The Golden Thread of Building Information Explained

The golden thread is the set of building safety information and documents that must be kept, digitally and up to date, for a higher-risk building in England, together with the standards that govern how it is kept and who must be given access to it. It is a statutory duty with a defined content list, not a filing habit and not a product you buy. If your building is below the higher-risk threshold you do not have a golden thread duty, although you almost certainly have other record-keeping obligations.

The Two Halves of the Duty

The golden thread runs across a building’s life in two parts, created by two different sets of rules.

During building work on a higher-risk building, regulation 31 of the Building (Higher-Risk Buildings Procedures) (England) Regulations 2023 requires the client’s arrangements to include an electronic facility, created and maintained by the client or on the client’s behalf, to hold the golden thread information, plus procedures giving designers and contractors access to it so they can keep it current. The same regulation sets out how that information must be held and what has to be added to it as the project moves through building control approval, change control and completion.

Once a building is occupied, section 88 of the Building Safety Act 2022 takes over. An accountable person must keep prescribed information in accordance with prescribed standards, keep it up to date so far as possible, and keep copies of prescribed documents to the same standards. Section 88(3) adds the part that catches most older buildings: where an accountable person does not hold prescribed information or a document, they must obtain it, except where it is not practicable to do so. Section 88 came into force on 16 January 2024, on the same day as the regulations that fill in the detail.

Which Buildings It Applies To

Section 65 of the Building Safety Act 2022 defines a higher-risk building as a building in England that is at least 18 metres in height or has at least 7 storeys, and contains at least 2 residential units. Both limbs have to be met: height or storeys, and the two units.

The measuring rules matter, because they decide whether a borderline building is in or out. Under the Higher-Risk Buildings (Descriptions and Supplementary Provisions) Regulations 2023, height is measured from ground level to the top of the floor surface of the top storey, ignoring any storey that is roof-top plant or machinery. When counting storeys you ignore any storey below ground level, any roof-top plant storey, and any gallery with an internal floor area under 50 per cent of the largest storey above or below it. The same regulations exclude buildings made up entirely of a care home, hospital, secure residential institution, hotel or military barracks.

This is England only. The regulations extend to England and Wales but apply in relation to England, so a building in Devon or Cornwall is covered and the Welsh and Scottish regimes differ. Registration of occupied higher-risk buildings is a separate duty with its own process, covered in our note on higher-risk building registration.

The threshold has been looked at and left alone. In a review published on 17 December 2025 the regulator concluded that the evidence did not support changing the scope of the higher-risk regime at this stage, and set out an ongoing risk-based review instead, with a wider review of the Act expected in 2027.

Who Has to Keep It

The duty falls on the accountable person, defined in section 72 of the Act as a person who holds a legal estate in possession in any part of the common parts, or who holds no legal estate in the building but is under a relevant repairing obligation for any part of the common parts. A residents’ management company that owns the freehold, or that is under a repairing covenant for the common parts, will normally be an accountable person. Where all the repairing obligations for the relevant common parts are functions of an RTM company, the estate owner is not the accountable person for those parts. On commonhold land, the commonhold association is the accountable person.

A building can have more than one accountable person. Regulation 4(2) of the 2024 Regulations splits the load: each accountable person keeps the information and documents that relate to the part of the building it is responsible for. Several items in Schedule 1 are prescribed only for the accountable person that is also the principal accountable person, including the registration information, the key building information, the registration certificate, the building assessment certificate and anything connected with a building assessment certificate application.

A managing agent is not an accountable person by virtue of being the agent. It can create the system, populate it, keep it current and answer requests, and in practice that is how most golden threads are run. The legal exposure stays with the accountable person, which for a resident-led block usually means the directors of the management company. That is one reason the agent’s terms of engagement should say plainly who does what, and why golden thread work belongs in the same conversation as the rest of your statutory compliance and health and safety programme.

What the Golden Thread Must Contain

Schedule 1 to the Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2024 is the list. Paragraphs 2 to 14 prescribe information under section 88(1); paragraphs 16 to 31 prescribe documents under section 88(2). The table below groups the main headings.

