Schrödinger’s Skyscraper

Unsafe or Unbuilt: Why “Never Again” Must Be Written Into Law

Nearly seven years after the Grenfell Tower inferno of June 2017, a blaze that claimed 72 lives[1], Britain’s approach to building safety has become a tale of two extremes. On one hand, thousands of existing high-rises remain wrapped in dangerous materials or beset by fire-safety defects, their residents trapped in limbo awaiting remediation. On the other hand, the country’s pipeline of new housing, especially much-needed high-rise homes, has been choked by a post-Grenfell regulatory regime so cumbersome that projects are stalled before they even break ground.

It is a Schrödinger’s skyscraper of sorts: a building stock that is either unsafe or unbuilt, and in some cases seemingly both at once. Despite a deluge of new safety laws and regulations, the outcome on the ground has been dispiriting. In theory, Britain now has one of the world’s toughest building safety regimes; in practice, that regime has delivered reams of paperwork and paralysis, but precious little improvement in actual safety. As the National Audit Office (NAO) bluntly concluded in late 2024, the post-Grenfell cladding remediation saga had become a “seven year story of non-starts, false starts, misunderstandings, confused priorities, competing objectives and a desperate failure to admit fault”[2].

Yet the paradox runs deeper still. Even as developers, landlords, freeholders, manufacturers and building-control bodies have been placed under unprecedented legal scrutiny since Grenfell, one key institution has emerged from this regulatory revolution almost entirely unscathed: the fire and rescue services themselves. The Grenfell Inquiry identified grave operational failures at the London Fire Brigade (LFB), including an unshakeable adherence to an obsolete “stay put” policy, the absence of any evacuation doctrine for a failing high-rise, and serious breakdowns in command, communications and fire-survival-call handling. These were systemic shortcomings, not isolated mistakes. And yet, unlike the construction and housing sectors, the fire services have escaped meaningful structural reform or expanded statutory accountability.

This absence of reform is sharpened by a striking institutional irony. Two central figures from the Grenfell response - Andy Roe the incident commander on the night of the fire, and Charlie Pugsley, LFB’s senior fire investigator in the aftermath - now occupy the top leadership positions within the Building Safety Regulator (BSR). Roe, chair of the BSR, and Pugsley, its Chief Executive, are now responsible for overseeing the very regulatory regime intended to prevent another Grenfell. Their elevation underscores a troubling continuity: the same leadership cohort whose organisations were criticised for profound operational failings are now entrusted with enforcing a regime that leaves their former institution, the LFB, structurally untouched.

In effect, the actors who once operated within a system unable to prevent or adequately respond to the Grenfell fire are now charged with policing the rest of the safety landscape, while the institution they came from remains exempt from the kind of scrutiny that developers and building owners now face as standard. This represents not only an accountability gap, but a governance paradox: a regulatory regime that re-engineers the entire construction ecosystem while leaving the fire-service architecture that failed so visibly in 2017 largely intact.

Meanwhile, other parts of the world have demonstrated how decisive, coherent reform can strengthen both building safety and fire-service accountability. Singapore’s Building and Construction Authority can approve a new building plan in as little as seven working days[3], about as long as it takes a British regulator merely to locate its in-tray. Simply because its model distributes responsibility clearly and enforces it rigorously on all parties, including on fire-safety engineers and the authorities charged with responding to emergencies.

Britain, by contrast, has introduced a Building Safety Regulator (BSR) that takes nearly a year to approve high-rise projects, around 43 weeks nationally, and up to 48 weeks in London[4], while leaving the preparedness, competence and accountability of the fire services that will eventually respond to incidents in these buildings untouched. This transcontinental contrast, along with reflections of other international comparisons, underscores the true paradox: Britain has promised “never another Grenfell,” yet its convoluted regulatory crackdown has left the country with hundreds of Grenfell-like buildings still awaiting fixes, a housing sector struggling to build the safer homes of tomorrow, and a fire-safety system in which the only major actor that has escaped meaningful reform is the one charged with protecting the public when disaster strikes.

Hong Kong Burns, Britain Fiddles

If Britain’s post-2017 efforts seem lethargic, the recent experience of Hong Kong provides a jolting counterexample. On 26^th November 2025, a fire tore through Hong Kong’s Wang Fuk Court housing estate with apocalyptic fury, engulfing seven high-rise blocks and killing at least 159 people[5]. The territory’s deadliest blaze in decades. The response from authorities was swift and uncompromising. Within days, Hong Kong’s government banned the use of the renovation material blamed for fanning the flames and ordered its removal from every building under renovation, citywide[5][6].

By the first week of December, police had arrested 21 people in connection with the fire – 15 individuals from construction firms (including company directors) on suspicion of manslaughter, and 6 more from a fire systems contractor on suspicion of fraud[7].

Investigators homed in on substandard plastic mesh netting and foam insulation that allegedly turned the scaffolding into a giant wick, as well as fire alarms that mysteriously failed to sound[8]. Faced with public fury, officials didn’t hesitate: they ordered protective nets torn down from every building under scaffolding and bluntly told contractors to bear the costs of this massive safety purge[6].

A judge-led inquiry was set up to examine the disaster[9], but crucially Hong Kong has not waited years for an inquiry report before taking action. In a matter of days, the authorities identified what went wrong, ripped out the suspect materials, and began hauling those responsible in front of judges.

Now cast an eye back to Britain. The Grenfell Tower fire occurred in June 2017; its ashes have long cooled, but the quest for justice and safety improvements remains, at best, lukewarm. The official public inquiry into Grenfell has stretched on for years, divided into multiple phases of painstaking testimony and cross-examination. Civil and criminal proceedings have inched forward at a snail’s pace, bogged down in a labyrinthine legal process. By late 2024, seven years after Grenfell, hundreds of other buildings with similar flammable cladding were still standing, many with remediation works not even started.

The NAO’s review of the cladding crisis was scathing, describing a litany of government missteps and delays and calling the overall record “damning”[10]. In plainer terms: Britain fiddled while unsafe buildings proliferated. Yes, there has been progress on paper; bans on the exact type of cladding used on Grenfell, thousands of pages of new regulations, a new Building Safety Act in 2022, and the creation of various oversight bodies. But on the ground, how much has really changed? If a Grenfell-like blaze struck a high-rise in London tomorrow, would we fare significantly better? One hopes so.

There have been some safety retrofits (sprinklers installed in some high-rises, new alarm systems in others) and the most egregiously dangerous cladding materials (like the ACM panels on Grenfell) are no longer permitted on new buildings. Yet the uncomfortable truth is that hundreds of high-risk buildings remain inadequately fixed as of 2025, and no individual in Britain has faced criminal punishment to date for the myriad failures that led to Grenfell. The contrast with Hong Kong is stark. In Hong Kong, within days of a disaster, company bosses were led off in handcuffs[7].

