High-Risk Buildings: The registration countdown
The deadline for registering an occupied Higher Risk Building (HRB) with the Building Safety Regulator (BSR) is fast approaching. With less than a month left to register, we highlight below some key pointers to help you with the registration process.
Although the deadline is fast approaching, there is still a month to go so all is not lost if you haven't yet registered. We've recently assisted a client with a registration so there is still time to get your registrations in – they do take time to prepare though so you'll need to move fast. We're well placed to help with this.
When is the deadline?
30 September 2023. This is a hard deadline. It is an offence if residents occupy an unregistered HRB after this deadline.
Does my building need to be registered?
If your building (a) is at least 18 metres in height or has at least 7 storeys and (b) contains at least 2 residential units, then it is a HRB and it must be registered before it can be occupied. There are certain asset classes that are excluded from the definition of HRB such as care homes and hotels.
If you are unsure about the height of your building, the government has issued guidance and rules about counting stories which can be found here: Criteria for being a higher-risk building during the occupation phase of the new higher-risk regime - GOV.UK (www.gov.uk)
Who is responsible for registration?
The "Principal Accountable Person" (PAP) will have ultimate responsibility for registering the building with the BSR. The PAP is the individual or organisation that owns or has legal obligations to repair the structure and exterior of the HRB.
How do I register?
The PAP will need register the HRB through the government website which can be found at: https://register-high-rise-building.hse.gov.uk/. There is a fee of £251 for registration.
What happens next?
Responsibilities and duties relating to HRB do not stop at registration. Within 28 days of registering, the PAP will need to submit "Key Building Information" (KBI) in an electronic form to the BSR.
KBI is specific information about the HRB. The Higher-Risk Buildings (Key Building Information etc.) (England) Regulations 2023 and the government guidance Building Safety Regulator: giving us structure and safety information (key building information) - GOV.UK (www.gov.uk) set out what information should be provided. As a brief summary, it includes details of fire safety prevention and protective measures, structural data, and maintenance and inspection information.
There is a continuing obligation on the PAP to update the KBI from time to time and as necessary.
Key take aways
- Identify all buildings within your portfolio that fall into the HRB category.
- The PAP must register all existing occupied HRB before 30 September 2023.
- Within 28 days after registration the PAP must submit all Key Building Information.
- The PAP must provide updated KBI to the BSI from time to time.
If you need further information on registering HRB or Building Safety Act matters please get in touch.