The change control plan in a Gateway 2 application

Why it gets applications rejected

The change control plan is one of the documents a Gateway 2 application for a new higher-risk building must include (regulation 4(2)(b)(iv) of SI 2023/909). For work to an existing higher-risk building it's required for category A work (regulation 12(2)(c)). In a sample of new-build applications the BSR rejected after validation, 27% didn't set out how changes would be managed during construction. The BSR doesn't state the sample size or period (why Gateway 2 applications fail).

What the plan must set out

Schedule 1, paragraph 3(1) says the plan must set out the strategies, policies and procedures the client has adopted so that every controlled change follows regulation 18 and is logged under regulation 19. It must explain:

1. how proposed changes will be identified, and who they must be reported to;
2. how the impacts of proposed changes are identified and considered;
3. the decision-making procedure for agreeing a change, including whose advice is sought;
4. how changes are recorded, and by when;
5. the procedure for deciding which changes must be notified to the BSR and which need a change control application;
6. how the dutyholders (client, principal contractor, principal designer) will periodically review whether the plan is working.

The BSR's guidance on preparing applications adds that all advice received should be recorded, including advice that wasn't followed, along with who gave it.

What a controlled change is

Under regulation 18(1), a controlled change is a change to:

• the current plans of the work, or carrying out the work other than in line with them;
• any stage of the work, including adding or removing a stage;
• any strategy, policy or procedure described in an agreed document. That includes the change control plan itself.

Before any controlled change is carried out, the client must make sure it's recorded in the change control log and that a revised version of every affected agreed document is produced (regulation 18(2)). There are three kinds of change: major, notifiable and recordable. A major change can't be carried out, and the work it relates to can't start, until the BSR grants a change control application (regulation 18(5)–(6)). A notifiable change can't be carried out, and its work can't start, until the BSR has been notified (regulation 18(3)–(4)). Other changes are recorded. Related major and notifiable changes can go in one change control application, but unrelated changes can't be combined (regulation 18(7)–(9)). Your plan's classification procedure (point (e) below) has to work quickly enough not to hold up the site. Examples and timescales are in major and notifiable changes after Gateway 2.

What the change control log records

The principal contractor (or sole contractor) keeps the change control log (regulation 19). Your plan should explain how each entry gets made. For every controlled change, the log records:

• the name of the person recording it;
• a description of the change and the reasons for it;
• whether it's a recordable, notifiable or major change;
• the name and occupation of everyone whose advice was sought, with a summary of their advice;
• which agreed documents it affects, with confirmation that revised versions have been produced;
• a "compliance explanation": how the work will still comply with the building regulations after the change, and how the procedures in the agreed documents (change control, mandatory occurrence reporting, competence, information sharing and co-operation) will still meet their requirements.

An outline you can adapt

This is a structure that maps one section to each requirement. It isn't a template that guarantees acceptance. The BSR looks for procedures specific to your project: named roles, real timescales and real routes for advice.

1. Purpose and scope. The project, the dutyholders by name, and which agreed documents the plan covers.
2. Identifying and reporting changes (3(1)(a)). Who can raise a change, how (for example a change request form), and who it goes to, by role.
3. Assessing impact (3(1)(b)). Who assesses the effect on building regulations compliance, fire safety, structure and the agreed documents, and how.
4. Deciding (3(1)(c)). Who can approve which kinds of change, and which specialists must be consulted, for example the fire engineer for anything touching the fire strategy.
5. Recording (3(1)(d)). The change control log: who keeps it, what each entry contains (see above), and the deadline for an entry, which must be before the change is carried out.
6. Classifying changes (3(1)(e)). How each change is classed as major, notifiable or recordable, who decides, and who prepares and signs the notification or change control application.
7. Advice log. How all advice is recorded, including advice that wasn't followed and why.
8. Reviewing the plan (3(1)(f)). When the dutyholders review whether the plan is working (for example quarterly and at each stage), and how changes to the plan itself are handled as controlled changes.

Common weak points: a generic company procedure that doesn't name this project's roles; no timescale for recording; no route for deciding whether a change is major; and no mention of advice that was rejected (our view, from the requirements and the BSR's rejection reasons).

Check your plan

The free Gateproof checker reads your change control plan and looks for wording on each point above, including the advice log. In a combined "control plans" document, it reads only the change control section. It does the same for the other Schedule 1 documents: the competence declaration (paragraph 1), the construction control plan (paragraph 2), the compliance statement (paragraph 4), where it lists which Parts of the Building Regulations are given with an approach, which are only named and which aren't mentioned, and the fire and emergency file (paragraph 5). Wording found only next to "TBC" is marked for checking rather than as found, and tables of contents are ignored. It's a keyword screen: it shows whether a point appears to be covered, not whether the procedure is any good. For the competence declaration it looks for the statutory statements themselves (regulations 11E(2)(b), 11F and 11G or 11H, and a declaration of truth), not just the names of the appointees. It can't judge whether the statements are true, and it can miss wording that doesn't use those references.

Sources

• The Building (Higher-Risk Buildings Procedures) (England) Regulations 2023, SI 2023/909: Schedule 1 paragraph 3, regulations 4(2)(b)(iv), 12(2)(c), 18 and 19 (legislation.gov.uk, current text checked 14 October 2026).
• BSR, "Making changes to a higher-risk building project", GOV.UK, updated 1 October 2026.
• BSR, "Getting building control applications right" and "Preparing information for a building control approval application", Making Buildings Safer and GOV.UK.

Written on 14 October 2026 and paraphrased from the sources above. Check the current guidance before relying on it. This is general information, not legal or compliance advice. Contains public sector information licensed under the Open Government Licence v3.0.