Anstey Horne

Do You Need to Register a High-Rise Residential Building?

Register High-Rise Residential Building

If you own or manage a high-rise residential building in England, you must confirm whether you need to register it with the Building Safety Regulator. The law requires certain buildings to be registered before anyone lives there. Registration is the legal gateway into the new building safety regime. It establishes who is accountable and ensures the regulator has core data about the building’s structure and fire safety. If you fail to register a building that meets the criteria, you commit an offence.

This guide explains when you must register a building, what counts as a “higher-risk” or “high-rise residential” building, who is responsible for the application, the information and fees involved, the offence for allowing occupation before registration, and what happens next. It is written to help you act decisively and avoid enforcement action.

What counts as a “high-rise residential” or “higher-risk” building

You need to register a building if it contains one or more high-rise residential structures. A high-rise residential structure has both of the following: at least 7 floors or a height of at least 18 metres, and at least 2 residential units. The registration must be with the Building Safety Regulator before residents move in. These buildings are treated as higher-risk buildings under the Building Safety Act 2022.

You do not register the following if they are entirely used as such: hospitals, care homes, secure residential institutions, hotels, military premises, or prisons. The detailed criteria explain how to treat connected structures and independent sections so that you register the right “building” rather than duplicating applications.

Practical Points - Register a High-Rise Residential Building

  1. Counting floors. Count all floors at or above ground level up to the top floor. If a mezzanine is 50% or more of the area of other floors, count it as a separate floor. Do not count any floor where the ceiling is below the established ground level, and do not count the roof.
  2. Establishing ground level and top floor. Ground level is the lowest part of the land immediately next to the building. Measure building height from this level to the top of the floor surface of the top storey. Ignore the roof.
  3. Estimating height. You can reasonably estimate height where the building clearly meets the thresholds. Keep a record of how you estimated this figure.
  4. Counting residential units. Include all self-contained places where people can live, such as flats, maisonettes or rooms in student accommodation, whether occupied or not.

Who is Responsible for Registration

The principal accountable person (PAP) must make sure you register the building. The PAP is the single organisation or, in limited cases, the individual with the legal obligation to repair the structure and exterior of the building, or otherwise meeting the statutory definition. In many cases this is a housing association, local authority, company, commonhold association or similar body. Only one PAP exists for each building, even if multiple accountable persons share responsibilities for different common parts.

The PAP can authorise another party to complete the application (for example, a managing agent or legal representative). The authorisation must be in writing, but it does not change who the PAP is or where legal accountability sits. You should also appoint a single point of contact to deal with the regulator day-to-day.

When you must Register a High-Rise Residential Building

You must register a qualifying high-rise residential building before anyone lives there. New buildings must also have a relevant completion or final certificate before occupation. If the building already has residents, it should already be registered under the regime. You commit an offence if you allow residents to occupy an unregistered high-rise residential building.

What the Application Involves

You register a high-rise residential building online. To complete the application you will need: the building name and address, a building summary that includes height, number of floors, number of residential units and the date of completion, and contact details for the PAP and any other accountable persons. You must pay an application fee and, within 28 days of submitting the application, provide more detailed structure and fire safety information known as “key building information.”

Key building information covers, for example, fire and smoke controls, energy supplies and storage, structure type, staircases and external walls, use, significant building work since original construction, and links to adjoining structures. Much of this can be drawn from your current fire risk assessment and any external wall appraisal rather than commissioning new surveys solely for registration.

Fees to Register a High-Rise Residential Building

Registration fee. You must pay £251 for each building you register. If you cannot pay by card, you can request to pay by invoice, but be aware that the regulator may reject your application if an invoice remains unpaid after 30 days.

Review fee. If the regulator refuses registration and you ask for a review of the decision, the review costs £302, payable before the review proceeds.

Building Assessment Certificate (BAC) fee. Later in the regime, the PAP must apply for a BAC when the regulator tells you to. The application charge is £302, and you will also pay for the regulator’s time under its published charging scheme. You must submit a BAC application within 28 calendar days of being told to apply.

