The golden thread is a data problem, and most projects are still solving it with photographs
Nearly three years on from the golden thread duties, the question on higher risk buildings is no longer whether you need a digital record. It is whether the record you have would survive being examined.
Nearly three years on from the golden thread duties coming into force, the question on higher risk buildings is no longer whether you need a digital record. It is whether the record you have would survive being examined.
What the law actually asks for
The duty sits in the Building (Higher-Risk Buildings Procedures) (England) Regulations 2023 (SI 2023/909), regulation 31, in force since 1 October 2023. It lands on the client, not the contractor. The client must arrange for an electronic facility to hold the golden thread information, created and maintained by the client or by someone on their behalf, and give designers and contractors access to it.
Regulation 31 then sets eight standards for that information. Most of them are unremarkable. Two are not, and they are the two that catch people out.
The information must be secure from unauthorised access. And it must only be changed under procedures that record who made the change and the date they made it.
Read that second one slowly. It is a version control requirement written into building safety law. A shared drive full of site photographs does not meet it. Neither does a folder of PDF surveys with filenames ending in _FINAL_v3_revised. If you cannot show who altered a record and when, you do not have a golden thread. You have an archive.
The same standards reappear for occupied buildings in the Higher-Risk Buildings (Management of Safety Risks etc) (England) Regulations 2023 (SI 2023/907), regulation 7, with the information itself prescribed in Schedule 1 to the Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2024 (SI 2024/41). Both commenced on 16 January 2024. Two separate regimes, one evidential standard.
The regulator has changed, and so has the pressure
On 27 January 2026 the Building Safety Regulator left the Health and Safety Executive and became a standalone body under MHCLG. The government confirmed on 9 July 2026 that it intends to go further and create a Single Construction Regulator, with implementation not expected before 2028.
In the meantime, the numbers tell you where the friction is. In the regulator's May to July 2026 application data, the median time to approve a Gateway 2 application for a new higher risk building was 22 weeks, against a statutory determination period of 12. Work to existing higher risk buildings ran to a median of 32 weeks for internal works and 34 for external remediation, against a statutory 8. Gateway 3 completion certificates ran to 16 weeks against a statutory 8, although that is on 29 determinations, all of them internal refurbishments, because no new build has yet reached Gateway 3. There were 1,547 Gateway 2 cases in progress.
22 week median against a statutory 12, with a 91 per cent approval rate, up from 39 per cent a year earlier.
32 weeks for internal works, 34 for external remediation, against a statutory 8 weeks.
1,547 Gateway 2 applications in progress at the end of July 2026.
The trend is improving. New build approval rates went from 39 per cent a year earlier to 91 per cent, and the median approval time fell from 43 weeks to 22. That came from better applications, not a softer regulator. On 22 June 2026 the BSR published guidance on the level of detail expected in remediation applications and the common shortfalls it keeps seeing. That is a regulator telling the market the evidence is the bottleneck.
Where the money goes when the evidence is weak
International studies cited in the Get It Right Initiative's Strategy for Change put the direct cost of avoidable error in UK construction at around 5 per cent of project value, roughly £5 billion a year, rising to between 10 and 25 per cent once indirect costs are counted. GIRI's own research puts the figure higher still, at around 21 per cent, or £21 billion a year. Treat all of these as orders of magnitude rather than live measurements.
A CITB funded GIRI training pilot reported in April 2026 is more concrete. It covered 25 UK projects worth £942.5 million and recorded £92.6 million of avoided error, 9.8 per cent of project value, with inadequate planning accounting for £71.2 million of it.
None of that is caused by a lack of photographs. It is caused by nobody being able to establish, quickly and defensibly, what was actually there on a given date.
What a spatial record changes
This is the specific problem OnXR was built for. A 3D Gaussian Splatting capture, which is a photorealistic three dimensional reconstruction of a real space, produces a measurable, navigable record of site condition at a point in time rather than a set of disconnected images. Capture the same space at intervals and you have a time series you can compare.
Every capture carries its own timestamp and provenance, so the record of when something was in a given state is inherent rather than reconstructed after the fact. Annotations and approvals carry the identity of the person who made them and the date, which is the audit behaviour regulation 31(2)(g) asks for. And because captures sit alongside IFC and BIM models in the same viewer, they work as a visual layer inside an information management framework built on ISO 19650 rather than as a parallel system nobody trusts. ISO 19650 gained a sixth part in January 2025 covering health and safety information, which is worth reading if your common data environment predates it.
Two honest caveats: OnXR is not a compliance tool and does not make you compliant. It provides evidence and visibility, and the duty holder remains the duty holder. And the golden thread is broader than visual data. It takes in approved plans, change control records and mandatory occurrence reports. A spatial record is one strand of it, not the whole.
The handover point nobody plans for
CDM 2015 regulation 12 requires the principal designer, or the principal contractor where there is no principal designer, to prepare the health and safety file and pass it to the client at the end of the project. Regulation 4(5)(b)(iii) requires the client to ensure that file is kept available for inspection by anyone who may need it to comply with a legal requirement. Regulation 4(7) then provides that, on disposal, the client meets that duty by passing the file to the acquirer and making them aware of its nature and purpose.
That file has to make sense to a facilities manager in 2035 who never met anyone who built the place. A folder of site photographs will not. A navigable record of what is behind the wall, captured before the wall went up, might.
If you are preparing a Gateway 2 or Gateway 3 submission and the evidence base is the part keeping you up at night, that is the conversation to have. Our earlier pieces on site capture as handover evidence and the IFC overlay inside the twin cover the mechanics.
This article is general information about UK regulation and is not legal advice. Duty holders should take their own advice on their specific obligations.
Talk to us about your Gateway evidence
We can walk you through how a dated, navigable record of a site sits inside an ISO 19650 information management approach, and what it does and does not do for a regulation 31 duty.
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