Building Safety Act: Accountable Person Duties 2026

Last updated: 8 November 2026

An Accountable Person under the Building Safety Act 2022 is the organisation or individual legally responsible for managing building safety risks in a higher-risk building, and there are an estimated 12,500 higher-risk buildings in England that must be registered with the Building Safety Regulator, carrying duties that range from fire and structural safety management to resident engagement and mandatory registration.

Key Takeaways

• Priority First notes that the Building Safety Act 2022 created the Accountable Person role to close the accountability gaps exposed after the Grenfell Tower fire.
• An estimated 12,500 higher-risk buildings in England fall within scope of the regulator's register, according to the CIH.
• As of 15 September 2023, only 48% of high-rise residential buildings (5,991 of an estimated 12,500) had been fully registered ahead of the 1 October deadline, per Project Safety Journal.
• More than 3,563 occupied higher-risk buildings were registered only after the statutory 1 October 2023 deadline had already passed, according to Construction News.
• Priority First advises that the Principal Accountable Person holds overarching legal responsibility where a building has more than one Accountable Person, with specific duties set out in Part 4 of the Act.

What is an Accountable Person under the Building Safety Act 2022?

An Accountable Person is the entity that owns a legal estate in a higher-risk building, or holds a relevant repairing obligation under a lease, and is therefore responsible by law for managing that building's structural and fire safety risks. The Building Safety Act 2022, passed by Parliament after the Grenfell Tower fire of June 2017, created this status directly through legislation rather than through appointment or agreement.

Legal commentary from Falcon Chambers makes the point precisely: "The status of accountable person is not granted by a determination of a tribunal or by an agreement between owners or occupiers of the building; it applies by virtue of the 2022 Act." Freeholders, resident management companies, right-to-manage companies and commercial landlords can all find themselves an Accountable Person depending on their legal interest in the building.

Part 4 of the Act sits alongside the wider regulatory architecture overseen by the Health and Safety Executive, which hosts the Building Safety Regulator. For a facilities management provider like Priority First, understanding exactly where this status falls in a complex ownership structure — freeholder, head lessee, management company — is often the first compliance question a client asks.

Which buildings fall within scope of the higher-risk regime?

Higher-risk buildings under the Act are residential buildings in England that are at least 18 metres tall or have at least seven storeys, and contain at least two residential units. Hospitals and care homes meeting the same height threshold are also caught during their design and construction phase, though occupied hospitals and care homes are currently outside the in-occupation duties.

The scale of this regime is substantial. The government estimated the total number of higher-risk buildings in England at 12,500 as of April 2020, according to Construction News, and that figure has defined the Building Safety Regulator's registration programme ever since. New construction continues to add to this total each year.

The government estimates that, on average, 490 new buildings meeting the higher-risk building definition will be constructed each year, per Gateley plc. Any new higher-risk building must pass through the "Gateway" regime — a series of hard stops at planning, pre-construction and completion — before occupation is permitted, administered by the Building Safety Regulator under the Health and Safety Executive.

How do you determine who the Accountable Person is for a specific building?

Determining the Accountable Person starts with identifying who holds a legal estate in the common parts of the building, typically the freeholder, or who owes a repairing obligation under a lease covering those common parts. Where several parties hold qualifying interests — a common scenario in mixed-use developments with separate commercial and residential freeholds — the Act can create multiple Accountable Persons for a single building.

This is one of the most commercially significant practical difficulties facing building owners. A management company may hold the repairing obligation on paper, while the true decision-maker over fire doors or cladding sits with a superior landlord several steps up the legal chain.

Priority First's experience managing prime central London residential portfolios reflects exactly this complexity. On a 16-building prime estate spanning mansion blocks, retail-residential parades and a private courtyard, a nightly manned patrol round produces 250–280 photo-backed patrols per building, each building set up as its own site with its own checkpoints so ownership and accountability questions never obscure who is responsible for what, night to night.

What is the difference between a Principal Accountable Person and an Accountable Person?

A Principal Accountable Person is the single Accountable Person responsible for the structure and exterior of the whole building, and for coordinating all other Accountable Persons where a building has more than one. Every higher-risk building with multiple Accountable Persons must have exactly one Principal Accountable Person identified, usually the party controlling the building's structure, external walls and common parts.

The Principal Accountable Person carries extra statutory duties the Act does not place on other Accountable Persons, including preparing and maintaining the building's overall Safety Case Report and holding primary responsibility for registering the building with the regulator. Where there is only one Accountable Person for a building, that party automatically takes on the Principal Accountable Person role too.