The offence for allowing occupation before registration

It is a criminal offence which could lead to a fine or imprisonment to permit residents to occupy a high-rise residential building that has not been registered. This point is explicit in the government’s registration guidance and sits alongside the requirement to register before occupation. The maximum penalty for an individual convicted of this offence is two years’ imprisonment, an unlimited fine, or both

If you are planning first occupation of a new building, finalise registration as soon as you have the relevant completion certificate or final certificate. If you are taking over an existing occupied building and you are the new PAP, verify that the building is already registered and that contact and building information held by the regulator is up to date.

What happens after registration

Registration is the start, not the finish. The regulator uses your registration and key building information to understand the building’s profile and to prioritise BAC assessments. You do not need a BAC before residents can live in the building. The regulator will instruct you to apply for a BAC later and currently prioritises certain profiles, for example buildings in specified height or unit count bands, those with combustible ACM cladding, or large panel system blocks where reinforcement is unclear. When told to apply, you have 28 days to submit the application.

Your BAC application must include three core items that you should prepare early and then maintain: a safety case report, your mandatory occurrence reporting (MOR) system information, and your resident engagement strategy. The regulator can ask for additional records, hold meetings and request system demonstrations. If it refuses your BAC application it will set out issues and deadlines to fix them and can take enforcement action if you do not. You must display a BAC or any compliance notice prominently in the building.

How the legal roles link together

The Building Safety Act introduces Accountable Persons and a Principal Accountable Person to manage structural and fire safety risks in high-rise residential buildings. The Fire Safety Order continues to apply to common parts, and in many cases the AP or PAP will also be the Responsible Person for fire safety. Where roles differ, they must share relevant safety information and coordinate. You should align your registration, safety case, fire risk assessment and golden thread information so they present a coherent picture to regulators and residents.

To-Do List - Register High-Rise Residential Building

  1. Confirm whether you must register. Apply the 18 metres or 7 floors threshold and the 2 residential units test. Use the rules for counting floors, mezzanines and height. Record your calculations.
  2. Identify the PAP. Work through complex leaseholds and repairing obligations carefully. Where uncertain, take legal advice and, if necessary, seek a tribunal decision on who is accountable.
  3. Gather information. Compile address and completion data, floor counts, unit numbers, AP contacts, and key building information. Cross-check against your fire risk assessment and any EWS appraisal to avoid duplicate effort.
  4. Complete the registration application and pay the fee. Do not delay if first occupation is approaching. Remember it is an offence to allow occupation before registration.
  5. Within 28 days, submit structure and fire safety information. Plan this workload early so you meet the statutory timescale without a scramble.
  6. Prepare BAC materials now. Maintain your safety case report, MOR system and resident engagement strategy so you can submit them within 28 days when instructed and avoid enforcement action.

Role of the Building Safety Case Report

A building safety case report explains how you identify and control your two managed building safety risks: spread of fire or smoke, and structural failure. It sets out building information, roles and responsibilities, construction and materials, structural condition, any relevant building work, fire safety measures, risk assessments, emergency planning and safety management systems. Update it whenever risks or control measures change and keep version control. You must provide it when told to apply for a BAC or whenever the regulator requests it.

Mandatory Occurrence Reporting and resident involvement

As PAP you must operate a single Mandatory Occurrence Reporting system for each building during occupation so residents, APs and users can quickly report serious safety occurrences. The system must capture reports, ensure prompt assessment, notify the regulator as soon as possible, and submit a full report within 10 calendar days when a safety occurrence is identified. During design and construction phases, the principal designer and principal contractor have their own MOR duties. You will need to show how your MOR system works when you apply for a BAC.

You also need a resident engagement strategy that explains how you involve and inform residents on building safety decisions, how you consult and gather opinions, and how you make information accessible. The resident engagement strategy must be prepared as soon as the building is occupied or you become the PAP. You must consult on it, review it regularly and provide it to APs and residents. You must also submit it as part of your BAC application.

Working alongside your Fire Safety Order duties

The Fire Safety Order imposes duties on the Responsible Person to take general fire precautions in non-domestic parts and, as amended, to address structure, external walls and unit entrance doors in multi-occupied residential buildings. If you are both PAP and Responsible Person you must integrate your approaches. If different parties hold these roles, share information and coordinate. This alignment matters for registration accuracy and for demonstrating competence when the regulator assesses you for a BAC.

