CLC Gateway 2 Guidance
In July 2025, the Construction Leadership Council (CLC) published a suite of Guidance Notes (01 to 07) for Gateway 2 applications on Higher Risk Buildings (HRBs) under the Building Safety Act (BSA). The Notes provide valuable guidance on some aspects of the BSA which façade engineers have been calling out for. Members of SFE are strongly encouraged to download and read the notes themselves, but we have provided a summary and thoughts on the key aspects of the Notes in this article. The full Guidance Note can be found at the CLC website.
What does the guidance include?
- The guidance introduces the “Approval with Requirements” process, allowing for staged submissions of information after the initial Gateway 2. This is discussed in more depth below.
- The guidance helps to streamline and clarify the documentation process for Building Control approval, introducing structured templates such as the Application Information Schedule, guidance on preparing a Project Brief, and an Application Strategy.
- The guidance encourages more systematic and traceable approaches to demonstrating compliance with Building Regulations, helping to discourage fragmented and ad-hoc information.
Building Control Approval with Requirements route
A key piece of the guidance is clarity on a method of Building Control Approval at Gateway 2 (GW2) called ‘Approval with Requirements’, outlined in Guidance Note 03. This is a function that can allow the approval of a GW2 application, but with conditions applied to certain aspects of design, allowing the project team to complete them after GW2.
The first possible use of this route would be by the Building Safety Regulator (BSR). If they deem that the GW2 application demonstrates regulation compliance, but they wish to see further information before construction commences, they can grant ‘approval with requirements’, and outline what information they require and by when to grant full approval. This could be viewed in a similar way to a conditional planning approval, with broad approval to proceed granted, but conditions applied for which evidence must be submitted before that aspect of the works can proceed.
The second possible use of this route would be proposed by the project team submitting the application. The guidance implies that it would be possible for a team to propose aspects of design which will be completed later, with initial approval granted on the overall principles of design and compliance approach. The CLC note that within the initial application the proposal must demonstrate that the building design can and will comply with the functional requirements of the Building Regulations, and that the team must demonstrate how and when the final design will be completed. This route is therefore not intended to give the project team more time to determine how compliance will be met or to abdicate the responsibility to Building Control.
It is important to note that under both routes, the conditioned design approved ‘with requirements’ must be completed and submitted to the BSR for approval before construction can commence, through separate information applications against a timeline submitted in the application. When seeking Approval with Requirements it is the applicant’s responsibility to prepare and submit with the main application a clear and comprehensive Approval with Requirements Plan to the BSR for agreement. The approved plan and agreed dates for submission of the information must be adhered to, and construction work is not allowed to commence on any specific element unless a full design is submitted and approved for that element by the Building Safety Regulator.
Specific façade examples are not provided in the CLC guidance, but the SFE BSA committee have has considered some examples. Members must treat these as untested guides only and make their own judgement for their own projects.
The approval with requirements route is highly unlikely to be accepted for the entire façade or for an entire system, and we expect that it is intended to be used for individual materials or components. Take first the example of a material – say an insulation product included in a façade rainscreen system – being proposed to be ‘approved with requirements’. Insulation is a key façade material, and it is not uncommon for the supply chain to want flexibility in which product manufacturer they use during the project to allow for fluctuating availability and commercial factors. It is therefore difficult to limit ourselves down to one product at GW2, and an approval allowing some flexibility in supply chain would be highly beneficial to a project. The guidance allows flexibility in manufacturer selection, provided the design shows that multiple tested products could meet the performance criteria within the dimensional constraints of the submitted plans.
It is highly unlikely that approval would be given if the application simply said that an insulation will be used that complies with Building Regulations, with no additional information provided, and a lack of clarity on the material or performance. Such a proposal is likely to be viewed as too vague, and not sufficiently showing that the design team understand the route to compliance. However, we can imagine that approval may be more favourably given if the application included:
- A description of the context of the element and its function
- A definition of the proposed material to be used
- A clear breakdown of the performance requirements of the material, and how they have been derived from the Regulations and Guidance documents, and a clear statement of how, if these requirements are met that Building Regulations will be achieved.
- Examples of products that will provide this material and the performance characteristics required – e.g. three suppliers of the same material family, with their data sheets showing compliance with the requirements, and a covering statement explaining this and that substitution between these products will not compromise Regulation compliance.
