The Golden Thread Explained: What It Means for Fire Safety and Building Safety Compliance
Three years on from Royal Assent, the Building Safety Act remains widely misunderstood by the very professionals it most directly affects. Here is what managing agents in the North West and North Wales need to know.
The Building Safety Act 2022 is described by the UK Government as the most significant reform to building safety regulation in a generation, and it has reshaped the legal framework within which managing agents operate. And yet, many of the agents we work with still seem to be uncertain about what the Act actually requires of them. This article provides a plain-terms account of the provisions most likely to affect professional property managers overseeing residential blocks, commercial premises, and mixed-use developments across Chester and Cheshire West, Liverpool and Merseyside, Greater Manchester, and North Wales.
The context: why the Act exists
The Building Safety Act 2022 was the legislative response to the Grenfell Tower fire of June 2017, in which 72 people lost their lives. The Hackitt Review, commissioned in the aftermath, concluded that the existing regulatory framework for building safety was not fit for purpose, characterised by a race to the bottom on costs, a confusion of responsibilities, and a culture of systemic non-compliance. The Act was Parliament's attempt to dismantle that framework and replace it with something more robust.
The core principle underpinning the Act is the concept of a clear, accountable duty-holder at every stage of a building's life, from design and construction through to occupation and ongoing management. For managing agents, it is the occupation phase that matters most.
Higher-risk buildings: the new regime
The Act introduces a distinct regulatory tier for what it calls higher-risk buildings, defined, at present, as residential buildings of at least 18 metres in height or at least seven storeys, containing two or more dwellings. For managing agents with buildings in this category, the implications are significant.
Higher-risk buildings must be registered with the Building Safety Regulator, an executive body established within the Health and Safety Executive. Registration is not optional. Managing agents acting as the Principal Accountable Person — the entity responsible for the external wall and structure — must ensure their buildings are on the register and must maintain a suite of documents known as the golden thread: a living, digital record of the building's design, construction, and ongoing safety management.
The golden thread is a dynamic record that must be updated whenever works are carried out, whenever safety-critical information changes, and whenever the building's safety case is reviewed. A robust fire safety policy and a current fire risk assessment are foundational elements of that record — without them, the golden thread is incomplete. For managing agents accustomed to periodic, static documentation, the shift to continuous, accountable record-keeping represents a material change in practice.
Register the building with the Building Safety Regulator. Identify and document the Principal Accountable Person. Establish and maintain the golden thread of building information. Produce and regularly review a Building Safety Case. Engage with residents through a mandatory Residents' Engagement Strategy. Notify the Regulator of any changes to the building's safety case. Apply for a Building Assessment Certificate before occupation of new buildings.
Lower-rise buildings: don't assume exemption
It is tempting, but mistaken, to conclude that the Act's most demanding requirements apply only to high-rise residential blocks and that lower-rise buildings are largely unaffected. The Act strengthens the fire safety framework across all multi-occupied residential buildings, not just higher-risk ones. The Fire Safety Act 2021, a precursor to the 2022 legislation, had already clarified that the scope of the Regulatory Reform (Fire Safety) Order 2005 extends to the structure, external walls, and flat entrance doors of all multi-occupied residential buildings, regardless of height. The Building Safety Act 2022 builds on this, strengthening enforcement powers, extending limitation periods for legal action, and creating new routes for residents to compel landlords and managing agents to address safety deficiencies.
Managing agents overseeing two-storey purpose-built flats in Chester or low-rise apartment blocks in south Liverpool are not outside this framework. They are within it, and the consequences of treating compliance as optional have become considerably more serious. A current fire risk assessment and a programme of regular fire door inspections are no longer best practice — they are the minimum baseline the Act and the FSO together require.
The Accountable Person and the Principal Accountable Person
The Act introduces two related but distinct concepts: the Accountable Person and the Principal Accountable Person. In a building with a single Accountable Person, typically the freeholder or head leaseholder responsible for repair and maintenance, that person is also the Principal Accountable Person. In buildings with multiple Accountable Persons, the one responsible for the structure and external walls takes the principal role.
