Why it matters at Gateway 2
Change control isn't only a construction-phase issue. The change control plan is one of the documents a Gateway 2 application must include. In the BSR's review of new-build applications rejected after validation, 27% did not adequately set out how changes would be managed during construction (why Gateway 2 applications fail).
Controlled changes
Once approved, the application documents become agreed documents. Any change to them is a controlled change. Every controlled change goes in the change control log, and the affected documents are updated. Some controlled changes also need the BSR's involvement:
- Major change: one that undermines the basis on which the project was approved. You need the BSR's approval through a change control application before the work starts. Unless an extension is agreed, the BSR takes up to 6 weeks to assess it.
- Notifiable change: one that could affect compliance with building regulations. You notify the BSR before the change is made and before related work starts. You can then proceed, and you don't have to stop work while answering the BSR's questions.
- Other controlled changes: recorded in the change control log.
Changes of client, principal designer or principal contractor, and changes of contact details, must also be notified.
Examples of major changes
From the BSR's guidance. Changes to:
- the external height or width of the building, or the number of storeys (including mezzanines);
- the number, width or length of staircases or other escape routes, including evacuation lifts;
- the external walls, including wall ties, restraint fixings or support systems in them;
- any part of the active or passive fire safety measures in the fire and emergency file;
- the layout or dimensions of the common parts;
- the number of residential or commercial units, or the structural design or loading;
- design assumptions set out in the building regulations compliance statement;
- part of the building becoming, or ceasing to be, a car park;
- replacing a product with one that has a lower reaction-to-fire classification than specified in the application.
A material change of use, such as converting commercial units to flats, is also treated as a major change.
Examples of notifiable changes
For example, changes to:
- layout or dimensions inside an individual flat, where the common parts aren't affected;
- the number or size of openings for pipes, ducts or cables through walls, ceilings or other elements;
- wall ties, restraint fixings or support systems in walls other than external walls;
- any other change to the fire and emergency file or the fire statement;
- the construction control plan or the change control plan;
- the partial completion strategy, or the staged work statement or a subsequent stages statement, if the application included one.
A replacement product with a different reaction-to-fire specification may be notifiable even if it is better. One with the same or a higher class is recorded instead.
What a change application or notification needs
For each change, the BSR asks for:
- a short description of the change and why it is major or notifiable;
- the reason for it (for example a new design approach or material availability);
- all the advice sought, including advice you disagreed with, and who gave it (name, occupation, contact details);
- which agreed documents it affects, with updated copies;
- an explanation of how the building will still meet all relevant building regulations.
For a change of client, principal designer or principal contractor, also upload the outgoing party's compliance declaration.
What the change control plan must cover
Schedule 1, paragraph 3 of SI 2023/909 requires the change control plan in the Gateway 2 application to set out:
- how changes are identified, and who they are reported to;
- how the impact of a change is identified and considered;
- the decision-making procedure, and whose advice is taken;
- how and by when changes are recorded;
- the procedure for deciding which changes are notifiable and which need a change control application;
- how the dutyholders periodically review whether the plan is working.
The BSR's guidance on preparing applications adds that all advice received, including advice that was rejected, should be recorded along with who gave it. In our view, a plan written as a generic company procedure, which doesn't name the roles on this project or say how a major change would be spotted, is a weak point.
Use the list above as a manual check of your plan. The free Gateproof checker confirms that a change control plan is in the pack, alongside the other required documents. It doesn't yet check the plan's content point by point.
Sources
- BSR, "Making changes to a higher-risk building project", GOV.UK (gov.uk/guidance/making-changes-to-a-higher-risk-building-project), updated 1 October 2026.
- The Building (Higher-Risk Buildings Procedures) (England) Regulations 2023, SI 2023/909, Schedule 1 paragraph 3 and Part 3 (changes before or during construction).
- BSR, "Getting building control applications right", Making Buildings Safer.
Written on 13 October 2026 and paraphrased from the guidance above. Check the current guidance on GOV.UK before relying on it. This is general information, not legal or compliance advice. Contains public sector information licensed under the Open Government Licence v3.0.