In Britain, more than six years elapsed before police even handed files to prosecutors recommending charges against some organizations (the local council and fire brigade, among others) – and those cases are still in legal limbo. Hong Kong treated mass-casualty negligence as potential manslaughter, whereas in Britain it has been treated as a “tragedy” to be meticulously studied and politely litigated. Where Hong Kong’s leaders moved with a “remove hazards first, assign blame fast” urgency, Britain’s response often felt bogged down by procedure and a fear of apportioning blame. It is a sobering reminder that strong safety regulations on paper mean little if they are not matched by effective enforcement and a willingness to hold wrongdoers accountable.

The Cladding Crisis: “Guilt by Wealth” and Glacial Progress

Nowhere is Britain’s muddled post-Grenfell approach more evident than in the ongoing cladding remediation saga. In the immediate aftermath of Grenfell, it became clear that hundreds of high-rise blocks across the UK were wrapped in similar combustible façades. Tens of thousands of residents, many of them first-time buyers in starter flats (myself included), suddenly found their homes labeled firetraps. Their property values plummeting to near-zero, their insurance premiums soaring, and their peace of mind destroyed.

One might have expected an emergency national operation to strip dangerous cladding off buildings as fast as humanly possible, backed by whatever resources necessary. Instead, the years following Grenfell saw faltering efforts and policy zig-zags. Initially, the government left homeowners (the leaseholders) on the hook for remediation costs that often ran into tens of millions of pounds per building.

Service charges soared. Waking watches, also known as Fire Wardens (or humorously Human Scarecrows), were required on National Fire Chiefs Council (NFCC) guidance. The NFCC being the professional body and collective voice for UK fire and rescue services. Neither a regulator, nor a government department. Such decisions drove up service charges, and combined with EWS1 ratings (external wall system assessments) requiring lengthy expensive fire investigations, people’s ability to remortgage or sell was trashed. All because there was no common fire alarm system capable of warning all residents, which in turn fire risk assessors would move to simultaneous evacuation. Human scarecrows was one of the few possible interim measures argued to be permissible until alarms or remediation were in place.

All this was a result of the Regulatory Reform (Fire Safety) Order Act 2005, under Labour. It shifted fire safety from a fire-authority certificate model to a responsible-person risk assessment model. Brigades like London Fire Brigade (LFB) were the enforces, and NFCC today helped set the standards, although back then it was the Chief Fire Officers’ Association (CFOA) – the precursor to the NFCC – who was consulted during its drafting.

At the time the LFB explicitly clarifying that waking watches were not imposed by the fire service, they were required to be put in place by the person responsible for fire safety in each building. Technically true under the Fire Safety Order. Fire and rescue services are not regulated in the same way building owners are. They enforce the Fire Safety Order, they are generally not subject to it. Only the responsible person, usually the freeholder or managing agent, had the legal duty to implement. LFB could not legally mandate waking watches by name.

Herein lies the first structural accountability gap. It is profoundly contradictory given waking watch became NFCC recommended, fire-brigade endorsed, risk-assessor specified, insurer-expected, leaseholder-funded, but nobody-mandated. It is the purest example of Post-Grenfell buck passing. A responsibility vacuum built into the regulatory architecture by a Labour government.

Public outcry eventually forced a U-turn: ministers acknowledged it was morally wrong for innocent flat-owners to pay, and vowed to make developers and builders (“the polluters”) pick up the tab. In 2022, then-Housing Secretary Michael Gove thundered that those who profited from shoddy construction would face consequences, and he introduced new legal tools in the Building Safety Act 2022 to compel them to act. Chief among these tools was the Remediation Contribution Order (RCO) – an order that can force a company to pay to fix a building’s defects, even without a traditional finding of legal liability, if the tribunal deems it just and equitable to do so[11].

This approach has been described as “guilt by wealth” by leaders in the industry: if you can’t easily establish who is at fault, then make whoever has the deepest pockets pay. Parliament essentially decided that waiting for years of courtroom battles to resolve exactly who was liable for each fire-safety defect was unacceptable. It was better to grab the most well-resourced actors (developers, freehold investors, construction firms, manufacturers) and strong-arm them into funding the fixes.

The moral logic is clear: someone has to pay to make these homes safe, and it shouldn’t be the blameless residents or the taxpayer if a private company is still around with a link to the building. The legal logic, however, is novel. An RCO is purposefully a non-fault-based remedy, designed as an alternative to fault-based claims in court[11]. In granting an RCO, a tribunal doesn’t need to find negligence or breach of contract, it only needs to find that the building has fire-safety defects and that it is “just and equitable” for the respondent to contribute.

In fact, the law explicitly allows RCOs to cover costs already incurred by others (e.g. the government’s interim grants), so that the public money can be recouped from private entities who might have been responsible[12]. In short, Parliament cut through the usual legal process: rather than prove Company X caused the problem, simply establish that Company X is connected to the building and has the means, then make them pay up front, and let them sort out the blame with their partners later.

The landmark test case for this new approach came in January 2024. A first-tier property tribunal, using its RCO powers for the first time, ordered the owners of London’s former Olympic Village development to pay £18 million toward cladding and fire-safety remediation works[13][14]. The case, brought by a social housing provider (Triathlon Homes) on behalf of leaseholders, targeted Get Living, a £9 billion investor-landlord that had bought into the Olympic Village site (now known as “East Village” in Stratford).

Several mid-rise blocks at East Village were found to have a smorgasbord of fire safety defects; Grenfell-style combustible cladding and insulation, missing fire breaks, flammable timber balconies, and more[15][16]. Remediating these five blocks was estimated to cost over £24 million[17].

Get Living argued that it did not design, build, or refurbish the blocks (which were originally constructed for the 2012 Olympics and then converted to housing) – in essence, “we’re just the current owner, why should we pay for others’ mistakes?”. The tribunal, however, decided that under the new law, Get Living (and its subsidiary that was the original developer) should indeed pay. It granted an RCO for roughly £17.9m (rounded as £18m), reasoning that this was exactly the scenario Parliament contemplated: the original developer entity (now owned by Get Living) bore primary responsibility for the cost of remediation, and if the developer itself couldn’t cover it, then its deep-pocketed parent company should step in[18][19].

The fact that government funds (the Building Safety Fund) were available was no barrier. Those grants were “a matter of last resort” and should not displace the developer’s obligations[12]. In the tribunal’s words, the Building Safety Act intended that “RCOs are essentially non-fault-based” and an independent means to secure urgent payments for repairs[11].

