Gateway 2 timescales: how long fire safety works really take

If you are planning fire safety works in a higher-risk building, the most useful document published in September was not guidance. It is a spreadsheet.

On 4 September, updated on 15 September, the Building Safety Regulator published its building control approval application data for June to August 2026. It sets out, category by category, how many gateway 2 applications went in, how many were approved, how many were rejected, and how long each took. It is the closest thing the sector has to an honest programme planning tool, and almost nobody reads it.

Here is what it says.

The headline numbers have improved a lot

Twelve months ago, a gateway 2 application for a new higher-risk building took a median of 43 weeks and had a 39% approval rate. In the twelve weeks to 31 August 2026, the median was 22 weeks with a 92% approval rate. External remediation applications moved from 43 weeks and 47% to 33 weeks and 89%.

That is a genuine turnaround, and it is worth saying so, because the figures still being quoted around the sector are the older ones.

The category that matters to you is the one nobody reports

Now the part that affects anyone maintaining an existing building.

BSR reports internal refurbishment works to higher-risk buildings separately, and that category accounts for around 43% of all gateway 2 decisions. Its performance looks nothing like the headline:

• approval rate 78%, so roughly one application in five is rejected
• median time to approval 32 weeks
• median time to a rejection 24 weeks, which is 24 weeks spent to be told no
• 457 new applications in twelve weeks against 143 decisions
• 141 applications invalidated or withdrawn in the same period, almost as many as were decided
• 1,082 applications in progress

In London the pattern is sharper still: 331 new in, 83 decisions, 100 invalidated or withdrawn, 734 in progress.

For context, the statutory period for BSR to determine an application for work to an existing higher-risk building is eight weeks. The median is currently four times that.

What this means for a fire safety programme

If your building is a higher-risk building and the work is more than maintenance, the approval is not an administrative step at the front of the job. It is most of the job’s duration.

Three practical consequences.

One: the categorisation question comes first, not last. Approval is needed before building work to an existing HRB “unless it consists only of exempt work, competent person scheme work, fibre optic cabling work or emergency repairs” (GOV.UK). But category A work expressly includes “work involving passive or active fire safety measures” and “work on the building’s common areas or parts, including internal or external remediation work”. A like for like replacement may sit outside the regime. A compartmentation upgrade through the common parts almost certainly does not. Establish which you have before you build a programme around it, because the two answers are about eight months apart.

Two: an application that goes in incomplete is worse than one that goes in late. 141 invalidations and withdrawals against 143 decisions is not a queue problem, it is a quality problem. BSR says plainly that it continues “to work closely with the sector to help applicants improve the quality of applications”, and that applications submitted more recently move faster: internal works applications submitted in 2026 have a median of 16 weeks, half the headline figure. The difference between 16 weeks and 32 is largely the evidence pack.

Three: avoid becoming a major change. Once you are on site, a major change request stops work on that part of the project until BSR approves it. There are 184 live major change requests, 67 of them on internal works, taking a median of nine weeks to close. Nine weeks of a stood-down fire alarm programme in an occupied residential block is not a paperwork problem.

And a warning that should concentrate minds: BSR’s growing inspection programme “has found a small number of examples where building work has not followed agreed designs and has required some remedial work”. What was approved and what was installed now get compared.

Gateway 3 is the next bottleneck

Of 346 gateway 3 completion applications received, 260 are internal refurbishments. In the last twelve weeks 16 were determined, at 88% approval and a median of 20 weeks. The quickest was seven. For internal works specifically there are 105 in progress against nine approvals.

Budget for it. A completion certificate application requires, among other things, a statement confirming the client has handed the building information over to the responsible person and the principal accountable person. If your records are assembled at the end, that is where the delay appears.

One thing you do not need to worry about

The Building Safety Levy started on 1 October 2026 and BSR expected an application surge because of it. It applies to major residential development creating new dwellings or student bedspaces. Work that creates no new dwellings is out of scope, so a refurbishment client pays nothing. You will, however, be queueing behind everyone who rushed an application in before the deadline. Applications in progress at gateway 2 rose by more than 100 during August alone.

How Gemini AMPM can help

We are the contractor side of this, not the building control side. What that means in practice is designing and installing the work so the evidence exists when it is asked for: compartmentation and fire stopping surveys with breaches photographed and closed out, fire alarm and remedial works to BS 5839-1:2025 under our BAFE SP203-1 registration, AOV and smoke extract systems with commissioning records that match the approved design, and fire door and fire barrier works recorded to the same standard.

For residential and social housing clients that matters twice over, because the same records answer the gateway and the building safety case.

If you have works planned in a higher-risk building and want the design evidence right before it goes in, call 0330 043 0080.

Sources: GOV.UK, Building Safety Regulator building control approval application data June to August 2026; BSR data PDF, 22 pages; GOV.UK, Building control approval for higher-risk buildings; GOV.UK, Applying for a completion certificate; GOV.UK, Building Safety Levy guidance.