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Insight · Health and safety

Gateway 2, and what it
does to a programme.

Approval has to be granted before construction starts, and the wait has improved sharply: a median of 22 weeks at June 2026 against 43 a year earlier. What that means if you are not the applicant.

Published ·Updated ·4 min read·Written by

Tower cranes above a building under construction

Gateway 2 is the Building Safety Regulator approval that must be granted before construction starts on a higher-risk building. Work cannot begin without it. The wait has improved sharply: a median of 22 weeks for new higher-risk buildings at June 2026, against 43 weeks a year earlier, with the rolling approval rate around 91%.

What is Gateway 2?

Under the Building Safety Act regime, higher-risk buildings pass through three gateways. Gateway 2 is the one that bites commercially: an application for building control approval made to the Building Safety Regulator, which must be granted before the construction phase can begin.

It is not a notification and it is not a formality. It is a permission, the Regulator can and does reject applications that do not contain enough information, and no amount of commercial pressure moves it. For anybody in the supply chain, the practical consequence is that a start date is not a start date until Gateway 2 is through.

What the wait actually is, as at June 2026

Figures below are from Building Safety Regulator published data and were checked on 20 August 2026. They are moving quickly, so check the current position rather than relying on these.

  • Median approval time for new higher-risk buildings: 22 weeks at June 2026.
  • A year earlier that median was 43 weeks, with an approval rate of around 39%.
  • The 12-week rolling approval rate has risen to roughly 91%.
  • Around 1,505 live building control applications sat with the Regulator at the end of June 2026, which is a working pipeline rather than a backlog that clears once.

The direction of travel is unambiguous and it is good news. It is also still a wait of roughly five months on a median case, which is a programme item rather than a detail.

Why you may have been told something much worse

Worth addressing directly, because a great deal of published commentary, and a fair amount of industry conversation, still describes this regime in terms of waits of 25 to 40 weeks and rejection rates around 70%.

Those figures were broadly accurate for the earlier period of the regime. They are now substantially out of date, and planning a programme or pricing a risk on them would produce the wrong answer in a way that costs money: over-allowing on a bid, or declining work on a basis that no longer holds.

Half the commentary on this subject describes a position that was true eighteen months ago. Check the current data before you price around it.

When you are not the applicant

Which, if you are a subcontractor, you almost never are. The application is made by the client or on their behalf, and the consequences land on you without your having any control over or visibility of the process.

Three specific exposures.

Your start date is not yours. Being told to hold availability for a date that depends on an approval nobody has yet received is a resourcing risk, and the cost of holding a gang for a date that moves is real and rarely compensated.

Design changes after approval are constrained. The regime restricts what can change after approval without going back, which affects how variations and value engineering work on these jobs. That is a different commercial environment from an ordinary project and it is worth understanding before pricing one.

Payment and programme knock on. A delayed start compresses everything downstream, and compression usually lands on the trades at the end of the sequence.

Planning around it

Four practical things, none of which requires you to be party to the application.

Ask, at tender, whether the building is higher-risk and whether Gateway 2 approval has been granted. A start date on an unapproved higher-risk building is provisional whatever the programme says.

Price the holding risk rather than absorbing it, or agree what happens to your costs if the date moves. Do not mobilise on a provisional date without something in writing about who carries the cost if it slips.

Keep your own records of dates you were given and dates that changed, because a compressed programme at the end is a claim about causation and causation is proved with contemporaneous records.

And check the current Regulator data rather than the anecdote, on each job. The numbers have moved twice in eighteen months and will move again.

Where this touches the platform

Gateway 2 is decided by the regulator. What Unibuild holds is the evidence that decides who carries the cost when a date moves: site diaries and daily records with dates, the programme information you were given and when, correspondence against the job rather than in an inbox, and labour planned and recorded against dates you can produce later. A subcontractor arguing that a compressed programme was not of its making is making a contemporaneous records argument, which is the same argument as every other delay claim and is set out in getting paid for variations.

Project and site Documents and certificates Comms and reporting The CDM 2015 guide

Where to start, on Monday

Take any job on your board that involves a residential building of significant height and ask the question directly: is this a higher-risk building, and has Gateway 2 been granted. If the answer is that approval is pending, your start date is an estimate.

Then decide what you will do about holding resource for it, and put that in writing before you are asked to hold anything.

Sources

Checked against the source rather than against commentary. Where a schedule, a rate or a threshold is definitive on a government site, read it there.

Asked most often

The follow-up questions.

The wider duty picture is in the CDM 2015 guide.

How long does Building Safety Act Gateway 2 approval take?
The median for new higher-risk buildings was 22 weeks at June 2026, according to Building Safety Regulator published data, down from 43 weeks a year earlier. The 12-week rolling approval rate had risen to around 91% from roughly 39% in August 2025. The figures are moving quickly, so check the current position rather than relying on any published summary.
What has to be submitted at Gateway 2?
A full application to the Building Safety Regulator demonstrating that the design complies with building regulations before construction starts. That means the design drawings and specifications, and the fire and structural strategies. The competence declarations for the duty holders. The construction control plan, the change control procedures and the mandatory occurrence reporting arrangements. It is an approval of a completed design.
Can construction start before Gateway 2 approval?
No. Gateway 2 is a permission rather than a notification, and the construction phase cannot begin on a higher-risk building until building control approval has been granted by the Building Safety Regulator. For anybody in the supply chain that means a start date is provisional until approval is through.
Why are Gateway 2 applications rejected?
Overwhelmingly for incompleteness. Missing competence declarations. A fire strategy that does not align with the drawings. Gaps in the construction control plan. Drawings at a stage of development below what the gateway requires. The regulator is assessing a complete design against the regulations, and an application submitted at the stage a traditional building control submission would have been made is not complete.
Is the Gateway 2 rejection rate still around 70%?
No, and this is the most commonly repeated out-of-date claim about the regime. Approval rates were low in the earlier period, but the 12-week rolling approval rate had risen to approximately 91% by mid-2026. Planning or pricing on the older figures produces the wrong answer, either by over-allowing on a bid or declining work on a basis that no longer holds.
What does a Gateway 2 rejection actually cost?
Mostly programme, and that is the part rarely allowed for. A rejection sends the application back to be corrected and resubmitted, with the assessment period starting again. On a higher-risk building that is months during which the site cannot start, while preliminaries, finance and professional fees continue. Price the risk of a resubmission into the programme, because the common cause is an incomplete application rather than a bad design.
Can design be changed after Gateway 2 approval?
Yes, through the change control procedure, and the category of the change determines what happens. Minor changes are recorded. Notifiable changes must be notified. Major changes require a fresh application and approval before that work can proceed. The discipline this demands on site is the real shift: an informal design change agreed at a progress meeting is no longer available as an option.
What does Gateway 2 mean for a subcontractor who is not the applicant?
Three exposures. Your start date depends on an approval you have no control over or visibility of, so holding resource for it is a real and rarely compensated risk. Design changes after approval are constrained, which changes how variations work. And a delayed start compresses the programme downstream, which usually lands on the trades at the end of the sequence.
How should I price work on a higher-risk building?
Establish at tender whether the building is higher-risk and whether Gateway 2 has been granted. Price the risk of holding resource for a provisional date, or agree in writing who carries the cost if it moves. Keep contemporaneous records of the dates you were given and when they changed, because a later compression claim turns on causation.
Next step

Hold the programme evidence either way.

A median wait of twenty-two weeks is survivable if the programme evidence is already assembled. It is not if you start assembling it when the letter arrives.

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