
The significance of collaboration in the purpose-built living sector since the introduction of the Building Safety Act 2022 has never been greater. BTR, PBSA and co-living developments, by virtue of their locations and the nature of their business model, make up a significant proportion of all tall buildings and consequently fall into High-Risk Building [HRB] designation. The impacts are far-reaching, creating a new framework of dutyholders, affecting processes and outputs, and creating new mechanisms for compliance.
The biggest concerns we see and hear at DLG are around the enhanced cost and programme implications arising from the Act, and how to future-proof development against legislative change and investor priorities.
Architectural Expertise
The Act aims to radically realign the way we design and deliver buildings, with a far earlier focus on safety and compliance. Our Design / Detail / Deliver approach avoids the traditional split between planning and technical delivery approaches.
At DLG Architects we have over 2000 homes in the pipeline – at planning or on site – many of which would fall under the HRB designation. We have invested heavily in training and building our Principal Designer suite of documents, trackers and processes for both CDM and Building Regulations.
Every element of our service is subject to a Quality Management agenda that is rooted in technical expertise. Our specialist technical delivery team – who have delivered multiple BTR developments on site – play a pivotal role in peer-review from the early stages, with robust auditing procedures before key milestones such as the Stage 2 report, Gateway 1 and planning. This approach ensures that costly, material design changes are avoided at the later stages, and that technical design is a more efficient process.
Safety from the Outset
We believe the design and client teams should work collaboratively from the point of instruction to discuss and understand issues of building safety. Kick-off meetings must identify the context of the proposed development and what the implications may be. Early appointment of the Fire Engineer is essential, as is making all parties aware of their duties – including the Principal Designer roles.
Does the Client want to maximise unit numbers, or keep a development below 18m (or 7 storeys) to avoid tipping in to HRB status? Our approach is to test each scenario at Stage 1, to allow clients to review the commercial risk / benefit – more units vs the potential implications to programme and cost – and for an agreed strategy to form an integral part of the brief.
Testing scenarios at the earliest stage will allow the client to review the commercial risks or benefits – more units vs the potential implications to programme and cost – and for an agreed strategy to form an integral part of the brief.

Keeping things efficient
Good BTR, PBSA and Co-Living is typified by highly-efficient plans which make generous amenity provision viable. The Act mandates that, from September 2026, second staircases must be included in all HRBs – at additional cost, and a hit to net-to-gross.
Despite the impacts, a second staircase is a critical part of ensuring resident safety – paramount to their sense of inclusion and happiness, reaching stabilisation and maintaining optimum occupancy levels. Moreover, developments without second stairs may not be so attractive to investors, or be more challenging to insure. Good design should avoid such outcomes.
Second staircases can be efficiently and intelligently designed to mitigate impacts and meet the requirements of the Act and the new Approved Document B; a rounded approach should consider how a building form and arrangement can provide two staircases efficiently at the point of the initial massing study, so any development appraisal is rooted in reality.
Despite the impacts, a second staircase is a critical part of ensuring resident safety – paramount to their sense of inclusion and happiness, reaching stabilisation and maintaining optimum occupancy levels.
Information Workflow
The Act introduces a 3-stage gateway regime for submission of evidence to the newly-created Regulator, without whose approvalthe project cannot progress. Crucially this changes the nature and detail of the information developed pre-construction, requiring exhaustive information to be provided before construction.
By considering the technical design of a building long before Stage 4, this can significant benefits to later design stages. Technical review at Stage 1 will establish a design safety framework; reviews at Stages 2 and 3 will identify issues and opportunities before consents are sought. Working extensively in the Living sector and alongside some of the UK’s leading contractors, we understand how to build. We have a library of approved materials and systems, and established golden-thread processes. All of these approaches will economise the Technical Design process toward Gateway 2 submission.
We also offer strategic advice on procurement strategies; Design & Build is now more like Design then Build. Early contractor engagement with the design team can ensure that what is designed for Regulator approval is contractually acceptable and avoids returning to Gateway 2 to seek change approval. 2-stage tender processes, and considering phasing of planning consents and delivery, could support the programme and respond proactively to the changes the Act introduces to the industry’s long-established tendering and procurement traditions.
Completed Projects
With a team of in-house technical experts, DLG Architects have now completed numerous projects as both the Building Regulations and CDM Principal Designer. Generally, this is achieved using the practice bespoke documentation, led through the coordination of health, safety, and building regulations compliance from project inception.
Throughout the design phases, we meticulously review for potential hazards with the design team, manage risks and ensure effective communication across design teams, with paramount on compliance with building regulations. Our proactive approach demonstrates our commitment to safety and regulatory adherence.

Summary
The BSA brings change to an industry that needed it. The living sector has responded decisively and collectively, but there are still unknowns to contend with as the Regulator becomes established and works through the first tranche of Gateway 2 submissions. Some challenges – such as the Gateway 3 sign-off and the potential for delay – are particularly challenging to the PBSA sector, for example, being tied to fixed term dates.
However – embedding technical expertise from the outset, and applying rigour to the design process, efficiencies can be introduced – and more timely compliance milestones achieved.