What we know, and what we do not

We know the document is published, because a national standards body is selling it. We know the UK adoption had not appeared on the NBS index by 17 September, which is normal: BSI adopts European and international standards on its own timetable, usually within weeks. We know that ISO 14001:2026 went through the same process earlier this year, released by ISO on 15 April 2026 and adopted as BS EN ISO 14001:2026 the same day, superseding the 2015+A1:2024 edition.

What we do not know, and will not pretend to, is what changed in the text. We have not read ISO 9001:2026 line by line. The certification bodies' summaries and the "what's new" webinars will follow, and some of them will be accurate, but the only reliable source is the standard itself, read against the 2015 edition clause by clause. Until we have done that, anything we said about specific new requirements would be a guess. We are not going to guess in print.

Your certificate is not affected today

A certificate to ISO 9001:2015 does not expire because a new edition has been published. When ISO issues a revision of a management system standard, the International Accreditation Forum sets a transition period during which certificates to the old edition remain valid and certification bodies move their clients across at surveillance or recertification audits. For the 2015 edition that period was three years from publication. Three years is the usual pattern for ISO management system revisions, but it is set case by case, so confirm the arrangements for this revision with your own certification body rather than relying on the pattern.

What that means practically: your next surveillance audit will be to the edition on your certificate unless your certification body tells you otherwise. Ask them in writing, now, what their transition plan is and when they will offer transition audits. Get the answer into your management review minutes so there is a record that the business knew and planned.

What to do now

1. Do not rewrite anything yet. A QMS that works, with records behind it, is worth more at your next audit than a hastily renumbered one. The transition period exists so that you do not have to rush.
2. Buy the text when BSI publishes the UK adoption, not a summary of it. The cost of the standard is trivial against the cost of a major nonconformity for a requirement you did not know existed.
3. Walk the clause map. Take your quality manual's clause cross-reference, or your gap analysis tool, and go through the 2026 text clause by clause against it. Record one of three things for each: unchanged, renumbered, or new or changed requirement. Only the third category needs work.
4. Put the gap on your corrective action register as a planned change under clause 6.3, with an owner and a date inside the transition window. Auditors like to see a revision planned rather than discovered.
5. Book the transition audit to coincide with a surveillance or recertification visit. Most certification bodies will combine them; a separate visit costs more.

How the StructAssure QMS handles it

The ISO 9001 Construction QMS is written to the 2015+A1:2024 clause structure and it will stay that way until we have walked the 2026 text against it. On 17 September we added an edition note to the quality manual (QM-001, section 1) and to the implementation plan (IMP-001): it records that ISO 9001:2026 has been published, that the pack follows the 2015+A1:2024 clause numbering pending review, and that the transition period is to be confirmed with the certification body. The note is there so that an auditor opening the manual sees that the business knows, which is itself evidence of clause 4.1 working.

The clause map inside the QMS has 66 rows, and the gap analysis tool (TOOL-001) follows the same numbering. When the UK adoption is available we will walk both against the new text and revise every procedure, form and register that the review touches. Buyers get the revision through their existing Payhip download link; the revision table in each document will show what changed and why. If nothing changed in a clause, we will say so rather than issuing a new revision for the sake of it.

We are taking the same line with ISO 14001:2026, which is already published and already cited in the Construction EMS, and with ISO 19011:2026 for the audit pack. The auditing standard is covered in a separate post.

The honest summary

A new edition of ISO 9001 is news for consultants and certification bodies. For a contractor with a certificate, it is a diary entry: ask the certification body about transition, buy the text when the UK adoption appears, walk the clauses, plan the change. If your quality system is built on evidence, hold points signed, NCRs closed with root cause, audits done and reviewed, the edition on the cover matters less than the auditor's ability to find that evidence. That is what we would spend the next three months on.

What ISO 19011 is, and is not

ISO 19011 is guidance. It is not a requirements standard and nobody is certified to it. ISO 9001:2015 does not even list it as a normative reference; it appears in the bibliography. The requirement to audit comes from clause 9.2 of ISO 9001, and its equivalents in ISO 45001 and ISO 14001: plan an audit programme, define criteria and scope, select auditors who are objective and impartial, report to management, correct what is found, keep the records. ISO 19011 tells you how to do those things well. So a change to ISO 19011 changes the advice, not the obligation.