What are the main legal duties of an Accountable Person under the Act?

Accountable Persons must assess and manage building safety risks, keep the "golden thread" of building information up to date, register with the Building Safety Regulator, and engage meaningfully with residents. The golden thread refers to the accurate, accessible digital record of information about a building's design, construction and ongoing management that must follow the building through its entire lifecycle.

The Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2024 set out precisely what information must be kept and for how long, implementing Part 4 of the Act. Core duties include:

• Conducting and documenting a building-wide fire and structural safety risk assessment.
• Taking all reasonable steps to prevent a building safety risk materialising or to reduce its severity.
• Preparing and submitting a Safety Case Report to the Building Safety Regulator.
• Registering the building and applying for a Building Assessment Certificate when required.
• Establishing a resident engagement strategy and a complaints procedure.
• Cooperating with every other Accountable Person for the same building.

These duties interact closely with existing fire safety obligations under the Regulatory Reform (Fire Safety) Order 2005, and the fire safety duties for building owners and managers guide sets out how these two regimes sit alongside one another for building owners managing day-to-day compliance.

"The most common mistake is treating installation as the finish line. Unwatched cameras are evidence for after the event, nothing more. The questions that matter are who is watching, what happens in the first minutes after something is seen, and whether the person responding has the authority and training to act." — Mo Hassan, Managing Director, Priority First

That principle applies well beyond CCTV. An Accountable Person who commissions a risk assessment but never acts on its findings, or who installs fire doors without a maintenance regime behind them, has satisfied the paperwork but not the legal duty. Priority First's work in this space — from CCTV monitoring to manned patrols — is built around that same distinction between having a system and proving it is actively managed.

What are the registration requirements with the Building Safety Regulator, and what are the deadlines?

Registration with the Building Safety Regulator is a statutory requirement for every occupied higher-risk building in England, and it was not met smoothly when the deadline first arrived. The registration window opened in April 2023, with a statutory deadline of 1 October 2023 for all existing occupied higher-risk buildings.

The early uptake was slow. Around 750 applications (6% of buildings in scope) had been started a month after the process opened, according to e-architect, citing Building Safety Regulator data. By mid-September 2023, still only 48% of high-rise residential buildings (5,991 of an estimated 12,500) had been fully registered, per Project Safety Journal, and an estimated 2,400 buildings were still unregistered just over a week before the deadline, according to Building.co.uk.

The aftermath is instructive for any Accountable Person assuming a missed deadline carries no consequence. More than 3,563 occupied higher-risk buildings were registered after the 1 October 2023 statutory deadline had already passed, according to a Freedom of Information response reported by Construction News. Registrations also took longer than expected to process — an average of 43 days per registration, which the regulator said was inflated by legacy cases, per the same Construction News report.

A Building Safety Regulator spokesperson has described the register's purpose directly: it "maintains a comprehensive register of high-rise residential buildings in England, which includes information about each building's principal accountable person, height, number of floors, construction date, and other pertinent details." Any newly completed higher-risk building must register before occupation, and the regulator expects an application for a Building Assessment Certificate once a building's Safety Case Report is in place.

What ongoing resident engagement and complaints-handling duties apply?

Resident engagement is a continuous statutory duty, not a one-off consultation, requiring Accountable Persons to share safety information with residents and provide a clear route for raising safety concerns. The Act requires a documented resident engagement strategy covering how residents will be consulted on building safety decisions, how information will be shared, and how a resident can escalate an unresolved safety complaint.

This duty sits awkwardly for many landlords who have historically treated building management and safety communication as separate functions. Priority First's approach to concierge and front-of-house management is designed around exactly this gap — a staffed presence at the building that residents can approach directly, rather than a safety strategy that exists only on paper.

The testimonial from one London residential client captures what good resident-facing engagement looks like in practice:

What are the penalties for failing to comply with Accountable Person duties?

Non-compliance with Accountable Person duties under the Building Safety Act 2022 can lead to criminal prosecution, unlimited fines, and the regulator appointing a Special Measures Manager to take over the building's management. The Building Safety Regulator, operating under the Health and Safety Executive, has wide enforcement powers including compliance notices, stop notices for new construction, and prosecution in the criminal courts.

A Building Safety Regulator spokesperson has been clear about the regulator's general enforcement posture, describing itself as "a proportionate and enabling regulator" whose "approach is not to reach immediately for enforcement or sanctions." That stance should not be mistaken for leniency on registration deadlines, given how many thousands of buildings were registered late in 2023 and the continuing processing delays the regulator itself has acknowledged.