Common Pitfalls - Register High-Rise Residential Building

  • Not identifying the correct PAP. Complex leaseholds can lead to confusion. Resolve responsibility early and formalise any authorisations in writing.
  • Inadequate building summary. Missing or inaccurate counts for floors or units, or weak rationale for height measurements, will slow assessment. Use the published counting rules and keep an audit trail.
  • Late key building information. You have 28 days after submitting your registration to provide the structure and fire safety details. Plan data collation and quality checks in advance.
  • Unpaid fees. Applications can be rejected if fees remain unpaid. Track invoices and purchase order processes carefully.
  • Waiting to prepare BAC materials. You must not wait until you are told to apply for a BAC to prepare your safety case report, MOR system and resident engagement strategy. The regulator expects you to have these in place when the building is occupied.

FAQs - Register High-Rise Residential Building

Do I need to register if my building is 17.8 metres but has 8 floors?

Yes. The thresholds are “at least 7 floors or at least 18 metres” and “at least 2 residential units.” Your building meets the floors threshold so you must register before occupation.

We operate a mixed-use building. Do I count commercial floors toward the “7 floors” test?

Yes. Count all floors above ground level up to the top storey, whether they contain residential units or not. The test is about the structure, not solely the location of flats.

Can I authorise our managing agent to register high-rise residential building duties on our behalf?

Yes. The PAP can authorise an agent in writing to submit the application. This does not change who the PAP is or where accountability sits.

We have two adjacent towers over a shared podium. Is that one registration or two?

You may need to register two or more structures as one building if they are connected in defined ways. Use the independent section criteria to decide and avoid double-counting or gaps.

What is the registration fee and how do I pay?

The registration fee is £251 per building. You can pay by card. If you request an invoice you must pay it; the regulator may reject applications if invoice payments are not made within 30 days.

What if the regulator rejects our registration?

You can ask for a review of the decision within 21 days, excluding public holidays. The review costs £302. The regulator sets out reasons for rejection, such as not paying fees or not providing the required information.

What happens after we register?

You continue to manage building safety. The regulator will tell you when to apply for a Building Assessment Certificate. You must submit that application within 28 days and include your safety case report, MOR system information and resident engagement strategy. The BAC application carries a £302 charge plus time-costed assessment fees.

Do we need a BAC before residents can live in the building?

No. You must register before occupation, but a BAC is not required before people live there. The regulator will prioritise buildings and then invite you to apply for a BAC.

How does mandatory occurrence reporting affect registration?

Registration asks for key building information, then the BAC process tests how you manage safety. As PAP you must run a single MOR system for the occupied building and report qualifying safety occurrences quickly, with a full report within 10 calendar days. You will need to describe this system when you apply for a BAC.

What if we are not the Responsible Person under the Fire Safety Order?

That is common in mixed management structures. You still must register high-rise residential building duties if you are the PAP and coordinate with the Responsible Person so fire safety information and controls align.

Key Takeaways - Register High-Rise Residential Building

  • If your building meets the height and units test, register it before occupation. Allowing people to live there before registration is an offence.
  • Confirm who the PAP is. Only the PAP can ensure registration, though you can authorise an agent to act.
  • Prepare your data early. Have your building summary and key building information ready so you can file within the 28-day window after application.
  • Budget for fees. Pay the £251 registration fee. Plan for the £302 review fee if ever needed and for future BAC charges.
  • Build the rest of the regime. Maintain your safety case report, MOR system and resident engagement strategy now so you can respond quickly when told to apply for a BAC.

Contact

For more information on registering a high-rise residential building or to commission a Building Safety Case Report please call 020 4534 3130.

If you would rather we called you instead, please fill in our Contact form and we will be in touch.

For more information on all aspects of this service see the collection of articles in our blog.

To commission a Building Safety Case please call 020 4534 3130.

For further information on Building Safety Case reports, Fire Strategies, Building Safety, FRAEW Surveys, PAS9980, EWS1 forms or advice in respect of your obligations as a building owner, developer or manager, please contact :

Sean Robinson

Sean Robinson

BSc (Hons) MCIOB MIFSM

Director, Head of Dept.

Building Safety

London

Nikki Barrow

Nikki Barrow

BA (Hons) CIHM aFa

Building Safety Coordinator

Building Safety

Sarah Taylor

Sarah Taylor

Business Support Manager

Building Surveying

London