What we have and have not checked

We have verified that the 2026 edition is current and that the 2018 edition is withdrawn, on the NBS Publication Index and against the release dates on en-standard.eu. We have not yet walked the 2026 text against the 2018 text line by line, and until we have we are not going to tell you which clauses moved or what new guidance was added. The 2018 edition set out seven principles of auditing (integrity, fair presentation, due professional care, confidentiality, independence, the evidence-based approach and, new in 2018, the risk-based approach), a clause on managing the audit programme, one on conducting an audit and one on auditor competence. Whether the 2026 text keeps that shape we cannot say yet. When we have read it, we will say so here.

In the meantime we have changed the citations. The internal audit procedure in the Quality Audit & Reporting Pack (QA-201) and the audit checklist Read Me in the ISO 45001 Construction OHSMS now cite ISO 19011:2026, with a note that the checklist questions were written to the 2018 process and have not yet been checked against the 2026 text. A note that admits what has not been done is worth more to an auditor than a citation that pretends.

The audit programme steps that do not depend on the text

These are the things that make an internal audit programme work on a construction contractor, and none of them will be changed by a revision of the guidance, because they come from the requirements standards and from what auditors actually find.

1. Plan by risk, not by calendar. An audit programme that visits every clause once a year in alphabetical order is a calendar, not a programme. Weight it towards the processes where failure costs most: hold points, subcontractor control, calibration, nonconformance, and the trade with the most NCRs last quarter. Record the reasoning on the programme so an external auditor can see it.
2. Write the criteria before the audit. Every checklist question names the requirement and where it comes from: the ITP line, the specification clause, the standard and its clause at the current edition. A question that does not cite its source cannot be failed fairly.
3. Audit evidence, not opinion. Each finding records the objective evidence: the document number, the location, the photograph, the name of the person interviewed. "Housekeeping poor" is an opinion. "Cable drums stored on bare ground at grid C4, contrary to the materials control plan section 5, photograph 12" is a finding.
4. Independence. The person who runs a process does not audit it. On a small contractor that means the site manager audits the office, the QS audits the site, and the director audits neither. If there is genuinely nobody independent, a half-day from an external auditor once a year is cheaper than a major nonconformity.
5. Grade findings consistently. Major, minor, observation, with the definitions written on the checklist. A major is a requirement absent or broken down; a minor is an isolated lapse in a process that otherwise works; an observation conforms but carries a risk.
6. Root cause before close-out. An NCR closed with "operative reminded" will reopen. Ask why until the answer is a process, a resource or a decision, and correct that.
7. Report upwards and prove it. Audit results are a required input to management review. Take the findings, the trends and the overdue actions into the review and minute what was decided.
8. Auditor competence on record. A training record, a witnessed audit, or a lead auditor certificate. The auditor's competence is one of the first things a certification body checks.

What to do this month

Change the citation in your internal audit procedure to ISO 19011:2026, add a note that the process has not yet been reviewed against the new text, and put the review on your document register as a planned change with a date. Buy the standard when your budget allows; it is guidance, so nobody will fail you for not owning it, but you cannot check your procedure against text you have not read. Then keep auditing. A programme with completed audits, findings closed at root cause and results in management review satisfies clause 9.2 whatever edition of the guidance is on the shelf.

ISO 9001 itself has also been revised this month. That one does carry obligations, and it has its own post.

Why it came back

An ITP has one job: to tell everyone, before the work starts, what will be inspected, against what, by whom, and what record will prove it. A reviewer working for the principal contractor or the client reads it with three questions in mind. Can I measure this? Can I find the clause it came from? Will I be there when it matters? An ITP that fails any of those questions is returned, usually with a comment such as "acceptance criteria to be developed" that tells you nothing about how to fix it. We set out the five reasons in the ITP guide; this post is the fix.

Minutes one to three: the acceptance criterion

Read every acceptance criterion and ask whether two competent people could disagree about whether it was met. "Installed to a satisfactory standard in accordance with the specification" fails: satisfactory to whom? Replace it with the value and the method. For a distribution board: "terminals torqued to the manufacturer's value with a calibrated tool and torque-marked; no exposed copper outside the terminal; conductors identified to Regulation 514". For a pour: "slump within the specified range at delivery, cubes taken at the frequency in the specification, cover checked with a spacer gauge before the pour is released". The criterion should read like the instruction to the person holding the clipboard, because it is.