For the affected residents of East Village, this ruling was a godsend. A long-awaited breakthrough that meant, finally, their homes could be made safe and they wouldn’t be bankrupted in the process. Triathlon Homes hailed the decision, saying it “creates a clear precedent” and brings hope of an end to the nightmare that had caused “such misery” for leaseholders living in uncertainty[20][21]. But for Get Living and many in the development industry, the outcome felt like rough justice. Get Living publicly called the tribunal’s decision “fundamentally flawed” and immediately lodged an appeal.

Its spokesperson argued that the tribunal had deemed it “just and equitable” to hold Get Living responsible even though the company “did not build the development” nor make the flawed design choices[22]. Indeed, the tribunal acknowledged Get Living was not involved in any original wrongdoing, but under the statute, that was beside the point[23]. The company effectively became the “wallet” for a problem it didn’t create, a role it clearly finds objectionable. The case is now headed to higher courts, where developers hope to argue against what they see as retrospective punishment and overreach. Yet, tellingly, the UK government itself has sided with leaseholders in this fight; even Michael Gove signaled support for the tribunal’s aggressive use of the new powers[24]. Politically, the previous government bet heavily on the “make the polluter pay” approach to resolve the cladding crisis.

And how is that approach going? In financial terms, some success: as of 2025, dozens of major developers have agreed (under threat of sanction) to fund repairs on buildings they put up in the past 30 years. Hundreds of millions of pounds have been committed by industry, and the Treasury set aside over £5 billion more in public funds for cases where the builder no longer exists. But in practical terms, progress on the ground has been agonizingly slow. By the end of 2024, the NAO found that up to 60% of buildings with dangerous cladding had not even been identified yet, let alone fixed[25].

It estimated the total cost of remediating all unsafe cladding in England at £16.6 billion, and projected that the “misery” will go on until 2035 before the work is done[26]. In the interim, hundreds of thousands of people remain stuck in limbo. The journalist Peter Apps, who has closely chronicled this crisis blaming corporate greed amongst other reasons, estimates that between 750,000 and 1,000,000 people in the UK are still living in flats affected by serious fire-safety defects[27]. These are homeowners who often cannot sell or re-mortgage their properties (because of the known fire risks), who may be paying extortionate insurance and service charges for interim safety measures, and who live with the anxiety that their building could be the next Grenfell. All fair points.

The NAO’s review described the human toll in measured terms, “stress, uncertainty and financial loss for those who simply bought a flat in modern Britain”[28], but for many affected residents the situation is nothing short of hellish. They feel abandoned: caught between a government that took years to mobilize a response, an industry that often denies responsibility, and a bureaucratic funding system that moves at a glacial pace. One poignant illustration came in late 2023, when a fire broke out in an East London apartment block that was in the middle of having its cladding removed, mercifully, no one was hurt, but it served as a stark reminder that until remediation is actually completed, these buildings and their residents remain at risk[29].

Britain’s cladding crisis response, then, has been a double-edged sword. On one edge, a commendable determination to protect leaseholders and hold industry financially accountable; on the other, a procedural quagmire that has left repairs grinding along slowly while homes sit in scaffolded disarray.

From the perspective of a displaced flat-owner, the government’s newfound toughness on developers is welcome, better a messy fight that results in the building being fixed at someone else’s expense than a tidy injustice where the homeowner pays. From the perspective of developers and investors, however, the experience has been bruising. They see a government willing to rewrite rules and bypass normal legal process to pin enormous liabilities on parties that may only be tangentially related to the original sins. Trust between the housing industry and the state has frayed.

Some major investors reportedly now hesitate to get involved in residential development or high-rise projects, wary that they could be landed with the “last man standing” bill for systemic problems. Indeed, even as the cladding remediation slowly advances, it casts a long shadow over the construction sector: investors are skittish about backing new high-rise developments amid so much uncertainty and regulatory risk[30].

As Melanie Leech of the British Property Federation told Parliament, “Investors look at the uncertainties … and they say, ‘Why would I go anywhere near that?’”[31]. This chilling effect on investment is contributing to a broader slowdown in building.

A point we turn to next.

Regulator or Roadblock? The Building Safety Regulator’s Dilemma

Amid the push to fix yesterday’s buildings, Britain has also tried to prevent the unsafe buildings of tomorrow. The flagship reform here was the creation of the Building Safety Regulator (BSR) under the Building Safety Act. Starting in 2023, the BSR (operating initially within the Health & Safety Executive) became the national building control authority for any “higher-risk building”, essentially, residential buildings over 18 meters or seven storeys, as well as hospitals and care homes meeting certain height criteria. The idea was to centralize and beef up oversight for complex high-rise projects, to avoid the regulatory lapses that allowed Grenfell’s defects to slip through.

In theory, this was a sensible upgrade: instead of leaving high-rise approval to under-resourced local building inspectors or third-party approved inspectors (as was the case pre-Grenfell), a dedicated expert regulator would scrutinize designs and construction plans at key “Gateways.” The most important checkpoint is Gateway 2, a stage at which the BSR must give detailed approval of a building’s safety design before construction can begin. By law, the BSR aimed to decide on Gateway 2 applications within 12 weeks (roughly 3 months).

In practice, however, the BSR’s rollout has been plagued by delays and capacity problems, to the point where it is now seen by many developers as a significant roadblock to getting anything built. As of mid-2025, the average time to get Gateway 2 approval in London was around 48 weeks (nearly a year)[4], and elsewhere in England about 43 weeks, four times longer than the target timeline. Official statistics released over the summer showed an average of 36 weeks nationwide for Gateway 2 decisions (with some cases stretching well beyond a year)[32].

By July 2025, the regulator disclosed that fewer than one-third of applications were being processed within the 12-week target[33]. The rest lingered for months on end. A backlog of roughly 35,000 residential units (in about 200+ projects) was stuck awaiting BSR decisions, effectively freezing those developments in place[33].

For a country already struggling with a housing shortage, this bottleneck was alarming. “Challenging, frustrating and costly,” is how one construction executive described his firm’s experience with the BSR process[34]. Another industry leader noted that high-rise schemes had “ground to a halt” due to the logjam[35]. In short, the very mechanism designed to guarantee we “build safely” was now being blamed for why we barely build at all.

Multiple factors contributed to this state of affairs. First, the BSR was a new entity that had to scale up quickly. It suddenly became responsible not only for new-build high-rises, but also for approving remediation plans (e.g. the recladding of existing towers) – leading to a flood of applications. Developers and housing associations, eager to get moving on projects that had planning permission, all submitted Gateway 2 applications as soon as the system opened, apparently overwhelming the small initial BSR team. Second, there is a scarcity of specialist expertise.