A description of the next steps after initial approval – including who will be responsible for making the final selection, what information will be submitted to Building Control for approval, and by when, and how the compliance of other works that may proceed before this date will not be dependent on this product being selected.
Another important example may be around testing. Where a full scalefull-scale performance test – such as CWCT Sequence B testing – is needed to demonstrate that performance requirements are met, a common concern across the industry has been the programme impact of having to complete this before GW2. The new ‘approval with requirements’ route may allow testing to occur after GW2 in parallel with other non-façade works, based on conditional approval that the test will be performed and achieve certain specified values outlined in the application and within the dimensional constraints of the submitted drawings.
Whilst we welcome this route, we would advise members to treat it with caution – our initial thoughts of things to be alert to are:
- As the CLC notes, works on site for any elements ‘approved with requirements’ can only proceed legally once final approval is given. This will require a series of additional submissions to the BSR post GW2, and it remains to be seen how long these approvals would take. Sufficient programme time should be allowed for this uncertainty. The information must also be provided, and if this relies on testing we should have confidence that the test will pass, and consider the risks of this not occurring. On large complex projects the number of additional submittals could be substantial, adding a lot of risk of any one of those submittals failing and impacting the project – achieving as much detail and design fixity before Gateway 2 will therefore still remain the best way of ensuring a smooth construction period.
- There is no guarantee this process will always be approved, and it will be up to the design team to sufficiently justify why it is appropriate. Consider what is reasonably appropriate – for example critical fire safety elements that are manufacturer specific assemblies that depend on specific test data for the project context may be less justifiable for this route than the example included above of insulation, where substitution of products within one material type will be simpler.
- The regulator may reject the proposals, which is likely to result in rejection of the complete Gateway 2 and resubmittal. We should therefore be confident that our proposals for ‘approval with requirements’ are reasonable and justifiable, and to explain this in our applications.
- This is not a route that allows significant change in design after GW2. The design must still be fixed and the compliant route confirmed, so significant changes to the façade design which may impact other aspects of the building will still fall under the typical change route in the Act, with the potential implications being works halting on site and resubmission of Gateway 2.
- This may not fully remove the need to bring on board contractors earlier to provide design before Gateway 2, a common impact we have seen of the Act. We should still involve contractors early in the design process where we feel the design cannot be completed by the design team, to minimise risk of major change later.
The examples above are not based on direct experience, and therefore the SFE are is not responsible for any risks taken by members of adopting them. We would welcome feedback and thoughts from members going through this process in their projects. - This begins to answer a common question across the façade industry which is what level of completeness of design is required to be completed by GW2, in particular around product selection. Over the coming months the SFE BSA Committee will be developing guidance examples, and we would welcome feedback from members of their own ideas or experiences successful or not of applications using this route.
Construction Control Plan – planning, managing, monitoring
The Construction Control Plan (CCP) is a critical component of the Gateway 2 submission and plays a central role in ensuring that any deferred design elements—such as those submitted under “Approval with Requirements”—are properly managed during the construction phase. The BSR may grant Approval with Requirements if they are satisfied with the plan (CLC, Note 3, 2.2), The CCP must clearly show how these elements will be controlled and integrated into the build safely and legally.
The principal contractor assumes a central role as coordinator, charged with overseeing all parties participating in the cladding design and installation. This responsibility requires strict alignment with the Application Information Schedule, and assurance that all subcontractors submit documentation and performance data that satisfy regulatory requirements. Furthermore, the contractor must maintain a systematic record of all design changes, ensuring these updates are submitted for BSR approval in accordance with regulatory mandates.
The contractor is expected to conduct regular inspections to confirm that installation aligns with approved designs and all relevant statutory standards. In line with CLC Guidance Note 03, records of all approvals, submissions, and communications with the BSR must be meticulously maintained. The Construction Control Plan must be promptly updated as new approvals are received, ensuring continuous regulatory compliance.