Minutes four and five: the citation, at the current edition

Every line cites the clause it is checked against, and the edition matters. An electrical ITP citing BS 7671:2018+A2:2022 in September 2026 tells the reviewer that the plan was copied from an older job and nobody checked it. The current edition is BS 7671:2018+A4:2026, and the packs we build record that A3:2024 ceases to be current on 15 October 2026. Fire alarm ITPs citing BS 5839-1:2017 clause numbers are worse, because the 2025 edition renumbered the clauses; a line that says "commissioning to clause 39" now points at certification. Check every cited standard against a current index before you issue. It takes minutes and it is the single most visible sign of a plan that was actually thought about.

Minutes six and seven: the hold points

A hold point means work stops until the named party has attended and signed. A witness point means the party is invited, and if they do not turn up within the notice period the work proceeds and the contractor signs. Surveillance means they may turn up unannounced. Review means they look at the document afterwards. Most rejected ITPs mark everything as a hold point for every party, which is not a plan, it is a way of never getting the client's engineer to site. Choose the genuine holds: the pre-pour, the pre-close-up of a service void, the pre-energisation, the pressure test. Everything else is witness or surveillance, and the notice period, typically 24 or 48 hours, is written on the ITP so it cannot be argued later. Then agree the holds with the reviewer before you issue, so the approval is a formality.

Minute eight: the verifying record

Each line names the document that proves it happened: the check sheet number, the test certificate, the delivery ticket, the calibration record, the photograph log. "Inspection record" is not a name. "Activity check sheet E-014, board serial number recorded" is. If the line has no record, it has no evidence, and an auditor will find that a year later when a defect appears and the site team has moved on.

Minutes nine and ten: the sign-off columns

Three parties, three columns, before the plan is issued: the contractor, the principal contractor, and the client or their engineer, each with name, signature and date. Add a fourth for a third party where the contract has one, such as a building control inspector or a warranty surveyor. A plan that has to be redrawn to add a column after the client asks where their signature goes has lost the reviewer's confidence for the rest of the job. The check sheet that sits behind each line carries the same three columns, so a signed sheet and a signed ITP line say the same thing.

Then the frequency, and the resubmission

Every line states how often: every board, every pour, one in ten, one per batch. "As required" is not a frequency. When the pass is done, issue at the next revision number with a short covering note that says what changed against the reviewer's comments, line by line. Reviewers approve plans that answer their comments; they return plans that make them look for the changes.

What this looks like done

The free ITP for LV distribution boards is a worked example of the whole pass: 26 lines, every criterion measurable, every citation at the current edition, hold and witness points chosen rather than sprayed, a named record on every line and three sign-off columns. Compare it with the plan you have just had returned. If yours is already at that standard, the rejection was about something else and you should ask the reviewer directly; if it is not, you now know what to fix.