For managing agents, the question of whether they are themselves an Accountable Person, or whether they act on behalf of one, has direct implications for legal liability. Agents who hold management responsibilities under a long-term management agreement, and who exercise discretion over the building's safety management, may find themselves characterised as an Accountable Person in their own right. This is not a question to leave to assumption. It warrants explicit legal advice and clear contractual drafting.
Residents' rights: a shift in the balance of power
One of the most practically significant changes introduced by the Act is the strengthening of residents' rights. Leaseholders and tenants in higher-risk buildings now have statutory rights to information about their building's safety, to be consulted on safety management decisions, and to raise safety concerns with the Building Safety Regulator directly. This matters for managing agents because it creates a channel of scrutiny that bypasses the agent entirely. A resident who believes that fire safety obligations are not being met can now escalate directly to a national regulator, and that regulator has real enforcement teeth.
Civil penalties under the Act are substantial, and the reputational consequences of a regulatory investigation are not trivial. In some cases, enforcing authorities have the power to take extreme measures — in July 2025 Merseyside Fire and Rescue Service served a formal prohibition notice ordering residents of Beech and Willow Rise in Kirkby to leave immediately. The implication is straightforward: managing agents who have historically treated fire safety documentation as an internal administrative matter should now treat it as a transparent, defensible record that could, at any point, be subject to external scrutiny.
What managing agents should do now
The first step is audit. Managing agents should identify, for every building in their portfolio, whether it meets the definition of a higher-risk building and, if so, whether it has been registered with the Building Safety Regulator. For lower-rise buildings, they should confirm that fire risk assessments are current, compliant, and produced by a competent assessor. Where the building contains fire doors in common areas or between flats and shared corridors, those doors should be subject to a regular programme of fire door inspections — the Fire Safety (England) Regulations 2022 introduced a quarterly self-check requirement for buildings above 11 metres, and an annual inspection by a competent person.
The second step is documentation. The golden thread concept — a live, accessible record of building safety information — is good practice for all buildings, not just higher-risk ones. That record should include the current fire risk assessment, fire door inspection reports, a fire safety policy, a fire evacuation plan, training records, and maintenance logs for all fire safety systems. Agents who can demonstrate a coherent, up-to-date safety record are in a fundamentally stronger position, both legally and reputationally, than those who cannot.
The third step is professional advice. The Building Safety Act is complex, its secondary legislation is still evolving, and the consequences of non-compliance are serious. Managing agents should not rely on a single article, including this one, as their guide. They should ensure that their fire risk assessments are conducted by competent assessors who understand the post-BSA landscape, and that their legal and compliance frameworks are reviewed in light of the Act's requirements. Where fire safety training records cannot be produced for all relevant staff, or where evacuation chair training has not been carried out for buildings where chairs form part of the evacuation strategy, those gaps should be addressed as a priority.
Ensure your buildings are BSA-compliant
Fletcher Risk provides fire risk assessments, fire door inspections, fire safety training, fire evacuation plans, fire safety policies, and evacuation chair training for managing agents across the full North West and North Wales — including Cheshire West and Chester, Cheshire East, Liverpool and Merseyside, Greater Manchester, Lancashire, Flintshire and Wrexham, the North Wales Coast, Gwynedd, Shropshire, and Staffordshire. Our assessors understand the post-Building Safety Act landscape and can help ensure your portfolio is compliant, documented, and defensible. Please get in touch.
Get in touch Fire risk assessments Fire door inspections Evacuation plans Fire safety policy Managing agentsThis article provides a general overview of the Building Safety Act 2022 and related legislation for information purposes only. It does not constitute legal, regulatory, or professional advice and should not be relied upon as a definitive or comprehensive account of the law. The Building Safety Act 2022 is supported by extensive secondary legislation, statutory guidance, and regulatory policy that continues to evolve. Managing agents, landlords, and other responsible persons should seek independent legal advice in relation to their specific obligations. Fletcher Risk Management Ltd accepts no liability for any loss, damage, penalty, or regulatory sanction arising from reliance on the contents of this article.