The kind of thorough fire and structural engineering review that the BSR must do for each complex building requires highly skilled staff; fire engineers, façade experts, structural engineers, etc. The construction industry itself has a limited supply of these professionals, and many were already occupied designing the solutions; the BSR struggled to hire enough qualified people to review them on the government side[36]. One developer testified that BSR salaries were not competitive to attract top talent, noting that “good calibre fire safety experts are probably getting a better living in consultancy than they would at the BSR”[37].

Third, the BSR’s processes were (by its own later admission) initially too bureaucratic. It attempted “multi-disciplinary” team reviews of each application, which proved slow. Communication with applicants was poor; numerous projects sat idle with little feedback, then were hit with lengthy requests for further information. By the time 2025 rolled around, frustration in the building industry had reached boiling point. Parliamentary committees summoned the BSR’s leadership to explain themselves. Andy Roe, the newly appointed chair of the BSR (and formerly the London Fire Brigade commissioner), gave a remarkably candid warning in mid-2025: if the regulator did not show “very significant change by the end of the calendar year, we run the risk of losing the complete confidence of everyone in the regulatory regime”[38]. In other words, without rapid improvement, the entire post-Grenfell safety system could lose legitimacy in the eyes of those it regulates.

The government took note. In June 2025, barely a year into the BSR’s operation, ministers announced an emergency shake-up. The BSR would be removed from the HSE and re-established as a stand-alone executive agency under direct ministerial control[39]. Fresh leadership was brought in: Roe had already been installed as chair, and his former LFB colleague Charlie Pugsley (a veteran fire safety officer) was named chief executive of the regulator[40][41]. A “Gateway backlog sprint” plan was devised to clear outstanding cases by the end of 2025, and a “fast-track” process was introduced to triage simpler applications. The goal was to bring average Gateway 2 wait times down to the target 12 weeks in 2026. By late 2025, there were signs of progress, the BSR reported that it had largely cleared the oldest legacy applications and was hiring dozens of new staff[42][43].

But the damage to confidence was already done. Developers had started pricing in a 15 month regulatory delay into project timelines beyond obtaining planning permission (making many schemes financially unviable in a high-interest-rate environment), or avoiding high-rise residential plans entirely. Britain’s overall housing construction numbers reflected this malaise, with new housing starts in 2023–25 falling sharply. The Home Builders Federation warned that unless the BSR became more efficient, the government’s own housing supply targets would be impossible to meet[44].

The irony is that other advanced jurisdictions manage to combine rigorous safety oversight with timely approvals, showing that “safe” and “swift” need not be mortal enemies. Singapore, for example, has equally strict building codes for high-rises, but its regulatory process is streamlined: a Qualified Person (registered architect/engineer) submits the plans, and the Building & Construction Authority commits to respond typically within 7 working days for straightforward cases[3] (and around 20 working days if multiple agencies must coordinate on a complex project)[45].

Compliance is heavily enforced in Singapore, builders face severe penalties for deviating from approved plans – yet the system trusts qualified professionals and focuses regulatory attention where it truly matters. The result: Singapore continuously adds to its skyline of safe high-rises without inordinate delay. By contrast, the UK’s BSR approach initially treated every project, big or small, as if it required months of deliberation, and in doing so it inadvertently threw concrete into the gears of development. Notably, the UK already had a statutory time limit of 5 weeks for local building control authorities to approve building regulation plans (extendable to 8 weeks with agreement)[46].

Of course, that old system wasn’t perfect, Grenfell’s refurbishment was signed off by a local council inspector in 2016, with disastrous results. But it at least operated within predictable timelines. The new regime, in seeking to fix the quality issue, created a quantity issue: it could not process the volume of cases in a timely manner.

It must be emphasized that safety and speed are not mutually exclusive goals. As Andy Roe himself told Parliament, “I do not think there is a tension between building [housing] at volume and doing it safely. There are plenty of other advanced democracies in the world where they do it, and people still make a profit and people live in houses”[47]. In other words, the UK should be able to build many new homes and ensure those homes are safe.

It simply needs a regulatory system that is competent, adequately resourced, and intelligently designed. The recent reforms to the BSR are an attempt to reach that balance by adding capacity and simplifying processes. Time will tell if they succeed. The stakes are high: without a functional regulator that can both hold builders to high standards and approve projects efficiently, Britain risks sliding into a worst-of-both-worlds scenario, a dearth of new housing supply and lingering safety issues in the housing we already have.

Leadership and Accountability: LFB’s Legacy and the New Regime

As Britain revamps its building safety machinery, a thorny question has emerged: are we truly embracing change, or simply reshuffling the same deck? A notable feature of the new post-Grenfell landscape is that many of the key figures in building safety regulation come from the very institutions that were found wanting in the Grenfell disaster.

For instance, the BSR’s top leadership, Chair Andy Roe and Chief Executive Charlie Pugsley, are both longtime London Fire Brigade (LFB) officers. Roe was the LFB’s Commissioner from 2020 to 2023 (and on the night of Grenfell in 2017, he was the incident commander who eventually ordered the belated evacuation of the tower). Pugsley, likewise, served nearly 30 years in the LFB, including as a Deputy Commissioner in fire safety. Their appointments to the BSR in 2025 raised some eyebrows.

After all, the Grenfell Tower Inquiry had spotlighted systemic failings in the LFB’s preparedness and response. In his Phase 1 report, Sir Martin Moore-Bick found that the LFB’s reliance on a “stay put” strategy had become “an article of faith” within the brigade, so powerful that, even as flames raced up Grenfell’s exterior, abandoning ‘stay put’ was effectively unthinkable for far too long[48]. The inquiry noted that LFB commanders failed to plan for a scenario of full building evacuation despite obvious signs that compartmentation had collapsed. In fact, LFB’s Commissioner at the time (Dany Cotton) testified that she could not imagine how one would evacuate such a tower.

A statement the Inquiry said demonstrated that LFB had never even tried to answer that question in advance[49]. Training and preparation were “gravely inadequate”: no contingency plan existed for a Grenfell-like inferno, there was no procedure to coordinate the flood of 999 calls from residents trapped by spreading fire and smoke, and frontline crews had no training in the dangers of combustible cladding even though a similar high-rise cladding fire (Lakanal House 2009) had occurred years earlier[50][51]. These were not merely individual errors – they were institutional shortcomings stemming from culture, policies, and questionable leadership.

