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Building Safety Regime and the Golden Thread of Information

  • What systems and internal digital capabilities do you need? 
  • What processes and governance groups are required to enable the Golden Thread? 
  • What information needs to be provided, by whom, and when? 

Cohesive is helping clients such as Related Argent, Landsec U+I, and more* getting ready for the new Building Safety regulatory regime and the Gateways – setting out internal processes, systems, digital capabilities, and governance required, alongside the definition of Information Exchange Requirements from a Building Safety Act perspective, vital to enable the Golden Thread of Information from Capital delivery through Handover to Operations, meet the new statutory requirements, and stay on pace with the current market. 

With the new Building Safety Regime coming into force soon, it is important to understand which buildings are considered higher-risk buildings during the occupation phase of the higher-risk regime. 

The government released a guidance document published on the 21st of June 2023 to clearly establish the ‘Criteria for being a higher-risk building during the occupation phase of the new higher-risk regime’, only applicable to England. This guidance aims to answer three important questions around the following topics: 

  • Use criteria 
  • Legal definition of building 
  • Height and stories 

But let’s look closer at each topic and what questions need answering:  

Use criteria: 

  • What is my building used for? 
  • Does it meet any of the included or excluded categories of building? 


If an occupied building meets the height or stories threshold and contains at least two residential units, then it is a higher-risk building. This applies unless the entire building is used as: 

  • A care home 
  • A hospital 
  • A secure residential institution (e.g., prison, young offenders institution, detention center, secure training center, custody center, short-term holding center or secure local authority accommodation) 
  • A hotel 
  • Military barracks 

It also excludes buildings that contain living accommodation either provided by the Ministry of Defence, for His Majesty’s forces or any visiting force, or an international headquarters or defense organization designated for the purposes of the International Headquarters and Defence Organisations Act 1964. 


All other in-occupation residential buildings not listed in the exclusions above that meet the height or stories threshold and contain at least two residential units including mixed-used buildings – the guidance provides a few examples: 

  • Shopping center with at least two residential units 
  • University student accommodation (including private) 
  • Boarding accommodation in schools 
  • Supported and sheltered accommodation (e.g., domestic abuse refuges, children’s homes) 
  • Supported or sheltered homes for older people and those with additional care needs (which do not fall within the definition of a care home)

Legal definition of building:  

  • How does the building definition in the Regulations apply to my building structure? 

Buildings can be complex. In order to understand if part of an overall building structure can be an ‘independent section’, and considered a ‘building’ on its own from a higher-risk regime point of view, the following has to be considered: 

  • The section has its own entrance and exit to the outside, accessible from anywhere within that section, and either, 
  • has no access to any other section within the overall structure or, 
  • only has access to another section of the overall structure that does not contain a residential unit (e.g., basement) 

Once an independent section of the overall structure has been established, it still needs to meet the height or stories threshold and contain at least two residential units in order to be considered a ‘building’ from a higher-risk regime. 

The government guidance provides 7 diagrams/examples of different building types and how they can be interpreted under the definition in the Regulations.  

Height and stories:  

Does my building need to meet both height and story thresholds in order to be a higher-risk building? 

If the building already meets the use criteria (see topic 1 above), then it needs to meet the 18-metre or the seven-storey height threshold to be a higher-risk building. 

It does not need to meet both height thresholds. 

How do the methods for measuring height and stories in the Regulations apply to my building? 

Measuring height 

Height is measured from the external ground level, up to the floor-finished surface of the top story (excluding top stories used entirely as plant rooms). 

If the ground level around the building varies or is uneven, the height of the building is measured from the lowest part of the ground that touches the building.  

Measuring stories 

Stories should be counted from the story at ground level to the top story (excluding top stories used entirely as plant rooms). 

Stories that are entirely below ground should not be counted. However, semi-basements or stories where the finished ceiling is above the lowest part of the ground adjacent to the building will need to be counted. 

As some buildings might have galleries (also known as mezzanines), these will only be counted for the overall number of stories if the floor area of the gallery is at least 50% of the internal floor area of the largest above-ground story (above or below the gallery floor). 

The government guidance provides 5 diagrams/examples of different building configurations and how both height and story thresholds should be interpreted under the definition in the Regulations. 

Rui, a seasoned architect with over 15 years of design experience, brings a fervent commitment to both BIM and sustainability to his professional journey. He transitioned to a pivotal role as Head of BIM at a prominent international architectural firm, where he honed his expertise in shaping and executing digital strategies, contributing significantly to the successful delivery of high-profile projects spanning from conception to handover.

With an unwavering dedication to continuous learning, Rui has emerged as a recognized authority on critical topics such as the Building Safety Act and the Golden Thread of Information since joining Cohesive. This additional expertise enhances his already robust skill set.

Known for his exceptional leadership and strong interpersonal abilities, Rui is a catalyst for meaningful change. He excels in striking the delicate balance between people, processes, and digital tools, consistently driving progress in pursuit of excellence.

Rui Costa
Business Analyst: Buildings and Communities

Disclaimer: The information provided in this article is for general information only. All information provided here is one person’s interpretation and it cannot be used for legal purposes. Cohesive holds no responsibility and makes no representation or warranty about the accuracy or completeness of this information.

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