Golden thread contents for an occupied higher-risk building (Schedule 1, SI 2024/41)
Heading	What has to be held	Schedule 1 paragraph
Fire safety management	A list identifying each fire safety management measure and a record of where each one is located; the current fire risk assessment documents created to comply with article 9 of the Regulatory Reform (Fire Safety) Order 2005 and to manage fire spread	6 and 22
Evacuation	The evacuation strategy and the evacuation information for the relevant part, and for the whole building where the accountable person is also the principal accountable person	7
Fire Safety (England) Regulations records	The record of the design and materials of the external walls, and the floor plans including the single-page building plan	23
Structural risks	A list identifying each structural safety measure, plus any assessment or report on structural risks, or a statement that an assessment is not needed	9 and 24
Risk assessment and safety case	Any report containing an up to date assessment of building safety risks, and the safety case report for the building	25 and 26
Maintenance and inspection	The schedule of planned maintenance and repairs to safety-related equipment and materials, the most recent inspection report, and records of maintenance and repairs actually carried out	10 and 26
Design and plans	Information on the design approach, including any design code applied, any British or International standard applied and complied with, and the design intent; plans of the building as currently constructed and as first constructed	11 and 27
Certificates and applications	Completion or partial completion certificate and the application it came from, the registration certificate, the building assessment certificate and material connected with the application for it	16, 18, 19 and 21
Reporting, engagement and complaints	Mandatory occurrence reports made to the regulator and the steps taken in response, information and documents given to residents and unit owners, and records of relevant complaints	12, 13, 14, 28, 29 and 30

Some items carry retention periods. Mandatory occurrence reporting material, complaint summaries and maintenance and repair records are prescribed while no more than 7 years have passed since the record was created or received. A contravention notice given by an accountable person under section 96 of the Act is prescribed for 5 years. Notices refusing a building assessment certificate are prescribed for 7 years.

Two practical points follow. First, the golden thread is mostly made of documents you should already have: the fire risk assessment, the evacuation strategy, the external wall record, the floor plans, the maintenance schedule. What changes is that they must sit in one controlled, electronic place with an audit trail. Second, the list assumes you can prove what the building is made of, which is why the evacuation strategy, the fire risk assessment and the compartmentation evidence tend to be the items that expose the gaps.

The Standards It Must Be Kept To

The prescribed standards are in regulation 7 of the Higher-Risk Buildings (Management of Safety Risks etc) (England) Regulations 2023. Information under section 88(1) must be:

kept in an electronic format that can be transferred to other people without the data being lost or corrupted
accurate
intelligible to its intended readers, with any key needed to understand the data supplied alongside it
kept so that it is accessible as soon as reasonably practicable in response to a request from a person entitled to it under section 89
secure from unauthorised access
changed only in accordance with procedures that record who made the change and the date of the change

Copies of documents under section 88(2) are held to the equivalent standards: electronic, transferable without loss or corruption, accessible promptly on request, secure, and subject to the same change-recording procedure. The safety case report itself must be kept in electronic form.

Government guidance published on 29 February 2024 puts the same requirements in operational terms: the golden thread should be a building’s single source of truth, kept digitally, secure from unauthorised access, available when someone needs it and presented in a form they can actually use, and it must comply with data protection law. Nothing in the guidance overrides the regulations, but it is a useful test to apply to any system you are being sold.

There is no approved software list and no requirement to buy a particular platform. A structured, access-controlled document system with version history can meet the standards. A shared drive with no change log cannot, because it fails the requirement to record who changed what and when.

Handover: How Information Reaches You and How It Leaves

On a project, regulation 38 of the 2023 Procedures Regulations requires the client to give the specified golden thread information and the building and fire safety information to the relevant person no later than the date the work is completed, or, where a partial completion certificate applies, no later than the date that part of the building is to be occupied. The information has to be provided in a way that retains the filing structure it was kept in, including each index and key, and in a format that lets the recipient read, keep and update it. The recipient must then give the client a notice acknowledging receipt and confirming both that they can access the information and that it is enough to understand, operate and maintain the building and its fire safety systems.

That acknowledgement is worth taking seriously. Signing it when the pack is a folder of unindexed scans commits you to a position you will regret when the regulator asks how the building was built.

When an accountable person changes, section 90 of the Act and regulation 9 of the 2023 Management Regulations require the outgoing person to pass information and copies of documents to the incoming one as soon as reasonably practicable, electronically, without loss or corruption, and intelligibly with any key needed to read the data. The regulator must also be told the outgoing person’s name, the part of the building involved, the building’s registration number, the date responsibility ended and the incoming person’s contact details. Changing managing agent is not itself a change of accountable person, but it is the moment the golden thread is most often broken, so treat access, exports and ownership of the platform as a handover item.