Design maturity and submission content guidance
Guidance Notes 02 and 04 provide information on the content of the GW2 submission itself. Note 6 provides guidance on how to structure the information provided, including for example folders and sub folders’ structure and filing name conventions that shall be used. This reiterates common themes of the Act, requiring project teams to submit clear, coordinated and concise information to demonstrate how the building design meets Building Regulations, discouraging fragmented or “file dump” submissions that will contribute to unclear information and delayed review periods.
An important addition to this guidance is the example of an Application Information Schedule (AIS). The CLC is recommending that the AIS is submitted with each GW2 application, with its function being to signpost which evidence relates to each Regulation, who holds responsibility for it, and to describe completeness of design and if any ‘approvals with requirements’ are proposed. This seems similar to the approach many Building Regulations Principal Designers (BR-PD) are using for the Relevant Requirements Tracker, to provide clearer cross-referencing of information included in the Regulation Compliance Statement.
Annex 4A of the CLC note provides a useful example of the Application Information Schedule (AIS), and importantly examples of façade design to be included in the Gateway application. The notes accompanying this guide by the CLC stress that it should not be treated as a prescriptive guide and that project teams must consider the appropriate level of information for their projects, but it provides useful insight for façade engineers. Annex 6A describes the structure of the application, detailing its organisation into folders, sub-folders and files. This structure is designed to assist the Building Safety Regulator and Multi-Disciplinary review team in navigating and finding the submitted information efficiently. Annex 6A does not serve as a drawing register, but functions as a navigation too siting above a conventional drawing register.
The AIS guide is broken down – similarly to the relevant requirements tracker – by regulation, and for each provides examples of what information should be provided for key packages. Importantly it splits the information by what will be provided in the initial application, and what information may be submitted under a ‘approval with requirements’ route later. The examples provide some key insight into what the CLC and the BSR deem acceptable to fall under the ‘approval with requirements’ route:
- Under Part B – Fire - the guidance shows that it would be acceptable in the first submission to provide window and external door specifications and typical details from the consultant team, and typical contractors drawings, with full contractors’ details being provided later as a conditioned submission after GW2. For external fire resistant doors and fire resistant cladding, these may be required depending on specific design requirements.
- However, considering fire cavity barriers and fire stopping the guide implies that full details and test information must be provided by the contractors in the initial submission.
- These examples appear to show the approach that the Regulator will be considering in their review, with less flexibility allowed in elements that provide a critical role in fire safety, and which require testing based on specific contexts.
SFE members should download and read Annex 4A and consider its guidance in preparation of GW2. The SFE would also reiterate that this must be treated as guidance and is not a guarantee of GW2 approval, so we should consider how it applies to our projects and what further information may need to be provided to demonstrate Compliance.
Other guidance
The CLC guidance notes also provide guidance on writing a covering description of the project – the Application Project Brief – in guidance note 05 and managing information through the submission in guidance note 06.
Upcoming BSA Roundtable discussions
The SFE BSA committee intends to host a series of roundtable discussions for members to discuss key topics of the BSA. We hope these will facilitate valuable discussion and networking as well as informing guidance we provide on key topics to wider members of the SFE and industry, allowing us to hear the range of thoughts and approaches within our members to ensure guidance is as inclusive as possible.
Our initial ideas for topics, to be shaped as we gather possible participants are:
- Gateway 2 and design maturity – what makes up a successful GW2 for the façade, and what is reasonable to be ‘approved with requirements’.
- Gateway 3 and change control – what façade information should Gateway 3 include, and how is this managed?
- How is the BSA changing the role of façade engineers – how should we evolve to meet its requirements, how can we collaborate better across industry to improve safety of facades.
The first roundtables will be held without an audience, and we would like to form groups composed of a range of contributors reflecting the breadth of professionals involved in the design of HRBs – façade engineers and façade contractors but also architects, fire engineers, main contractors, BR-PDs, material/system suppliers, Building Control professionals, etc.
If you would like to be involved in one of these roundtable discussions please contact the SFE via [email protected] with a description of your role and experience of the BSA, and topics you’d like to input on.
House of Lords Inquiry
The SFE and CWCT would like to thank our members who provided their feedback on the questions raised in the House of Lords request for comment on the implementation of the Building Safety Act. We have taken the responses and formed a combined response reflecting the breadth of views of those who replied. These have been submitted to the Inquiry, and we will publish our response to SFE and CWCT members in the next issue of this newsletter.