Two thirds of building assessment certificate applications have been refused this year. That is an evidence problem.

On 9 July 2026 the Building Safety Regulator published something unusual: an admission that its own process was not working at the pace it planned, and a change of approach.

Since building assessment certificates began in April 2024, the BSR has directed principal accountable persons to apply in respect of nearly 2,000 buildings. Assessment is taking twice as long as it expected. And 66 per cent of the applications it has determined this year have been refused.

There are more than 6,000 accountable persons and principal accountable persons in England. Most have not yet been called in.

What the regulator actually said

The BSR will now call in new applications only when necessary until improved processes are agreed. It will prioritise applications already in assessment, explore fast track reassessment for buildings previously refused, focus on organisations responsible for multiple higher risk buildings, and give small volunteer run resident management companies more time.

Then it said the part easiest to misread as a reprieve.

Principal accountable persons must not wait. Managing fire and structural safety, running a mandatory occurrence reporting system and engaging residents are enforceable duties in their own right, and have been since January 2024. They do not switch on when the BSR writes to you. A slower certificate queue is not a slower compliance clock.

When the direction does arrive, you have 28 calendar days to submit. The application bundles the safety case report, details of your mandatory occurrence reporting system, the resident engagement strategy, serial numbers of any active compliance notices and confirmation of information sharing. The application charge is £312, on top of which the BSR recovers assessor time at £156 per hour plus any third party costs. Given that assessment is running at twice the expected length, the hourly element is the one to budget for.

Twenty eight days is not enough time to build a safety case. It is enough time to assemble one you already have.

The golden thread in occupation is not optional

The information you must keep is prescribed in Schedule 1 to the Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2024 (SI 2024/41). The standard for keeping it sits in regulation 7 of the Higher-Risk Buildings (Management of Safety Risks etc) (England) Regulations 2023 (SI 2023/907). Both commenced on 16 January 2024.

Regulation 7 requires the information to be electronic, transferable without loss or corruption, accurate, intelligible to its intended readers, accessible as soon as reasonably practicable on request, secure from unauthorised access, and changed only under procedures that record who changed it and when. Copies of documents have their own test: they must be accessible promptly in response to a request.

That change control clause is doing a lot of work. It rules out anything you cannot audit.

The fire safety duties stack up quickly

The Fire Safety (England) Regulations 2022 came into force on 23 January 2023. In a high rise residential building, meaning 18 metres or seven storeys and above, the responsible person must give the fire and rescue service up to date electronic floor plans and a hard copy building plan in the secure information box, provide external wall design and materials information, check lifts intended for firefighter use and other key firefighting equipment monthly, report a defect to the fire service if it is not fixed within 24 hours, and install wayfinding signage visible in low level lighting or when lit by a torch. Above 11 metres, add annual checks of flat entrance doors and quarterly checks of all fire doors in common parts.

Since 1 October 2023, section 156 of the Building Safety Act has required the responsible person to record the fire risk assessment in full, not just the significant findings, and to record the fire safety arrangements in all circumstances. It also raised fines for three specified offences from level 3 to level 5, which is unlimited.

Since 6 April 2026 the Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 have required responsible persons in scope to identify residents who need support, carry out person centred fire risk assessments, and prepare emergency evacuation statements and a building emergency evacuation plan.

The enforcement picture is not comfortable. In the year to March 2025, fire and rescue services in England carried out 51,020 fire safety audits. 21,306 of them, 42 per cent, were unsatisfactory, close to the previous year, which was the lowest satisfactory proportion since the year ending March 2011. The Home Office is careful to say this reflects sharper targeting of higher risk premises rather than proof of falling standards. Either way, if you are on that target list, the audit is coming.

Maintenance evidence is the same problem wearing different clothes

SFG20 remains the working reference for maintenance specification in the UK. It was created in 1990 by the body now known as BESA, and SFG20 states its library runs to over 2,000 maintenance task schedules. Be precise about its status: it is a commercial subscription library, not a statutory instrument, and no law mandates it. Its authority is de facto.

In June 2026 SFG20 launched a Ratification and Compliance Committee, meeting quarterly, to independently challenge and ratify the governance behind every schedule update. Its head of compliance framed the move against AI generated maintenance content that can appear authoritative but often lacks the legislative and technical insight behind it. That is a signal worth reading.

On the money, the National Audit Office put the government building maintenance backlog at at least £49 billion in January 2025, and quoted a Cabinet Office estimate that deferring backlog maintenance can multiply costs by over 1.5 times over a two to four year period. Deferral is not a saving. It is a loan at a punitive rate.

What OnXR does about it

A spatial intelligence platform will not write your safety case. It will change what your safety case is built on.

Regular 3D captures, meaning photorealistic three dimensional reconstructions you can navigate and measure, create a dated record of condition rather than a folder of photographs with no provenance. Compare two captures and you see what changed between them. Annotate a defect and the annotation carries who raised it and when. Where the record can be linked to work orders in a CAFM or EAM system such as IBM Maximo, the maintenance history sits in the place it happened rather than in a row of a table.

For a compliance officer, that is the difference between asserting a condition and evidencing it.

If you are managing a portfolio of higher risk buildings and you would not want to be called in next month, the useful question is not whether your evidence exists. It is whether you could produce it in 28 days. Our pieces on asset visibility across an estate and planned maintenance with live sensor data go into the day to day of it.

This article is general information about UK regulation and is not legal advice. Responsible persons and accountable persons should take their own advice on their specific obligations.