Staged HRB building control approvals – updated guidance

A staged G2 application can now be made for new Higher Risk Building (HRB) developments — those over seven storeys or 18 metres — where works will be delivered in stages/phases. Each stage is assessed and approved separately by the BSR, and stages can start or finish on the same or different dates. This approach applies to single tower projects and multi-tower schemes.

Crucially, BSR will now accept staged G2 applications for all new single tower HRBs classified as “non-complex” (with no more than one basement level), separating groundwork and foundations from the above-ground structure. This marks a significant improvement to the G2 process. The definition of “complex” versus “non-complex” is set out in Regulation 46A of the Building Regulations 2010. Previously, staged applications were limited to complex buildings such as multi-tower developments, buildings with multiple basement levels, or public buildings. The change means developers can seek early approval for groundwork and foundations, then apply later for the superstructure, provided BSR criteria are met. This could allow earlier site starts while later designs are finalised, rather than waiting for full development approval upfront.

For multi-tower projects, BSR now advises contacting them before submitting a staged application — a major shift from earlier guidance that ruled out pre-application advice. Developers should factor this into programmes, although it remains to be seen how quickly advice will be available. Whether or not advice is sought, no building work can begin on any stage until G2 approval for that stage is granted.

BSR’s aim is clear: streamline G2 approvals, reduce bottlenecks and accelerate HRB construction. If properly resourced, staged applications should lead to faster approvals, parallel workstreams and more effective project management, particularly for complex schemes. They would also allow design teams to focus on discrete elements while maintaining compliance across the whole project. However, programmes must account for potential delays in multiple G2 approvals, and parties will need to agree who bears the risk of any hold-ups.

For further information, the BSR Guidance to staged G2 applications can be found here: Building Safety Regulator: latest news and updates and the CLC guidance here: News – Construction Leadership Council

This article is for general information purposes only and does not constitute legal advice or a comprehensive statement of the law. Specific legal advice should always be sought in relation to individual circumstances.

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