At the heart of this new regime are Gateway 2 and Gateway 3, which place greater scrutiny on the design, construction and completion of higher-risk buildings (HRBs).

For fire engineers and specialists, these changes bring new responsibilities, higher expectations around competence, and a much greater emphasis on detailed, compliant design before work begins on site.

To support the industry, the FIA has developed guidance to help fire engineers and fire safety specialists understand their role within Gateway 2 and Gateway 3 submissions. This guidance reflects FIA’s interpretation of the regulations and is intended to assist those involved in preparing fire strategies, designing fire safety systems, or contributing to compliance on HRB projects.

Why this matters

Gateway 2 is now a critical approval stage before construction can begin on HRBs. It requires a robust and fully developed design that clearly demonstrates compliance with Building Regulations. Gateway 3, at completion, ensures that what has been built aligns with what was approved, supported by full documentation and evidence.

Understanding these requirements early is essential. Errors, incomplete submissions, or late design changes can lead to costly delays, rejected applications, or issues at handover.

Key points from the FIA guidance

• Gateway 2 applies to all ‘building work’ on HRBs and applications must go directly to the Building Safety Regulator (BSR), not local authorities.
• Approval at Gateway 1 does not guarantee Gateway 2 approval as they sit under different legislation and assess different criteria.
• Design maturity is critical. FIA recommends designs are developed to RIBA Stage 4 before submission.
• Fire strategy and system designs are central. Submissions must include a comprehensive Fire and Emergency File and detailed fire safety designs.
• Competence must be demonstrated, ideally through third-party certification or professional registration.
• Change control is tightly managed. Most fire-related changes during construction will be classed as Major Changes, requiring BSR approval.
• Gateway 3 requires ‘as-built’ information, including updated fire strategies and evidence from installation and inspection stages.

FIA would strongly recommend that anyone involved in a Gateway 2 submission should carefully read the following guidance documents and websites that have been published by the BSR and the government.

• https://www.hse.gov.uk/building-safety/building-control/regime-overview.htm
• https://buildingsafety.campaign.gov.uk/building-safety-regulator-making-buildings-safer/the-building-control-authority/
• https://www.gov.uk/guidance/building-control-approval-for-higher-risk-buildings)

Read the full FIA FAQs (scroll down to the relevant section) and guidance to ensure your projects remain compliant and avoid costly delays.