Registering a higher-risk building: the PAP's first duty
Every higher-risk building in England must be registered with the BSR before it is occupied, and registration is the principal accountable person's duty. Occupying an unregistered higher-risk building is a criminal offence, and existing buildings had to be registered by 30 September 2023.
What is registration, and why does it exist?
The register is the regime's census: the BSR cannot regulate buildings it cannot see, so every higher-risk building in England must be registered before occupation, with existing buildings swept in by the 30 September 2023 deadline. Registration puts the building, its basic characteristics and, crucially, its accountable people on public record, which is the foundation everything else in the occupation regime stands on: you cannot demand a safety case from a building with no named owner of the duty.
Who registers, and what goes in?
The duty belongs to the principal accountable person, the lead accountable person responsible for the building's structure and exterior. The application carries key building information: the factual profile of the building, its height and storeys, its uses, and headline information about how it is built. The profile feeds the regulator's risk picture, so accuracy matters; a building described casually at registration invites questions later, when the safety case has to reconcile with what was declared.
Where does registration bite on a new building?
At handover, in sequence. The Gateway 3 completion certificate says the building may be occupied; registration says the regulator knows who answers for it; and the law requires both before residents move in, with criminal liability for occupying without them. On a live development programme that makes registration part of the occupation gap arithmetic: the PAP needs to be identified, resourced and ready to register the moment the certificate lands, not discovering the duty in the week the tenants arrive.
The practical advice for developers is to settle the accountable person structure early, because on mixed-tenure and build-to-rent schemes the question of who ends up as PAP is a legal and commercial decision with a statutory deadline attached. And for residents, the register is worth knowing about for the simplest reason: it is public, and a building that should be on it and is not is a question worth asking.
Frequently asked questions
- Who registers a higher-risk building?
- The principal accountable person: where several organisations hold accountable person duties, the one responsible for the structure and exterior leads, and registration is among its lead duties. The application includes key building information about the building's height, use and construction.
- When must a new building be registered?
- Before anyone occupies it. On a new higher-risk building the sequence at handover is completion certificate from the BSR at Gateway 3, then registration, then occupation; occupying without either is a criminal offence.
- Is the register public?
- Yes. The BSR publishes the register of higher-risk buildings, so residents, buyers and managing agents can check whether a building is registered and who is accountable for it.
Related
This page is information, not legal advice. It is written and maintained by a practitioner, verified against primary sources on the date shown above, and corrected fast when the regime moves. Spotted something out of date? Tell us.