What a Managing Agent Actually Has to Do

Reduced to a working method, keeping a golden thread on behalf of an accountable person looks like this.

Build the inventory. Take Schedule 1 paragraph by paragraph and record, for each item, whether you hold it, where it lives and when it was last reviewed.
Close the gaps. Section 88(3) requires missing prescribed information and documents to be obtained unless that is not practicable, so chase the developer, the freeholder, the previous agent and the building control file, and keep evidence of the attempts where an item genuinely cannot be recovered.
Put it in one controlled system with named user access, permanent version history and a change log that captures the person and the date.
Set a review rhythm. Update after every inspection, every fire risk assessment revision, every alteration and every mandatory occurrence report, rather than in an annual scramble.
Feed residents what they are entitled to receive, including a summary of the current fire risk assessment with its evaluation of the level of risk, a summary of the safety case report, the residents’ engagement strategy, and the names and contact details of the accountable person, the principal accountable person and any responsible person.
Have a route for requests. Residents aged 16 or over and owners of residential units can request further material under section 92, and Schedule 3 to the 2024 Regulations lists what falls within that right.
Record refusals properly. The 2024 Regulations allow limited exceptions for security, commercial sensitivity and personal data, and each has conditions, so a refusal needs a stated basis rather than a blanket policy.

What Happens If It Is Incomplete

Failing to keep the golden thread is not prosecuted directly. It is enforced through compliance notices. Under section 99 the regulator may give a compliance notice to an accountable person who appears to have contravened, to be contravening, or to be likely to contravene a requirement under Part 4, requiring specified steps or remedy within a specified period. Where the contravention places people in or about the building in imminent danger, the notice can be marked as an urgent action notice.

Contravening a compliance notice without reasonable excuse is an offence. On conviction on indictment it carries up to two years’ imprisonment or a fine, or both, with a further daily fine at level 1 on the standard scale for each day the default continues after the first conviction. Section 99 has been in force since 1 October 2023.

The other pressure point is the building assessment certificate. The regulator has been reshaping how it handles those: in a statement on 9 July 2026 it said it would only call in new certificate applications where necessary until improved processes are agreed and communicated to duty holders, that it would prioritise applications already under assessment, and that initial updated resources were expected from September 2026. The regulator was equally clear that the underlying duties do not change, and that accountable persons must continue to manage their buildings so residents are safe. The Building Safety Regulator itself became a standalone body on 27 January 2026, sponsored by the Ministry of Housing, Communities and Local Government, having previously sat within the Health and Safety Executive.

If Your Building Is Below the Threshold

Most blocks in Plymouth, Exeter, Truro and the surrounding towns are under 18 metres and under 7 storeys, so they have no golden thread duty at all. That does not leave them without records to keep.

Under regulations 4 to 6 of the Fire Safety (England) Regulations 2022, the external wall record and the floor plans with a single-page building plan are required for high-rise residential buildings, meaning at least 18 metres or at least 7 storeys with two or more sets of domestic premises, along with a secure information box. Fire door duties reach lower: in a building with two or more sets of domestic premises that is above 11 metres in height, regulation 10 requires the responsible person to use best endeavours to check flat entrance fire doors at least every 12 months and to check communal fire doors at least every 3 months, keeping a record of the steps taken.

For a smaller block the sensible approach is to run a scaled-down version of the same idea: one indexed digital record of what the building is, what safety measures it has, when they were last tested and what has been altered. It costs little, it survives a change of director or agent, and it answers most of what a buyer’s solicitor, an insurer or a fire officer will ask. Our note on the Building Safety Act below 11 metres sets out where the statutory duties stop and proportionate practice begins.

Where to Start If You Are a Director

If your building is at or over the threshold, ask your managing agent for the Schedule 1 inventory with a status against every paragraph, and ask who is named as accountable person and principal accountable person on the register. If it is below the threshold, ask for a single indexed record of the building’s safety information instead. Plymouth Block Management runs formal property manager inspections every three months, holds accredited fire door inspectors, and provides independent building safety consultancy for buildings under 11 metres, so if you want a second view on where your records stand, that is the conversation to have.

