End of September Building Registration Deadline
For most block managers, the news that the ‘high-rise’ building registration deadline is looming (30 September), should not be news!
It’s been well publicised by the Building Safety Regular (part of the Health & Safety Executive) and by industry bodies like the TPI, representing ARMA and IRPM members.
There are an estimated 12,500 (HSE estimation) buildings in scope, and simply, these are multioccupancy residential buildings that are 18 metres or greater in height, or 7 storeys or more. The safety regulator expects all buildings to be registered on its portal by 30 September.
What has been less well published is the requirement to provide Key Building Information, abbreviated by the safety regulator to KBI, also to the same deadline of the end of the month. The unofficial word is that an extension of time is being allowed for, for the KBI only, but we wouldn’t suggest you rely on it.
The initial registration is quite straightforward. The online form asks for information such as the height of the building, the number of storeys and when it was constructed. Still, the safety regulator needs to know the identity of the Principal Accountable Person (PAP), as defined by the Building Safety Act 2022.
Despite its name, the PAP is usually the RTM or RMC, rather than a single person, unless the building is owned by such a person with no entity below it with management responsibilities under the lease. Be careful though, as there may be additional Accountable Persons (AP) in addition to the PAP! This isn’t that common but if you have a complex lease and management structure, you might want to get some legal advice on PAP/AP, and fast.
The onus is on the PAP to register the building. They – most often the RTM or RMC board of directors – may delegate that responsibility to you as their block manager, and they are entitled to do that, as long as they put in writing that they recognise their RTM/RTM as the PAP and that they give you the go-ahead to do the registration for them. They may ask a third party to help with the registration, a consultant for instance.
Once that initial registration is done, the safety regulator will automatically ask you to complete another online form to provide the KBI. This is much more involved, and you are unlikely to have all the answers at your fingertips. We are finding that the requirement for KBI is catching out managing agents and PAPs, so we have been helping our clients to put them in touch with people who can help. Do reach out to us if you need help with the initial registration or the provision of the KBI. If you are ahead of the curve and ready to start preparing your safety case report (due by April 2024), we have some partners in our network who can help you with that as well.
Failure to register by the deadline of 30 September is a criminal offence and could result in a fine or imprisonment.
Building safety could not be higher up the priority list for managing agents with high-rise buildings in their portfolios. For us at Cledor, building safety starts with on-site personnel – concierges, estate managers, porters, cleaners – and we ensure the highest standards are reached through careful selection and training.