The Building Safety Act 2022 represents the most significant reform of building safety regulation in England since the Building Act 1984. Born from the recommendations of Dame Judith Hackitt's Independent Review of Building Regulations and Fire Safety, the Act creates a new regulatory framework for higher-risk buildings — one that places clear, personal accountability on those responsible for managing building safety.
For organisations managing residential buildings at least 18 metres in height or with at least 7 storeys containing two or more residential units, understanding the role of the Principal Accountable Person is not optional. It is a statutory obligation with potential criminal sanctions for non-compliance.
Who Is the Principal Accountable Person?
The Building Safety Act introduces the concept of the Accountable Person — the entity that holds a legal estate in possession of any part of the common parts of a higher-risk building, or that does not hold such an estate but is under an obligation to repair or maintain those common parts. Where there is more than one Accountable Person for a building, one must be designated as the Principal Accountable Person (PAP). The PAP is typically the freeholder or the management company with repairing obligations for the structure and exterior.
The PAP carries overarching responsibility for the safety of the building. This includes coordinating with other Accountable Persons, registering the building with the Building Safety Regulator (BSR), applying for a Building Assessment Certificate, and maintaining the safety case for the building on an ongoing basis.
Registration and Building Assessment Certificates
All higher-risk buildings in England must be registered with the BSR. Registration requires the PAP to provide key building information including the building's height, number of storeys, number of residential units, structural type, and external wall materials. The deadline for registration of existing occupied higher-risk buildings has passed, and the BSR has enforcement powers against those who have failed to register.
Following registration, the PAP must apply for a Building Assessment Certificate (BAC). The BAC application requires the PAP to demonstrate that they are managing building safety risks effectively. This includes submitting a safety case report that sets out how fire and structural safety risks have been identified, assessed, and are being managed.
The Safety Case Approach
The safety case approach requires the PAP to take a proactive, systematic approach to managing building safety. Under the safety case approach, the PAP must:
- Assess all building safety risks — not only fire risk, but also structural safety risks
- Take all reasonable steps to prevent a building safety risk materialising, and to reduce the severity of any incident that does occur
- Prepare a safety case report demonstrating how risks are identified, assessed, managed, and kept under review
- Establish and maintain a mandatory occurrence reporting system
- Prepare and maintain a residents' engagement strategy
How Apex Can Help
Apex Fire Engineering supports Principal Accountable Persons in preparing for Building Assessment Certificate applications. We deliver fire risk assessments, retrospective fire strategies, compartmentation surveys, external wall appraisals, and building safety case reports — the technical fire safety documentation that underpins the safety case. Every instruction is led by a senior practitioner who understands both the technical requirements and the regulatory expectations of the BSR.