Gateway 2 Approvals Are Speeding Up — But Is Your Submission Ready?

The Building Safety Regulator has introduced a new outsourced batching model for Gateway 2 applications, and the early results are notable. Median decision times have fallen to four weeks across all application categories — a substantial improvement on previous performance. The legacy backlog has been reduced to just two cases, and 13 complex applications are being handled through a dedicated specialist process.

These are genuine improvements and the industry should acknowledge them as such. But there is a risk that faster processing times are read as a signal that Gateway 2 has become easier. It has not. If anything, the opposite is true: a more efficient system will reject inadequate submissions more quickly, not approve them more leniently.

Understanding what the batching model actually involves — and what it demands of applicants — is essential for any team preparing a Gateway 2 submission in 2026.

What the Batching Model Involves

The BSR's approach, piloted from September 2025, involves grouping Gateway 2 applications and assigning them to external engineering suppliers for assessment. The first batch of 26 cases was sent to external suppliers on 30 September 2025. The BSR retains oversight of the process; external suppliers work under its direction rather than independently.

The model is a pragmatic response to a well-documented resourcing constraint: the BSR has faced significant pressure to reduce decision times while managing a growing volume of applications. Outsourcing grouped applications to specialist engineering suppliers allows the regulator to process more cases in parallel without compromising technical rigour.

The BSR's acting CEO has been explicit that speed cannot come at the cost of safety. That principle shapes the batching model. External suppliers are not a relaxed alternative to internal BSR assessment — they apply the same technical standards and will raise the same requisitions for the same deficiencies.

The current approval rate of 67% indicates that a third of applications are not passing first time. In a faster system, that means a third of applicants are experiencing requisitions — and associated delays — more quickly than before.

The Approval Rate Is the Number That Matters

Median processing time of four weeks is genuinely encouraging. But for the 33% of applicants whose submissions draw requisitions, the four-week figure is almost irrelevant. A requisition pauses the clock. The application enters a back-and-forth cycle that can add weeks or months to the overall timescale.

London accounts for 60% of Gateway 2 decisions, reflecting the concentration of higher-risk building development in the capital. For London-based projects — typically the most complex, with constrained sites, phased programmes and demanding fire engineering — the pressure to submit a clean, complete package is particularly acute.

The BSR is not going to approve a submission it is not satisfied with, regardless of how quickly it is processing applications. Speed of processing is a variable the regulator controls. Quality of submission is the only variable the applicant controls.

What a Clean First Submission Looks Like

The BSR's Gateway 2 requirements are well established under the Building (Higher-Risk Buildings Procedures) (England) Regulations 2023. The most common reasons for requisitions have not changed because the batching model has been introduced. What the faster system does is surface those deficiencies more quickly.

A clean first submission typically has the following characteristics:

• Compliance statements written to the specific building. Each statement addresses the requirements of the relevant Approved Document by reference to the actual design — drawings, specifications and calculations. Generic or template-based statements are among the most common triggers for requisitions.
• Internal consistency across the document set. The fire strategy matches the architectural drawings. The structural strategy reflects the current specification. The duty holder competence documents reference the same individuals named in the appointment schedule. Version dates are aligned across all documents.
• Duty holder competence evidence that meets the BSR's standard. The BSR expects competence evidence to reference established frameworks — BSI Flex 8670 for individuals, PAS 8672 for organisations. A professional membership certificate is not sufficient on its own. Evidence must demonstrate HRB-specific experience and capability.
• A drawing package that supports the compliance case. Drawings at appropriate scale, with compartmentation shown on floor plans, key construction details included, and MEP schematics present where required by the compliance statements.
• A project-specific Construction Control Plan and MOR Plan. Neither document should read as a generic template. Both should name responsible individuals, identify project-specific triggers, and demonstrate that the applicant understands what the obligations require in the context of their project.

Pre-Submission Review: The Most Effective Risk Mitigation

The most consistent indicator of a successful first submission is an independent pre-submission review. This means commissioning a review of the draft submission package — checking completeness, internal consistency and quality of evidence — before the package is submitted to the BSR or its external suppliers.

The logic is straightforward: an issue identified before submission can be addressed at no cost to the programme. The same issue identified by the BSR as a requisition costs time, credibility and, in many cases, money. In a batching model that processes applications quickly, the interval between submission and requisition is shorter — which means the interval available for correction is also shorter.

Teams that start compliance work at RIBA Stage 1 and maintain it through to Stage 4 are consistently better placed than teams that treat the submission as a Stage 4 document-assembly exercise. Compliance is not a submission activity — it is a design activity. The submission is the evidence of work that should already have been done.

What This Means For Your Project

If your Gateway 2 submission is in preparation, the improved processing times at the BSR change one thing: the window between submission and a decision — or a requisition — is shorter. That means any weaknesses in the submission package will be identified more quickly. It does not mean they will be overlooked.

The practical implications are:

• Do not submit ahead of design readiness. A submission at Stage 3 or early Stage 4, intended to "start the clock," will almost certainly attract requisitions. A complete Stage 4 submission is more likely to be approved in four weeks than an incomplete one is to be approved in twelve.
• Commission a pre-submission review before lodging the application. The cost is modest relative to the programme risk of a requisition cycle.
• Ensure duty holder appointments — particularly the Principal Designer (Building Regulations) — are in place early enough to contribute meaningfully to the compliance statements.
• Treat the CCP and MOR plan as substantive documents, not administrative formalities. The BSR scrutinises them as indicators of the team's understanding of its obligations during construction.

The BSR's investment in faster processing is a signal that the regulator is taking its obligations seriously. The appropriate response from the industry is to take submission quality equally seriously. A faster decision on a complete submission is a win for everyone. A faster rejection of an incomplete one helps no one.