The fourteen

1. BS EN 166 is withdrawn. Eye protection is now specified to BS EN ISO 16321-1:2022+A1:2025, with BS EN ISO 16321-3 for the mesh and welding parts. Every RAMS, COSHH assessment and PPE matrix that says "safety glasses to EN 166" is citing a dead standard, though the stock in your stores still carries the EN 166 marks and will for years. We name ISO 16321-1 and keep the legacy mark in brackets. Bites: the Site Health & Safety Pack (done) and the RAMS worked examples (next).
2. BS 5975:2019 became two parts. BS 5975-1:2024 covers procedures and BS 5975-2:2024 falsework design; the single 2019 document was withdrawn on 18 December 2024. A temporary works procedure citing "BS 5975:2019" is out of date, and a register that does not distinguish the procedural part from the design part will confuse a temporary works coordinator. Bites: the Temporary Works Control Pack and the formwork and falsework lines in the civils ITP library.
3. BS 7671:2018+A4:2026. The fourth amendment to the Wiring Regulations is current, and the packs record A3:2024 as ceasing to be current on 15 October 2026. Every electrical ITP, check sheet and test record cites it. Bites: the free ITP, the ITP Starter Pack (M&E), the Commissioning & Test Plan Pack and the Construction Records Library.
4. BS 5839-1:2025. The fire detection and alarm code of practice for non-domestic premises was reissued on 30 April 2025 and the clauses were renumbered; the FIA's guide to the changes sets out where. A fire alarm ITP that cites the 2017 clause for commissioning now points at certification, and the cause-and-effect matrix is expected in the handover documentation. Bites: the fire alarm ITP in the M&E pack, the commissioning pack and the Handover & Close-Out Pack.
5. BS 5266-1:2025 with BS EN 1838:2024. Emergency lighting: the escape route illuminance criterion moved from the centre line to across the width of the route (not less than 1 lux, excluding the outer 0.5 m each side), with 0.5 lux for open areas. A commissioning check that measures the centre line only is measuring the wrong thing. Bites: the emergency lighting ITP, the commissioning check sheets and the test records.
6. BESA TR/19 is withdrawn. Ductwork cleanliness is now TR19 Air, Version 2 (2026), and kitchen extract is TR19 Grease (the August 2020 issue). A cleanliness certificate citing "TR/19 3rd edition" cites a withdrawn document. Bites: the ductwork cleanliness record in the Records Library and the kitchen extract ITP in ITP Library Volume 3.
7. BS 8300 split. BS 8300-1:2018 covers the external environment and BS 8300-2:2018 buildings; the undivided 2009 edition is withdrawn. Accessibility lines in a handover deliverables schedule need the right part. Bites: the Handover & Close-Out Pack and the accessible-installation notes in the M&E ITPs.
8. BS 7976 to BS EN 16165:2021. The pendulum slip test is now specified in the European standard; BS 7976 parts 1 to 3 are withdrawn. Floor finish handover evidence should cite the 2021 method. Bites: the Handover & Close-Out Pack.
9. BS 1377-4:1990 to BS 1377-2:2022. Compaction testing for earthworks moved parts when BS 1377 was reorganised. A compaction record citing Part 4 is citing a withdrawn document. Bites: the earthworks compaction record in the Records Library.
10. BS 8212:1995 to BS 8000-8:2023. Dry lining and gypsum board workmanship now sits in the BS 8000 workmanship series. Bites: the plot completion checklist in the Housing & Fit-Out Completion Pack and the dry lining ITP notes.
11. BS EN 124 is a series. Gully tops and manhole tops are covered by BS EN 124 Parts 1 to 6:2015, with the classes in Part 1 and the material-specific parts after it; the undivided 1994 document is withdrawn. Bites: the drainage ITP in the civils library and the drainage checklist in the Quality Audit & Reporting Pack.
12. BS EN 10025 is a series. Structural steel is BS EN 10025 Part 2:2019 for the non-alloy grades S275 and S355, with the later parts for the fine-grain and weathering grades. A materials approval schedule citing "BS EN 10025" without the part is not wrong, but a mill certificate is checked against the part. Bites: the structural steel ITP, the Materials & Procurement Control Pack and the steelwork audit checklist.
13. CIBSE Guide M, 3rd edition, 2023. Maintenance engineering and management, the reference for O&M manual structure and maintenance schedules at handover. The NBS index still carries only the withdrawn 2008 and 2014 rows; the current edition is on cibse.org. Bites: the mechanical and electrical O&M lines in the Handover Pack deliverables schedule.
14. BS EN 16282-1:2026. Commercial kitchen ventilation. The 2017 edition's own index page records it as superseded by the 2026 text, even though the 2026 row had not reached the index list on the day we checked. Bites: the kitchen extract ITP in ITP Library Volume 3.

Also moved this year

Three management system standards have new editions: ISO 14001:2026 (adopted as BS EN ISO 14001:2026 on 15 April), ISO 19011:2026 (BS EN adoption 9 June) and ISO 9001:2026 (published 16 September, UK adoption pending). BS 8214:2026 for fire door installation, BS EN 206-1:2026 and 206-2:2026 for concrete, BS EN 12845:2015+A2:2026 for sprinklers, BS 7273-4:2015+A2:2023 for fire door release and BS EN 15978:2026 for whole-life carbon assessment have all superseded the editions many documents still cite. Each has its own pack note, and the two ISO revisions have their own posts.

How to find yours

Take every standard cited in your quality plan, ITPs and RAMS and put them in one list with the edition as written. Check each one against a primary index: the NBS Publication Index carries the supersession history for British Standards; en-standard.eu gives release dates; cibse.org, hse.gov.uk and legislation.gov.uk for their own publications. Two traps we fell into. A base standard that has become a multi-part series shows as withdrawn when only the pre-series base document is, and the index list can lag a new edition that its own detail page already names. Write the check date on the list. Then do it again before every tender submission, because the reviewer on the other side has a list too.

