Understanding BS 9991:2024 and the Building Safety Regulator’s Position
The Building Safety Regulator (BSR) has issued clear guidance on the adoption of BS 9991:2024 in applications for Building Control Approval, as detailed in a recent letter from Philip White, Chief Inspector of Buildings at the HSE. This is further supported by an advisory note from the Construction Leadership Council (CLC).
Here’s what developers, designers, and contractors need to know:
Key Transitional Dates for BS 9991 Adoption
- From 17 March 2025:
Planning applications submitted after this date should adopt BS 9991:2024.
- Gateway Two Applications (Current Designs using BS 9991:2015):
If your project has been progressing under the previous BS 9991:2015 standard, you must clearly explain:- How the building work remains compliant with current Building Regulations.
- Why the original design approach remains appropriate despite updated standards.
- From 30 September 2026:
All Gateway Two applications must apply BS 9991:2024.
At FDS Consult UK, we are already supporting developers and design teams through these transitions with our expert Planning Gateway 2 consultancy services. Learn more here.
Expectations from the Building Safety Regulator
The BSR expects all applications — particularly those involving Higher Risk Buildings (HRBs) — to provide:
- Clear justification for the standards and approaches used.
- Demonstrable compliance with Building Regulations.
- Evidence that the safety level is at least equivalent to that required by Approved Document B, considering transitional arrangements.
The BSR has confirmed it will take a pragmatic approach when assessing applications, especially where a project has evolved alongside changing standards. However, applicants must be prepared to robustly defend their designs with appropriate evidence and rationale.
Other Building Control Bodies
It’s important to note that building control providers for non-HRB buildings are not legally bound to follow the BSR’s processes. They may implement independent policies and procedures when assessing compliance.
FDS Consult UK: Your Partner for BS 9991 Compliance
Our team of fire engineering experts is already guiding clients through the implications of BS 9991:2024, ensuring designs are not only compliant but also future-proofed against regulatory change.
For more detailed insights, you can also read our article: Introducing BS 9991:2024
Whether you’re preparing for Planning Gateway Two, refining your fire strategy, or responding to the latest regulatory changes, FDS Consult UK can help you navigate the evolving landscape with confidence.