So, when two senior LFB leaders were put in charge of the new Building Safety Regulator, some survivors’ groups and observers were understandably concerned. Would this be a fox guarding the henhouse scenario? Or could insiders like Roe and Pugsley be the reformers needed to turn the system around? The question was posed directly in a parliamentary hearing: with two “fire brigade people” at the helm, how can we be sure the new regulator will truly shake things up and not repeat old patterns? Andy Roe’s response was illuminating. He acknowledged the concern, “I completely accept the optics of it”, he said, but argued that his and Pugsley’s experience was actually an asset[52].

Roe pointed out that as LFB Commissioner, he had in effect been running “one of the largest regulatory businesses in the UK,” responsible for fire safety across 3.8 million dwellings and 20,000 listed buildings in London, among other sites[53]. Roe also claimed in a recent interview with Peter Apps that “you cannot physically build a regulatory department that’s big enough to get everywhere”. For comparison, the UK has 12,500 high-rise buildings, while Singapore has over 10,000. This is a classic example of civil service lack of accountability that has focused attention of reform far too narrowly. Despite this, this experience gave him, he said, an intimate understanding of how the new BSR needed to function (indeed, the LFB was heavily involved in setting up the BSR’s processes).

He also insisted that he was coming in with humility: “we ain’t got all the answers”, Roe told the committee, promising to bring in a mix of experts and to be fully transparent and accountable for the BSR’s performance[52][54]. He noted, too, that his appointment was time-limited, effectively suggesting that if he didn’t deliver results in short order, he expected to be replaced[55].

Still, critics argue that the creation of the BSR allowed the London Fire Brigade itself to evade direct reform. The Inquiry’s recommendations did include many measures for the fire service (improved training, new policies for incident command, better information systems for high-rises, etc.), and LFB has been implementing those. Andy Roe in his tenure as Commissioner did oversee some meaningful changes, and the brigade was lifted out of a form of special measures by 2022 after showing progress[56].

However, the fundamental structure and resourcing of fire services in the UK, and their relationship to building safety enforcement, remains largely the same. The BSR oversees building control and safety case reviews for buildings, but fire brigades continue to handle on-the-ground inspections and emergency response, and there is no single unified fire and building safety agency.

One could argue that the BSR’s arrival allowed government to say “we’ve fixed the system” without having to confront deeper issues like fire service capacity, inter-agency coordination, or the fragmentation of responsibilities. In a sense, the regulatory deck has been reshuffled, not necessarily fundamentally improved. The same LFB that was unprepared for Grenfell is still fighting fires today; the hope is that lessons have been learned, but some campaigners remain skeptical.

Notably, community groups and civil rights advocates have pointed out that over three-quarters of Grenfell’s residents were from ethnic minority backgrounds, and they have raised uncomfortable questions about whether institutional racism or class bias played a role in how safety concerns at Grenfell were ignored pre-fire and in how authorities responded post-fire[57][58]. The inquiry, constrained by its terms of reference, largely sidestepped examining these issues of social housing policy and discrimination.

Its final report stated it found no evidence that racial or social prejudice affected the decisions that led to the disaster[59]. Essentially concluding that incompetence and regulatory failure alone could explain it. But many in the Grenfell community dispute this conclusion. Groups like the Runnymede Trust responded that the tragedy was “marred at every point by structural and direct racism” from the fact that the victims were mostly people of colour and low-income, to the way survivors were treated in the aftermath[60].

They argue that wider structural issues; namely indifference toward social housing tenants, deregulation driven by cost-cutting, and marginalised voices, set the stage for Grenfell. These voices worry that without addressing those root causes, a new regulator or new laws alone will not prevent history from repeating.

In judging Britain’s post-Grenfell reforms, one must therefore ask: has accountability truly been delivered, and have the right lessons truly been learned? On the accountability front, as noted, no individuals have yet been held criminally responsible for Grenfell. The corporate and organisational accountability has taken the form of inquiries, lawsuits, and public shaming. But the Grenfell families still await concrete justice.

On the lessons front, the reforms have certainly addressed technical failings (banning combustible materials, tightening building standards, etc.), but it is less clear that they have addressed cultural failings, such as the “it could never happen here” mindset that pervaded some corners of industry and regulators, or the tendency to cut corners to save costs at the expense of safety. The presence of former LFB chiefs in the new regime could be seen as a commitment to continuity of expertise, or as an instance of the establishment marking its own homework.

Ultimately, albeit somewhat perversely, Roe and Pugsley will be judged by whether the BSR actually makes buildings safer without strangling development. If they succeed, their background will be of little concern; if they fail, it will raise serious questions about whether Britain really changed or just changed the guard. And why they able to avoid being prosecuted themselves.

The Fire Service Accountability Gap: Why the UK Lacks Criminal or Regulatory Oversight for Operational Fire Failures

The UK is unusual among advanced countries in having no independent regulator for fire-service operational competence. No statutory licensing for senior fire officers. No legal duty of operational competence equivalent to clinical or engineering professions. And no periodic external audit of doctrine, training, or operational readiness. As a result, failures cannot be sanctioned by an external body, lessons from major incidents rely on self-implementation, accountability remains diffuse or symbolic, and public confidence remains low. The Post-Grenfell regime regulates buildings, not the organisations responding to fires in those buildings.

In the United States, there is accreditation standards for fire departments, licensing and decertification mechanisms for fire-service leaders in many states, civil liability risks for command decisions. Japan can hold fire chiefs criminally liable for “professional negligence resulting in death”, with independent oversight at municipal and national levels.

Compared to these systems, the UK has limited personal accountability mechanisms and no external regulatory body overseeing fire-service performance. British senior fire service leaders currently operate without a statutory competence framework, and without a professional licensing regime. A key issue in Grenfell unresolved is the absence of fire-service regulation. There is still no mechanism to prevent a recurrence of the failures seen at Grenfell.

On reflection, the post-Grenfell landscape has exposed a deep structural paradox at the heart of Britain’s building and fire-safety architecture: the fire and rescue services, despite being pivotal actors during the Grenfell disaster and key contributors to the shortcomings identified by the Inquiry, remain the least regulated, least scrutinised, and least legally accountable institutions within the safety regime.

While landlords, developers, manufacturers, and building control bodies now operate under a dramatically expanded web of civil and criminal liabilities, the fire services themselves, including the London Fire Brigade (LFB), continue to occupy a regulatory blind spot.