First, what certification is

A UKAS-accredited certification body audits your business in two stages. Stage 1 is a readiness review: does the documented system cover the standard, is it in use, is there enough evidence for a full audit to be worth doing. Stage 2 is the audit proper: the auditor samples your records against the standard and your own procedures. If there are no major nonconformities, or they are closed, a certificate follows, valid for three years with surveillance audits between. Buying documents does not get you a certificate; the audit does. The documents are what make the audit about your business rather than about your paperwork.

The minimum document set

ISO 9001:2015 does not prescribe a quality manual or a list of procedures. It requires documented information where the standard says so and wherever you need it for the process to work. For a contractor of five to fifty people, our minimum is this:

1. A top-level description of the system, mapped clause by clause to the standard, with the scope of certification written down. Call it a quality manual if you like; the auditor uses it to find things.
2. The quality policy, signed by whoever runs the business, and quality objectives that can be measured: right-first-time at hold points, NCRs closed within a stated period, audits completed to programme.
3. Procedures for the processes that carry risk: document control, tender and contract review, supplier and subcontractor approval, materials control, planning and control of the works, inspection and test, nonconformance and corrective action, calibration, competence and training, internal audit, management review. If you design nothing, say so in the scope and leave design out.
4. The forms those procedures produce: the NCR, the corrective action request, the inspection and test record, the concession, the goods receipt check, the audit checklist, the management review agenda and minutes.
5. The registers that hold the evidence: documents and standards, ITPs, NCRs and corrective actions, approved suppliers, calibration, training, the audit programme, risks and opportunities.
6. A project quality plan for at least one live job, with its inspection and test plans and the signed check sheets behind them. This is the evidence the Stage 2 auditor spends most of the day on.
7. One completed internal audit against the programme, with findings recorded and closed, and one management review with minutes showing the inputs the standard lists and the decisions taken.

That is the whole list. Everything else in a full QMS is there because it makes the system easier to run at scale, not because the auditor will fail you without it.

A realistic timeline

Ninety days is achievable for a contractor with no full-time quality manager if someone owns it and the documents are not being written from a blank page. The roadmap we build into the QMS runs roughly like this:

• Weeks one and two: brand and tailor. Put your name on the documents, delete the procedures that do not apply, fix the scope, sign the policy, set the objectives. Do not add anything yet.
• Weeks three to eight: run it on a live job. Issue the project quality plan, get the ITPs approved, sign the check sheets, raise the first NCR and close it properly, log the calibration certificates, approve the subcontractors you already use with the evidence you already hold. This is where a system either becomes real or stays a folder.
• Weeks nine to twelve: audit and review. Do the internal audit, close the findings at root cause, hold the management review, and only then book the certification body. Booking earlier is the commonest mistake: a Stage 1 with no records behind it is a paid rehearsal.

Certification bodies need lead time for Stage 1 and Stage 2, so speak to two or three early, ask what their diary looks like, and compare the day rates and the scope wording rather than only the price. Tell them you intend to be ready in a stated month and ask them to hold it.

What goes wrong

Three things, in our experience of taking a contractor through it and of auditing the ones that struggled. First, the system was written by someone who does not work in the business, so nobody on site recognises it. Second, procedures promise records that do not exist: a procedure says "the site manager completes form F-12" and there is no F-12. Third, the audit and the review were done the week before Stage 1 with nothing behind them, and the auditor could tell. The fix for all three is the same: use the documents on a live job before anyone external looks at them.

What it costs, honestly

We will not quote you a figure for certification, because it depends on your headcount, your sites and the certification body's day rate, and anyone who quotes a number without knowing those is guessing. What we can say is that the document set above, done properly, is the smaller part of the cost. The larger part is the time of the person who runs it for ninety days. Budget for that person, or for a consultant to stand in for them, and the certificate follows.

One more thing. ISO 9001:2026 was published on 16 September 2026. If you are starting now, build to the edition your certification body will audit you against, which for the moment is 2015; this post explains why that is not a reason to wait.

The frame

The application is made under the Building (Higher-Risk Buildings Procedures) (England) Regulations 2023, SI 2023/909, regulation 4 and Schedule 1. The regulator, a standalone body sponsored by the Ministry of Housing, Communities and Local Government since 27 January 2026, works to a determination period of 12 weeks for a new higher-risk building and 8 weeks for work to an existing one, extendable by agreement. It may approve, approve with requirements, or reject. Our Gateway 2 guide sets out the full checklist; this post is about the order the evidence is read in and what makes each item survive the reading.

