England and Wales following the Grenfell Tower fire. It received Royal Assent in April 2022, with its core duties commencing from October 2023. It established the Building Safety Regulator (which became a standalone body on 27 January 2026, sponsored by the Ministry of Housing, Communities and Local Government), introduced dutyholder roles for building work, created a new higher-risk building regime with a gateway approval process, and placed new legal duties on principal contractors to manage and demonstrate competence throughout the supply chain.
What does the Building Safety Act require of principal contractors?
The Act requires principal contractors, as dutyholders for regulated building work, to take all reasonable steps to ensure that everyone they appoint, at every tier of the supply chain, has the skills, knowledge, experience and behaviour (SKEB) to carry out their work safely and to the required standard. They must manage competence throughout the project, maintain the golden thread of information, and cooperate with the client, principal designer and Building Safety Regulator. These duties apply to the construction phase of higher-risk buildings and, through the competence regulations, to building work more broadly.
What is the higher-risk building regime?
The higher-risk building regime applies to buildings in England that meet or exceed 18 metres in height or seven storeys, and contain at least two residential units. It governs these buildings across their whole life cycle through three gateways: Gateway One at planning, Gateway Two before construction starts, and Gateway Three before occupation. Each gateway requires Building Safety Regulator approval, and the building must be registered and hold a Building Assessment Certificate once occupied.
What is the golden thread of information?
The golden thread is the requirement to create, hold and maintain the information needed to manage a higher-risk building safely across its whole life cycle. For principal contractors it means keeping accurate, up-to-date records of the building's design, construction, and safety case, so that the dutyholder accountable for the building in occupation can demonstrate it is safe. It is a live, evidenced record, not an archive assembled at handover.
What is the SKEB competence standard?
SKEB stands for Skills, Knowledge, Experience and Behaviours. The Building Safety Act 2022 widens the CDM 2015 definition of competence beyond skills, knowledge and experience to include behaviour, recognising that how people work on site, whether they follow process, report defects and cooperate, is part of being competent. Principal contractors are expected to assess and evidence SKEB for the people they appoint, not just rely on a card or certificate.
Does the Building Safety Act apply to all construction work or only higher-risk buildings?
The competence dutyholder regime introduced under the Act applies to building work generally through the Building Regulations etc. (Amendment) (England) Regulations 2023, not only to higher-risk buildings. The gateway, registration and golden thread requirements are specific to higher-risk buildings, but the duty on principal contractors to manage and demonstrate competence extends across building work, reflecting the Act's aim to raise standards industry-wide.
Who is the Building Safety Regulator?
The Building Safety Regulator is the regulator established by the Act. It became a standalone body on 27 January 2026, sponsored by the Ministry of Housing, Communities and Local Government, separate from the Health and Safety Executive it previously sat within. It oversees the safety and performance of buildings, regulates higher-risk buildings through the gateway and registration regime, and leads work to improve competence and building safety standards across the construction industry.
How does LUMA1 help principal contractors meet Building Safety Act duties?
LUMA1 holds the competence, induction and attestation evidence the Act expects against every worker, on every site, across every tier of the supply chain, and turns it into a single Cleared or Not Cleared status with a timestamped audit trail. That gives a principal contractor live evidence of who is on site, whether they were inducted and understood it, whether their credentials are valid, and whether the tier beneath them was ever checked, the evidence the golden thread and competence duties require.
The Act Asks for Evidence, Not Process.
The Building Safety Act 2022 moved competence from something a principal contractor describes to something a principal contractor must prove. LUMA1 holds the induction, credential and attestation evidence the Act expects against every worker, on every site, across every tier, so the status is one word and the evidence is one link.