Common Questions

Six points that come up repeatedly when directors first meet the golden thread duty.

Does the Golden Thread Apply to a Three-Storey Block of Six Flats?

No. The duty applies to higher-risk buildings, which under section 65 of the Building Safety Act 2022 must be at least 18 metres in height or have at least 7 storeys and contain at least 2 residential units. A three-storey block is outside the regime entirely. It will still have fire safety duties under the Regulatory Reform (Fire Safety) Order 2005 and, if it is above 11 metres, fire door checking duties under the Fire Safety (England) Regulations 2022.

Can the Golden Thread Be Kept on Paper or on a Shared Drive?

No to paper. Regulation 7 of the Higher-Risk Buildings (Management of Safety Risks etc) (England) Regulations 2023 requires information and copies of documents to be kept in an electronic format that can be transferred without loss or corruption. A shared drive is unlikely to be enough on its own, because the same regulation requires that information is only changed under procedures that record who made the change and the date of the change, and that it is secure from unauthorised access.

Who Pays for It, and Can the Cost Go on the Service Charge?

That depends on your lease. The golden thread duty sits on the accountable person, and the cost of meeting it is a management cost like any other, but recovery through the service charge requires wording in the lease that covers it. Under section 19 of the Landlord and Tenant Act 1985 relevant costs count only to the extent they are reasonably incurred and the work is of a reasonable standard, so both the lease route and the amount can be challenged. Take advice before assuming a new platform subscription is recoverable.

A Leaseholder Has Asked for the Safety Case Report. Do We Have to Provide It?

Broadly yes. Under section 92 of the Building Safety Act 2022 a resident aged 16 or over, or an owner of a residential unit, can request prescribed information and documents, and the accountable person must give it as soon as reasonably practicable. Schedule 3 to the 2024 Regulations includes up to date fire risk assessments, the most recent safety case report and the documents behind evidence quoted in it. Limited exceptions exist for security, commercial sensitivity and personal data, and each has its own conditions, so a refusal needs a stated legal basis.

What Happens to the Golden Thread When We Change Managing Agent?

The duty does not move, because the agent was never the accountable person. What must move is the content and the access. Make sure your appointment terms say the accountable person owns the data, that a complete export in a readable format with its filing structure and version history is provided on termination, and that administrator rights transfer to the incoming agent. If the accountable person itself changes, section 90 of the Act and regulation 9 of the 2023 Management Regulations set out what must be passed on and what the regulator must be told.

Is the Health and Safety File the Same Thing as the Golden Thread?

No, but it belongs inside it. Government guidance on keeping information about a higher-risk building treats the health and safety file as one of the documents an accountable person should hold as part of the golden thread, alongside the safety case report, the residents engagement strategy and the mandatory occurrence reporting system. The golden thread is wider, and its statutory content is the list in Schedule 1 to the 2024 Regulations.

Sources

Everything above is taken from these, not from a summary of them:

Building Safety Act 2022, section 88: Keeping information about higher-risk buildings legislation.gov.uk
Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2024, Schedule 1 legislation.gov.uk
Higher-Risk Buildings (Management of Safety Risks etc) (England) Regulations 2023 legislation.gov.uk
Building (Higher-Risk Buildings Procedures) (England) Regulations 2023, Part 4 legislation.gov.uk
Building Safety Act 2022, section 65: Meaning of higher-risk building legislation.gov.uk
Building Safety Act 2022, section 99: Compliance notices legislation.gov.uk
Keeping information about a higher-risk building: the golden thread GOV.UK
BSR to introduce more proportionate and targeted approach for higher-risk building assessments GOV.UK
Higher-Risk Buildings (Descriptions and Supplementary Provisions) Regulations 2023 legislation.gov.uk
Building Safety Act 2022, section 72: Meaning of accountable person legislation.gov.uk
Building Safety Act 2022, section 90: Provision of information etc on change in accountable person legislation.gov.uk
Fire Safety (England) Regulations 2022 legislation.gov.uk
Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2024, Schedule 3 legislation.gov.uk
Landlord and Tenant Act 1985, section 19: Limitation of service charges: reasonableness legislation.gov.uk
Definition of higher-risk buildings: initial review and plans for ongoing review GOV.UK
BSR becomes standalone body in landmark step towards single construction regulator GOV.UK

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