1. The building regulations compliance statement

This is opened first, and it is where most rejections originate. The team is looking for a strategy: how the design meets each applicable requirement of Schedule 1 to the Building Regulations, and where and why it departs from Approved Document guidance. A statement that lists the Approved Documents and says the design complies with each is not a compliance statement; it is a table of contents. Write it requirement by requirement, cross-referenced to the drawing or calculation that demonstrates the point, and make the departures explicit with the justification and the alternative evidence. A reviewer who finds the fire strategy, the structural strategy and the departures in the first ten pages reads the rest with confidence.

2. The drawings, at the right level

The drawings are read against the statement. They must demonstrate compliance, not describe a planning scheme with a note that details will follow. If the compliance statement says cavity barriers are provided at every compartment line, the reviewer expects to find them on a drawing with the product and its assessed classification, not "cavity barriers by specialist". The set that goes in is the set the approval attaches to, and every change to it afterwards is at least a recordable change.

3. The construction control plan

This is the principal contractor's document, and the team reads it to decide whether the people building the design will be able to prove they built it. It describes how the work will be planned, managed and monitored so that it complies: the inspection regime, the hold points, the records at each, the interface with the principal designer when the design changes, and how compliance will be evidenced at completion. The test a reviewer applies is whether the plan could be audited. A plan that says "inspections will be carried out in accordance with the quality management system" cannot. A plan that lists the inspection and test plans by element, marks the hold points, names the record for each and says who signs it can.

4. The change control plan

Read together with the control plan. Every change to the approved design during construction is at least recordable under regulations 18 to 26; a notifiable change is notified before it is carried out; a major change is applied for and not carried out until approved, and the regulator has six weeks to determine it. The plan has to show the classification method, the log, who classifies, and how a change discovered on site reaches the principal designer before the concrete is poured. A reviewer who sees a classification guide, a log template and a named owner believes the process exists. One who sees a paragraph does not.

5. The mandatory occurrence reporting plan

The system for identifying, reporting and recording safety occurrences under regulations 32 to 37, in place before construction begins. A safety occurrence meets the risk condition in regulation 35: it could cause a significant risk to life if it were not remedied. A notice goes to the regulator by the quickest practicable means and a report follows within ten days. The plan needs the definition, the workforce briefing, the internal reporting route and the form. Cross-reference it to change control, because an occurrence such as a cavity barrier that is not the product assessed is also a change.

6. Competence and the dutyholder appointments

Part 2A of the Building Regulations 2010 requires the client to appoint the principal designer and principal contractor in writing and to take reasonable steps to satisfy itself of their competence, including organisational capability and any serious sanctions. The application carries declarations to that effect. The evidence behind them is a record: the appointment letters, the competence assessment, the organisational capability evidence and the sanctions check. Reviewers do not read this first, but they read it, and a declaration with nothing behind it is the easiest requirement to attach to an approval.

7. The rest, and what happens after

The fire and emergency file, the partial completion strategy where the building will be handed over in parts, the planning statement and the higher-risk determination itself complete the set. Confirm each against the current text of Schedule 1 and the regulator's guidance on the application, which was updated on 1 April 2026.

Approval starts the clock, not the close-out. Work must commence within three years or the approval lapses under section 32 of the Building Act 1984, and for higher-risk building work regulation 46A of the Building Regulations 2010 treats the work as commenced when the client's statement confirms that 15 per cent of it has been done. From the first day the principal contractor is audited against the plans in the application: the change log open, the occurrence reporting system briefed, the golden thread kept to the standards in regulation 31, the Regulation 7 record for materials, and the ITPs with the hold points the control plan promised. Every declaration in the Gateway 3 completion certificate application under regulations 40 to 45 depends on those records, and under section 76 of the Building Safety Act 2022 the building cannot be occupied until the certificate is issued. A contractor who assembles the Gateway 2 pack in the order above has, without noticing, also built the filing system for Gateway 3.

England only; Wales, Scotland and Northern Ireland have different regimes. This is a summary of the regulations as read on 16 September 2026 and is not legal advice; the Building Safety Regulator's current guidance and the text of the regulations govern.