Commercially, the risk extends beyond fines. Insurers, lenders and prospective buyers increasingly ask to see evidence of Building Safety Act compliance before engaging with a residential block, making a clean compliance record a financial as well as a legal asset.

Comparing in-house compliance management against outsourced support

Many freeholders and resident management companies face a genuine choice between building Accountable Person compliance capability in-house or engaging specialist facilities and security partners to manage it alongside day-to-day building operations.

Priority First's model — combining facilities management, building management and security under one accountable partner — is built for Accountable Persons who need evidence-backed compliance without running a specialist in-house safety function. On a Bedfordshire care home with 96 units, for example, Priority First deployed manned security with every patrol, incident and handover logged on its platform, checkpoints completed with a photograph, GPS and timestamp — producing over 1,000 photo-backed patrols that give the building's management a documented, auditable safety record rather than an asserted one.

Your Accountable Person compliance checklist

• Confirm which legal entity holds the freehold, head lease or relevant repairing obligation for your building's common parts.
• Identify your Principal Accountable Person in writing where more than one Accountable Person exists.
• Register the building with the Building Safety Regulator without delay if it meets the 18-metre or seven-storey threshold.
• Commission a documented fire and structural safety risk assessment covering the whole building.
• Build and maintain the golden thread of building information as required by the 2024 Regulations.
• Publish a resident engagement strategy and a clear safety complaints route.
• Prepare the Safety Case Report and apply for a Building Assessment Certificate when due.
• Review patrol, maintenance and incident records regularly to ensure evidence is current, not retrospective.

FAQ

What is an Accountable Person under the Building Safety Act 2022?

An Accountable Person is the freeholder, management company or lease-holding party legally responsible for managing building safety risks in a higher-risk building. The status arises automatically under Part 4 of the Building Safety Act 2022 and is not something granted by agreement or tribunal.

What buildings count as higher-risk buildings?

A higher-risk building is a residential building in England at least 18 metres tall or with at least seven storeys, containing two or more residential units. Hospitals and care homes of the same height are also captured during design and construction.

What happens if a building misses the Building Safety Regulator registration deadline?

Missing the registration deadline does not exempt a building from the requirement — it simply means registration happens late and under greater regulatory scrutiny. More than 3,563 occupied higher-risk buildings were registered after the 1 October 2023 deadline, according to Construction News, showing this is a widespread rather than isolated problem.

Who prepares the Safety Case Report?

The Principal Accountable Person is responsible for preparing and maintaining the building's Safety Case Report. Other Accountable Persons must cooperate and provide the information needed to keep it accurate and current.

Can an Accountable Person delegate their statutory duties?

An Accountable Person can delegate day-to-day tasks, such as patrols, maintenance and record-keeping, to a specialist facilities management or security provider. The underlying legal responsibility, however, remains with the Accountable Person and cannot be transferred away by contract.

How does the Accountable Person role differ from the Responsible Person under the Fire Safety Order?

The Responsible Person under the Regulatory Reform (Fire Safety) Order 2005 has fire safety duties for a wider range of non-domestic premises, while the Accountable Person role under the Building Safety Act 2022 applies specifically to higher-risk residential buildings with broader structural and governance duties. In many higher-risk buildings, the same organisation holds both roles simultaneously.

How much does compliance typically cost an Accountable Person?

Costs vary widely by building size and existing management arrangements, covering risk assessments, golden thread record systems, resident engagement processes and ongoing patrols or monitoring. Treating compliance as an integrated part of facilities and security management, rather than a separate bolt-on exercise, is generally the more cost-effective route for multi-building portfolios.

Securing compliance confidence with Priority First

Meeting Accountable Person duties under the Building Safety Act 2022 depends on evidence — proof that risk assessments translate into daily action, that patrols happen, and that residents have a real route to raise concerns. Priority First builds exactly this evidence trail into its facilities management and security work across prime central London and nationwide.

On a 16-building prime central London estate, 250–280 photo-backed patrols per building are now delivered, with every checkpoint completion carrying a watermarked photo, GPS location and timestamp — turning an "assumed complete" nightly round into a documented one an Accountable Person can show a regulator, insurer or resident without hesitation.

If your building needs a facilities management and security partner that understands the evidentiary demands of the Building Safety Act, get in touch with Priority First to discuss a compliance-ready building management plan.

Related Reading

• Fire Safety Compliance Residential Blocks UK 2026 Guide
• Best Security Practices for Construction Sites: Ensure Safety and Compliance
• Building Compliance Services London | Priority First 2026

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