Passing Gateway Two: What you need to know from an MEP expert

What is Gateway 2 and Why Does it Matter?

Introduced under the Building Safety Act 2022, Gateway 2 (also referred to as Gateway Two) is the regulatory checkpoint at which construction can begin on a higher-risk building (HRB), typically any residential or mixed-use building over 18 metres or seven storeys in height. No work may commence until the Building Safety Regulator (BSR) has reviewed and approved the full design documentation, making it one of the most significant quality gates in the UK construction process.

The BSR's Gateway 2 guidance sets out the full application requirements. Getting the submission right the first time is critical, as rejection can trigger costly redesigns, programme delays, and contractual complications that affect the entire project team.

According to the Construction Plant-hire Association (CPA), more than 150 high-rise residential construction projects across the UK have been delayed by the BSR’s Gateway Two regulatory checkpoint. In fact, a survey undertaken by the association revealed schemes had typically been delayed by up to 40 weeks, compared to the two-week approval timeline that was originally intended.

While we have seen a few of our projects pass this vital checkpoint in recent weeks and months, we are well aware of the substantial impacts Gateway Two is having on the built environment.

With that in mind, I feel it’s pertinent to underline the importance of passing this checkpoint and what designers, consultants, architects and property developers can do to increase the likelihood of doing so.

The Vital Need to Signpost Information

There have been many occasions where industry associates have told us their construction projects have been rejected by the BSR because ‘there was a lack of information provided’. While, sometimes this is true, there are also repeat instances of all relevant information being provided but it being missed by the individual(s) reviewing the application.

With the BSR having to review huge numbers of project applications, this is perhaps somewhat forgivable. However, it emphasises the need for anyone submitting an application to be as clear as possible and to ‘signpost’ all the vital information to prevent it being missed.

It’s also well worth providing a narrative-driven explanation of how each element of the design meets the respective requirements of the Building Regulations. This can be done in the Compliance Statement, a key document that accurately demonstrates compliance through the provision of clear examples and the use of specific standards and codes where possible.

Co-ordination is Essential for Gateway 2 Approval

When it comes to building design, taking a holistic approach can have a major impact on whether a project application passes Gateway Two. For instance, in higher-risk buildings, sprinkler systems and other Contractor Designed Portion (CDP) items will be required to provide enhance fire safety. These products will need to be integrated into building design at the earliest possible opportunity.

Similarly, other safety-critical elements, from fire stopping plans and fire strategies through to waterproofing and structural integrity, will need to be effectively co-ordinated from the outset Doing so will ensure that all these critical aspects of building and fire safety work together effectively – increasing the likelihood of the project application passing Gateway Two.

The other key benefit is that you will have a near complete coordination package between the design team, reducing any issues on site once the build has started.

The main MEP Contractor Design Portion (CDP) packages that would typically need to be engaged for a BSR submission include sprinkler systems, fire alarm systems, smoke ventilation systems, dry/wet riser systems, evacuation alert systems, PV and secondary supply systems, and disabled refuge alarm systems. Ensuring all of these are specified, co-ordinated, and documented in parallel, rather than sequentially, is central to a strong Gateway 2 application.

Gateway 2 Document Requirements: Plan Ahead

Of course, preparing documents in advance and being methodical in your approach is crucial. With the BSR demanding many mandatory documents and items, such as competence declarations, fire emergency files and project and team information, cross-referencing everything and only including what’s relevant to your project can make a huge difference on the speed of BSR assessment and the likelihood of success.

It’s also worth bearing in mind the application process isn’t something that takes place overnight. So, account for that when planning and submitting your application. In fact, the BSR actually recommends giving notice up to six months prior to your planned submission. Therefore, it is essential the clients allow sufficient time for the design team to produce and coordinate the information to ensure this is not something picked up by the BSR.

It would also be worth acknowledging and understanding the process for applying to the Secretary of State for a non-determination in case the BSR doesn’t respond within the statutory timeframe.

Consult with experienced specialists

It may sound obvious, but seeking advice and support from experienced consultants and industry experts can make a huge difference to the success or failure of your BSR application. With the Gateway Two approval process an incredibly stringent and time-consuming affair, avoiding rejection cannot be understated.

So, engage specialists in building and fire safety, not to mention compliance, and provide them with all necessary information for them to review designs and documentation before you apply to the BSR. Any weaknesses or potential pain points will be identified early and give you the ideal opportunity to address them before it is too late. This will also prevent much more costly alterations further down the line.

Some of the main MEP Contractor Design Portion (CDP) packages that would need to be engaged for a BSR system include sprinkler systems, fire alarm systems, smoke ventilation systems, dry/wet riser systems, evacuation alert systems, PV systems, secondary supply systems and disabled refuge alarm systems.

At Whitecode Consulting, we specialise in providing clients from across the UK with first class MEP design and sustainability consultancy services. Through our comprehensive and unrivalled support and guidance, we have helped several clients with successful Gateway Two applications.

Our Design Audit and Peer Review service is specifically designed to help project teams sense-check their documentation ahead of submission, identifying weaknesses before they become grounds for rejection. We work across residential and mixed-use developments, bringing the MEP design, fire engineering, and building analysis expertise needed to maximise your chances of first-time approval.