Social housing providers will be aware that the draft Building Safety Bill (published in July 2020) creates a new duty holder regime with the obligation to report the "golden thread of information" for all High Risk Residential Buildings ("HRRBs") to the newly established Building Safety Regulator at three critical gateways. Those gateways are: 

1. At planning application stage; 

2. Before constructions works commence; and 

3. before the HRRB is occupied.

What is not yet clear is what information is required within the "golden thread of information", or the extent to which the Building Safety Regulator will interrogate that information. Compiling the "golden thread of information" is a potentially a substantial exercise, particularly for social housing providers with significant numbers of existing HRRBs in their housing stock, and so these questions are of very real concern to social housing providers.  

The Centre for Construction Law & Dispute Resolution, King's College London, is undertaking a project to prepare criteria for the Building Safety Regulator to consider at the three gateways. While there is no published timetable for publication of the guidance, the prospect of official guidance relating to the "golden thread of information" for the construction of new HRRBs will be of interest to the social housing sector.

Maintaining the "golden thread of information" has the potential to be a real driver for improved building safety. However, an enduring concern for many social housing providers is whether the "top down" regulation approach of the Building Safety Bill will ultimately address the workmanship and quality issues in construction works which frequently lead to fire safety risks.