1. Fire Services: The Regulators Without Regulation

Under the existing framework, fire and rescue services act as statutory enforcers of the Regulatory Reform (Fire Safety) Order 2005. They possess the power to:

o Inspect buildings

o Issue enforcement and prohibition notices

o Initiate prosecutions

o Compel remedial action through legal orders

Yet they are not meaningfully subject to the same regime they enforce. The Fire Safety Order regulates responsible persons (building owners, freeholders, managing agents, employers), not fire services. Failures in fire-ground decision-making or preparedness sit outside the Fire Safety Order’s scope, leaving no statutory mechanism to hold fire services to account when their own actions contribute to catastrophic outcomes.

This structural asymmetry is not incidental. It is designed into the system. The Order embodies a mid-2000s “light-touch” regulatory philosophy that shifted responsibility onto building operators while assuming fire services themselves were beyond the need for regulatory oversight. Grenfell revealed the flaw in that assumption.

2. No Criminal Liability for Operational Failures

In theory, individual fire officers could face criminal liability under:

o Gross negligence manslaughter

o Misconduct in public office

o Corporate manslaughter (for the authority, not individuals)

In practice, the threshold for such prosecutions is so high that no fire officer or fire authority has ever been successfully prosecuted for operational failures resulting in civilian deaths.

Even in the aftermath of Grenfell - where the Inquiry identified:

o The LFB’s entrenched adherence to an obsolete “stay put” doctrine

o A total absence of evacuation planning

o A failure to train commanders for façade-spread fire events

o Serious breakdowns in control room communication and situational awareness

To this date, there remains no realistic prospect that any individual officer will be held criminally accountable. Operational discretion during emergencies is shielded by a judicial reluctance to criminalise judgment calls, even where those judgments are demonstrably flawed, or where systemic preparations were woefully inadequate.

Instead they are leading the regulator of buildings. Despite never building anything themselves.

3. Limited Institutional Oversight Through HMICFRS

Institutional regulation of fire services is conducted by His Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (HMICFRS). Inspections can:

o Expose institutional weaknesses

o Place a brigade into “special measures”

o Require improvement plans

But HMICFRS has no power to impose fines, compel restructurings, dismiss leadership, or pursue criminal sanctions. It regulates performance, not compliance, and offers recommendations, not enforceable directives. It is effectively a diagnostic body rather than a regulator in the traditional sense.

This stands in stark contrast to how the Building Safety Regulator (BSR), the Health and Safety Executive (HSE), and even local authorities are now empowered to intervene aggressively in the private building sector.

4. The Paradox of NFCC Guidance and Accountability Avoidance

Post-Grenfell, the National Fire Chiefs Council (NFCC) produced national guidance, most notably its Simultaneous Evacuation Guidance, which became the de facto rulebook for managing high-rise buildings with dangerous cladding. Yet fire services, notably the LFB, publicly maintained that “we do not require waking watches”.

Technically true, because under law the “responsible person” implements interim measures. But practically false, because:

o NFCC guidance strongly recommended waking watches in buildings moved off “stay put”.

o Fire risk assessors followed NFCC guidance.

o Insurers expected compliance with NFCC guidance.

o Fire services based their advice and enforcement decisions on NFCC guidance.

The result was a multi-billion-pound waking watch industry, paid by leaseholders, arising from guidance written by fire chiefs who bore no liability for its consequences. This is a textbook example of non-accountable power: fire services shape doctrine that has quasi-regulatory force, while disclaiming responsibility for its impact.

5. Grenfell Exposed the Gap - But Reform Avoided It

The Grenfell Inquiry made plain that failures within the fire service were not isolated errors but deep institutional deficiencies:

o No evacuation doctrine for high-rise building failure

o No risk models for façade fires

o No integrated command and control system capable of processing fire survival calls

o A culture that treated “stay put” as non-negotiable

o No operational learning from earlier high-rise failures such as Lakanal House

Yet post-Grenfell reforms did not create any statutory mechanism to regulate or sanction the fire service for future operational failures. Instead:

o Fire services gained enhanced influence in shaping the new building control regime.

o Two senior LFB figures from the Grenfell era, namely Andy Roe and Charlie Pugsley, were elevated to leadership of the Building Safety Regulator.

o The new regime imposes unprecedented scrutiny on developers and building owners while leaving fire-ground decision-making largely untouched.

This creates a profound imbalance, because now those who build are more regulated than those who respond when the building fails.

6. International Contrast: Singapore’s Clear Lines of Accountability

Several countries show alternative models where fire authorities are not exempt from liability:

o In Singapore, fire safety engineers and approving officers can be criminally prosecuted or struck off for negligence in certification or inspection.

o After the 1986 Hotel New World collapse, Singapore introduced personal professional liability for design and inspection failures, something unheard of in the UK’s fire-service structure.

o Fire authorities are themselves subject to statutory performance and legal duties, including criminal oversight.

Britain currently still lacks any comparable mechanism.

7. Why This Matters

A system that places stringent criminal and civil burdens on developers, contractors, freeholders, and building inspectors, yet places no equivalent burden on the fire authorities, cannot claim to be a comprehensive safety regime.

This accountability gap matters because:

o Fire decisions directly affect life safety during an emergency

o Institutional learning is weak without external pressure

o Guidance issued by fire services has regulatory force yet no regulatory responsibility

o Public trust erodes when only some actors face consequences

o Uneven accountability distorts incentives across the safety ecosystem

In short, Britain reformed everything except the fire service. Fortunately, there are successful models it can follow.

The Radical Singapore-Style Accountability Model

If the UK is serious about closing the fire-service accountability gap, incremental changes will not be enough. The current framework treats fire and rescue services as enforcers rather than regulated entities, and treats even egregious operational failures as matters for internal learning rather than external sanction. By contrast, Singapore’s system embeds personal, professional and criminal liability into the very architecture of building and fire safety.

A radical reform programme for the UK would adopt the principles of the Singaporean model, not its political culture, by making senior fire officers, fire-safety professionals and approving authorities personally responsible in law for the consequences of their decisions.

1. Core Principles Drawn from Singapore

Singapore’s post-disaster regulatory evolution (notably after the 1986 Hotel New World collapse) rests on three pillars:

1. Named professional responsibility

o Design and approval documents are endorsed by specific Qualified Persons (registered engineers/architects) or Fire Safety Engineers; their signature is a legal declaration that the work complies with codes and is safe.

2. Statutory personal liability

o Under the Fire Safety Act, failure by owners, qualified persons or fire-safety engineers to comply with statutory duties can attract fines up to S$200,000 and/or imprisonment of up to two years, with additional daily fines for continuing offences.

3. Integrated fire and building safety enforcement

o The Singapore Civil Defence Force (SCDF) enforces fire-safety law, conducts inspections, issues Fire Safety Certificates and, since 2020 amendments, has expanded powers to investigate suspected offences and prosecute serious fire-safety risks directly.

