The Golden Thread in occupied buildings – what you should know

In her review of the building safety regime post-Grenfell, one of Dame Judith Hackitt's key recommendations was for a 'golden thread' of information for all higher risk buildings (HRBs). 

In response to that, the government introduced legislation – some covering the golden thread during the construction phase and which came into force in late 2023, and more recently covering the in-occupation phase and which came into force early 2024. These newer regulations are in the form of The Higher-Risk Buildings (Keeping and Provision of Information etc) (England) Regulations 2024 (Regulations).

These Regulations provide further details on what information the Principal Accountable Person (PAP) and Accountable Person (AP) must keep, maintain and provide to others, including residents of the building, in relation to occupied HRBs. 

What to store in your golden thread 

The golden thread is both the information that allows you to understand a building and the steps needed to keep both the building and people safe, now and in the future.

Broadly, an AP is the person or persons who owns any common parts of an HRB or has a repairing responsibility for any of these parts of that building (and the AP can be an organisation, rather than an individual). If the HRB only has one AP, they are the PAP. If it has more than one AP, the AP who owns or is responsible for repairing the structure and exterior of the building will be the PAP. Sometimes it is not entirely clear-cut who the AP and PAP are, so careful analysis is required.

The Regulations set out what should be stored and managed as part of the golden thread for the occupied HRB. This includes:

• The most up to date "registration information" for the HRB plus its key building information
• A list identifying each fire safety management measure, and a record of where each of those measures is located
• Evacuation strategies and evacuation information 
• A list identifying each structural safety measure in the building
• Details of certain maintenance and repairs planned and reports of inspections undertaken in relation to building safety risks
• The most up to date documents for managing the risk of fire spread in any part of the HRB 
• Any information recorded as part of the planning, design or construction of the HRB relating to the approach taken in designing it such as standards and design codes applied 
• Mandatory reporting information provided to the Building Safety Regulator (BSR) and a summary of steps taken
• Building assessment certificates and application information
• Resident engagement information (more on this below) 
• Complaints including steps taken and BSR involvement 
• Completion certificates and application information, including for partial completion
• Safety case report 
• Records of certain maintenance and repairs 
• Plans of the current construction of the building and its original construction, and 
• Contravention notices.

The above is not an exhaustive list – and you can find more information here. 

If there is more than one AP for a HRB, each AP must keep the above information for the part of the building that they are responsible for. They should also share any information they have with other APs in the building if that other AP is required to keep that information too. 

Further information from the HSE on how APs must store the golden thread can be found here.

Residents' voice 

As mentioned above, the Regulations also provide that the AP must proactively provide information to residents and owners of residential units. 

Dame Judith Hackitt had found that residents were previously frustrated due to the lack of information available to them about the management of the safety of their buildings. 

Furthermore, in response to a government consultation, 75% of respondents agreed that APs should provide information to residents about measures to reduce the risk of fire and ensure structural integrity of the building, contact information for those responsible for building safety matters, and information on residents' rights.

The Regulations have addressed this so that APs must provide information to the residents of the building aged 16 or over and all owners of the residential units. 

The relevant information includes:

• A summary of the most up to date fire risk assessment for each part of the HRB, including an evaluation of the level of risk to residents 
• A summary of the safety case report 
• Information on ways residents and owners can actively prevent a building safety risk occurring in their unit and reduce its severity, and how to report building safety risks
• Information about the location of fire escape routes, fire and smoke control equipment and how to use it, and the evacuation information for the building
• Information about the roles and duties of relevant persons and their contact details, including for the PAP, AP, and BSR
• The most up to date version of the residents' engagement strategy
• Details of the information and documents the AP must provide to residents and owners, and the information residents and owners can request, and
• A complaints procedure.

Again, this is not an exhaustive list and you can find further information here.

Residents and owners of the building are also able to make requests to APs to provide prescribed information and the APs must provide this information as soon as reasonably practicable. 

Duties on APs to share information with others 

The Regulations also set out which information or copies of documents from the golden thread of information an AP must share with various persons who have an interest in the HRB. 

This includes:

• As mentioned above, if there is more than one AP, each AP must provide the relevant golden thread information to every other AP that must keep that information also 
• If works are carried out to an occupied HRB, the AP must provide the client for the project with information about fire safety management, structural risks, management of building safety risks, and building design
• APs must provide their details to the BSR 
• If the AP issues a contravention notice on a resident who does not own the residential unit, the AP provides a copy to the relevant landlord, and
• The fire and rescue authority for the area in which the building is situated must also be provided with information. 

Are there any exceptions to providing information?

Yes, there are some exceptions to the duty to provide information or documents, for example where the disclosure would involve security sensitive or commercially sensitive material or personal data. 

However, whether or not these exceptions apply will depend on the information in question.

What next?

These Regulations, taken together with regulation 31 of the Building (Higher Risk Buildings Procedures) (England) Regulations 2023, which covers the golden thread during the construction phase, now complete the regulatory framework governing the provision of golden thread information for HRBs. The government has recently published government guidance here.

The industry now has the full outline of its obligations in this area, and should start gathering the necessary information accordingly, if it hasn't done so already.

For more information see our Building Safety Hub or contact us.