Keeping information about a higher-risk building: the golden thread

You must keep a digital record of information about a building if you are:

• a client on a project that involves higher-risk building work.
• a responsible person for a higher-risk building

In future this is likely to include an accountable person or principal accountable person when legislation comes into force for the management of building safety risks during occupation of a building.

The information about a building is sometimes known as the golden thread. Keeping it helps you:

• comply with your legal duties
• manage building safety

Other bodies such as Fire and Rescue Services may also use the information where appropriate.

A higher-risk building is a building that has at least:

• 7 storeys or is at least 18 metres high 
• 1 residential unit or is a hospital, a care home or a children’s home

Some types of buildings are excluded from being a higher-risk building, such as hotels, secure residential institutions and military barracks or other Ministry of Defence accommodation. 

You can read guidance on when buildings are considered to be higher-risk buildings during construction of new buildings and when carrying out building work on existing buildings.

You must manage and store information about a building, so that it is:

• kept electronically
• capable of being transferred electronically to other persons without the data, information or document in it being lost or corrupted
• accurate and up to date
• secure from unauthorised access
• available in a readable format when someone needs the information
• presented in a way someone can use
• a building’s single source of truth
• accessible, by providing the information in a simple format that is easy to understand and written in plain English
• compliant with General Data Protection Regulation (GDPR)

Client’s responsibilities

As the client, you must keep information that describes the building and shows how it complies with building regulations. To do this, you must keep a record of:

• how those responsible for the building work comply with their duties
• how you will manage the work, so you build what you set out to build

You must share information about the building with every designer and contractor on the project. 

To store information about the building electronically, you must provide a record-keeping system. Your system should have version control so users can see any changes. You must set out your policies and procedures, to make sure your system is:

• secure
• available for authorised access

Your record-keeping system will help you with the information you’ll need to prepare when you apply for building control approval.

These include:

• drawings and plans
• competence declaration
• construction control plan
• change control plan and log
• building regulations compliance statement
• fire and emergency file
• client authorisation
• site location plan
• mandatory occurrence reporting plan
• planning statement
• a partial completion strategy

At the end of the construction phase

When the building work is finished, as the client, you must apply for a completion certificate.

To apply for a completion certificate you must demonstrate that you have given the information about the building to the Responsible Person for the building.

The building information you must hand over includes:

• all of the information you used to apply for your building control approval
• all of the information you provided for the completion certificate application
• the building completion certificate
• access and control of the building information
• the relevant fire safety information

The person you give the information to must confirm they have received it and that it is in a format they can use.

Principal designer’s responsibilities

As the principal designer, you must capture and keep all of the design information up to date. 

You must work with the principal contractor to:

• make sure you record and evidence the design work during the construction phase
• help the client to provide information to anyone who needs it
• share information relevant to the building work

You must have processes in place to help:

• communication between designers
• capture and share information relevant to the building work

Principal contractor’s responsibilities

As the principal contractor, you must use the record-keeping system provided by the client to ensure that information about the building is up to date.

You must:

• help the client to provide information to anyone who needs it
• work with the principal designer to share information relevant to the building work
• have processes in place to help communication between all contractors
• keep evidence that the building work meets building regulations
• work with the design team to manage control changes

The Regulatory Reform (Fire Safety) Order 2005, the “Fire Safety Order”, currently applies to almost all premises in Wales that are not single private dwellings (such as ordinary houses and bungalows). Under the Fire Safety Order the “responsible person” for each premises is required by law to take steps to minimise the risk of fire on those premises. That includes completing a regular fire risk assessment and acting on the findings.

The responsible person may be an individual human being or (more commonly) a corporate entity like a company, charity or public body. Identifying the responsible person may not be straightforward in some cases, but in essence the responsible person is

• In relation to a workplace, the employer, if the workplace is to any extent under their control. In relation to premises that do not satisfy the above:
  • The person in control of the premises for the purposes of a business or undertaking(such as a landlord or self-employed person); or
  • The owner of the premises, where the person in control of the premises does not have control in connection with the carrying on by that person of a trade, business or other undertaking
  • The Building Safety (Wales) Act 2026 was passed by Senedd Cymru in March 2026. It is expected to come into force in the following few years. In certain cases it will effectively replace the Fire Safety Order for buildings which include two or more residential units, for example purpose-built blocks of flats, properties converted into flats and most houses in multiple occupation. 

Under the Act, duties to assess and manage fire safety risks, similar to those of the responsible person under the Fire Safety Order, will fall on an “accountable person” and a “principal accountable person” instead (see sections 8 and 9 of the Act).