In effect, engineers, fire-safety professionals and approving officers know that negligence can cost them their licence and their liberty. This tightens discipline upstream and reduces the need for slow, bureaucratic over-control downstream.

A radical UK reform would take these principles and apply them to fire-service leadership and operational fire-safety decision-making, not just to designers and developers.

2. A New Legal Architecture for Fire-Service Accountability

2.1 Create a Fire Safety Accountability Act

Parliament should legislate a Fire Safety Accountability Act (FSAA), mirroring Singapore’s Fire Safety Act in its structure and sanctions but tailored to UK conditions.

The FSAA would:

· Define statutory duties for:

o Chief Fire Officers/Commissioners

o Gold and Silver Commanders

o Fire-safety directors and heads of prevention within each service

· Cover:

o Operational preparedness for high-risk scenarios (e.g. façade fires, full-building evacuations)

o Maintenance of functional command and control arrangements

o Competence and training standards for incident command

o Integrity and accuracy of advice issued to building owners (e.g. on evacuation strategies, interim measures)

Breach of these duties, where it creates or materially contributes to serious risk to life, would become a criminal offence - with sanctions analogous to those faced by negligent professional engineers under Singaporean law.

2.2 Register and License Senior Fire Officers

In parallel, the UK should introduce a statutory licensing regime for senior fire-service leadership, akin to the registration of professional engineers in Singapore or British doctors under the GMC.

Key features:

· Licensing requirement for:

o All Chief Fire Officers/Commissioners

o Assistant Chiefs or equivalent

o Officers designated as Gold or Silver Incident Commanders for high-risk environments

· Revalidation every five years, contingent on:

o Demonstrated CPD in high-rise fire dynamics, evacuation science, command decision-making and human factors

o Evidence of learning implementation from major incidents and exercises

· Sanctions:

o Suspension or revocation of licence for gross incompetence, negligence, or failure to comply with FSAA duties

o Prohibition on holding senior fire-service posts without an active licence

Professional licensing would make it possible to remove individuals from positions of authority when systemic failures are demonstrably linked to poor leadership, rather than relying on informal resignations or early retirements.

2.3 Extend Personal Liability to Fire-Safety Sign-Offs

Currently, building-safety sign-off in the UK is focused on designers, contractors and the new Building Safety Regulator. A radical model would:

· Require named, registered senior fire officers (or accredited fire-safety professionals) to endorse:

· High-rise pre-incident plans

· Evacuation strategies (stay put, phased, or simultaneous) for higher-risk buildings

· Acceptance of complex fire-safety design solutions (e.g. performance-based designs) from a fire-service perspective

Their endorsement would carry statutory liability equivalent to that of a Qualified Person in Singapore:

· Knowingly or negligently endorsing unsafe strategies would be a criminal offence, with fines and/or imprisonment available on conviction.

This would end the current situation where fire-service doctrine (e.g. “stay put” in a cladding-compromised tower) is highly consequential but legally consequence-free for its authors.

3. Independent Fire & Building Safety Authority

To avoid simply inserting new duties into the existing, fragmented system, a radical model would establish an integrated Fire & Building Safety Authority (FBSA).

3.1 Mandate and Powers

The FBSA would:

· Combine the building-safety regulatory functions of the BSR with a new fire-service regulator, empowered to:

· Inspect fire and rescue services for operational competence (not just organisational effectiveness)

· Mandate improvements in training, doctrine, and systems

· Enforce FSAA duties on named officers

o Refer cases for criminal prosecution where appropriate

· Hold a joint responsibility for certifying:

· Higher-risk buildings as safe to occupy, and

· The corresponding fire-service as competent and prepared to respond to emergencies in those buildings.

Occupation of a new higher-risk building would require dual sign-off:

1. Structural and building-systems safety (FBSA “building” arm)

2. Operational fire-response readiness (FBSA “fire” arm)

This mirrors Singapore’s integration of building control (BCA) and fire-safety enforcement (SCDF), where both code compliance and fire-response readiness are overseen under coherent statutory frameworks.

3.2 Powers to Prosecute and Sanction

The FBSA would:

· Have powers similar to SCDF under the Fire Safety Act, including:

· Investigation of suspected fire-safety offences

· Entry powers to premises and access to documents

· Ability to bring prosecutions directly in serious cases.

· Maintain a public register of sanctions against:

· Licensed senior fire officers

· Registered fire-safety engineers and assessors

· Corporate fire authorities (for systemic failures)

This would provide visible, enforceable consequences for operational neglect in a way that does not currently exist.

4. Tightening NFCC Guidance: From “Soft Power” to Legal Instruments

NFCC guidance currently functions as quasi-regulation without corresponding responsibility. A radical model would regularise this:

· Designate certain NFCC guidance as “Statutory Fire Safety Instruments” once approved by the FBSA.

· Require an explicit impact assessment and formal consultation before such guidance is adopted.

· Make non-compliance by fire services with these instruments:

· Presumptive evidence of breach of FSAA duties; and

· A basis for enforcement action against both the service and the responsible senior officer.

This would remove the present ambiguity where NFCC guidance can drive decisions like mass deployment of waking watches, yet all key institutions can disclaim responsibility for the outcomes.

5. Criminal Liability Focused on Systemic Neglect, Not Honest Error

A Singapore-style model must be calibrated to avoid chilling appropriate operational discretion. The aim is not to prosecute every misjudgement under pressure, but to capture:

· Deliberate or reckless disregard of foreseeable risks

· Persistent failure to implement known recommendations or lessons

· Sustained under-provision of training or resources in the face of repeated warnings

Examples of trigger conditions might include:

· Ignoring a national standard requiring evacuation planning for high-rise façade fires;

· Failing, over many years, to implement control room upgrades needed to handle fire survival calls;

· Repeatedly dismissing or sidelining internal and external warnings about unsafe policies or inadequate training.

In such cases, prosecution under the FSAA would target management failures and leadership decisions, not split-second frontline choices.

6. Implications and Trade-Offs

A radical Singapore-style accountability regime for UK fire services would have far-reaching implications:

Culture change

· Senior officers would have to internalise that their signatures, policies and omissions carry personal legal consequences.

· Fire services would need to invest far more heavily in risk assessment, data, and scenario planning.

Professionalisation of fire command

· High-rise and complex incident command could evolve into a recognised, regulated speciality, analogous to surgical sub-specialties or chartered structural engineering.

Improved public confidence

· Survivors and residents could see that failures at the fire-service level are not shielded from scrutiny or sanction, closing an important legitimacy gap exposed by Grenfell.

Risk of over-caution

· Poorly designed, the regime could drive defensive practice and reluctance to innovate. This risk underscores the need to focus liability on systemic neglect and pre-incident preparation, not on good-faith decisions taken in the fog of an unfolding emergency.

Nonetheless, the status quo, where fire and rescue services are uniquely insulated from meaningful legal accountability while everyone else in the building-safety chain faces heightened penalties, is neither sustainable nor just. A Singapore-style model, adapted for UK institutions, offers a coherent way to align power, responsibility and consequence across the whole system.

BSR’s Gateway Regime versus Singapore’s Approach

There is much to be learnt from Singapore in further reform to the BSR given its current shambolic implementation. The BSR is a very slow, very blunt hammer aimed at almost entirely at buildings, while leaving the fire authorities conveniently out of scope. Singapore shows you can have strong safety with clearer rules, faster approvals and much tougher accountability on people doing the work, while also including mandatory façade inspections every 7 years by certified inspectors.

For higher-risk buildings (HRBs), BSR runs a 3-gateway system.

· Gateway 1 is for Planning, where a fire-safety statement is required with the BSR as a statutory consultee.

· Gateway 2 is Pre-Construction. Full-building control approval by BSR before works start.

· Gateway 3 is Pre-Occupation. A certificate at completion from BSR is required before anyone moves in. A classic “stop-go” point. No certificate, no lawful occupation.

Each of these is a hard gate. If BSR is slow, cautious, or overwhelmed at Gateways 2 and 3, projects stall even when their risk is routine and their design is standardised. Crucially, it is all aimed at developers and building control, not at fire authorities.

Singapore’s BCA also runs a staged regime. But it is structured differently. Building plan approval sees proposals go to the Commissioner of Building Control for approval. Clearances from technical agencies, including the fire service, are coordinated. It does not function as a freeze point that stops projects for months or a year, as Gateway 2 currently does in the UK.

Singapore’s building control sequence involves:

1. Submission of building plans by a Qualified Person (QP) i.e. registered architect or engineer

2. Approvals typically within 7 to 20 working days, depending on complexity

3. Construction may commence immediately after approval

4. Continuous inspection regime during construction, done via QPs, accredited checkers, and periodic BCA audits

5. Temporary Occupation Permit (TOP)/ Certificate of Statutory Completion (CSC) approval typically in the order of weeks..

The plan approval stage is fast and predictable so it does not create a construction hiatus. In practice, Singapore’s system is built around three pillars that eliminate bottlenecks:

A. Delegated Professional Accountability (Opposite of UK’s Hyper-Centralisation)

Legal Duty on:

§ Qualified Person, architect or engineer responsible for integrity of design

§ Accredited Checker (independent professional who verifies structural safety), and

§ Builder – responsible for execution

Because professionals, not the regulator, carry legal liability (including criminal liability), the BCA does not micromanage or re-review everything.

This shifts the UK model from regulator must check everything before construction to Singapore’s professionals must be competent and the regulator checks risk-based audits.

B. Statutory Fast Timelines (7 to 20 working days)

Singapore’s BCA guarantees time-bound approvals:

§ Simple Building Plan – 7 working days

§ Complex / Multi-Agency Plans; usually 20 working days

Commitments are actually met because:

§ The system is highly digitised using the CORENET X platform, which coordinates:

· Fire Safety & Shelter Department

· Urban Redevelopment Authority

· Public Utilities

· Environmental agencies

· BCA

· Agencies coordinate concurrently, not sequentially

· Planning and building approvals historically evolved together to avoid duplication

This meant no developer waits up to a year like in the UK BSR system.

C. Construction can proceed after approval with no hidden procedural traps

After plan approval, Singapore does not repeatedly halt construction or operations unless major non-compliance is discovered.

The philosophy is:

· Approve early

· Inspect continually

· Enforce harshly if non-compliance is found

· Hold professionals criminally liable for negligence or misrepresentation

The UK’s system is reversed:

· Inspect late (Gateway 2)

· Approve slowly (months-long backlog)

· Enforce administratively (stop notices)

· Diffuse professional liability

Singapore avoids stop-start construction by pushing responsibility onto those who design and build, not the state. Singapore’s system is designed to catch errors early through continual professional oversight, so stop-orders are rare, and only if serious safety breaches occur.

Recommendations for Reforming the Building Safety Regulator (BSR)

From Stop–Start Paralysis to a Coherent, High-Performance System

The Building Safety Regulator (BSR) was established to ensure that catastrophic failures like Grenfell could never recur. Yet the current Gateway system has produced a new form of systemic risk: regulatory gridlock. With Gateway 2 approvals taking 43–48 weeks on average, nearly 35,000 homes trapped in pre-construction limbo, and developers facing unpredictable compliance pathways, the BSR has become a structural brake on national housing delivery.

Reform must achieve two goals simultaneously:

1. Restore the ability to build safely at pace, and

2. Embed accountability across the entire safety ecosystem; including the fire services.

There are two viable reform pathways: a pragmatic “Stop–Start Fix” that stabilises the current system, or a radical Singapore-style overhaul that replaces the UK’s bottlenecked structure with a fast, accountable, integrated safety regime.

Option 1: Stop–Start Fix – Incremental Reform of the BSR

These measures aim to unblock the current system while retaining its overall architecture.

1. Legislate Statutory Timelines for Gateway Approvals

· Introduce an 8-to-12-week statutory maximum for Gateway 2 decisions.

· Require automatic escalation to senior BSR leadership when deadlines are breached.

· Mandate quarterly public reporting to Parliament on compliance with statutory timeframes.

2. Create a National Digital Portal for Concurrent Reviews

· Replace the slow, sequential approval model with a single digital submission platform enabling simultaneous review by BSR, fire authorities, environmental bodies and structural specialists.

· Deliverable via secondary legislation and ministerial direction.

3. Provide Transparent, Standardised BSR Requirements

· Publish template safety cases, model design submissions and checklists to minimise costly redesign loops.

· Clarify what constitutes “sufficient information” to avoid repeated requests for additional detail.

4. Expand Capacity Through Recruitment and External Reviewers

· Increase the number of BSR fire engineers, façade specialists and building-control experts.

· Authorise accredited independent reviewers for low-risk elements to relieve immediate bottlenecks.

5. Introduce a Risk-Proportionate Approval Pathway

· Establish a Fast Track for standardised, code-compliant designs.

· Reserve enhanced scrutiny for complex buildings or performance-based fire engineering.

6. Mandate Transparent Performance Auditing

· Require annual public reporting on approval timelines, staffing, case throughput and appeals.

· Benchmark BSR performance against global regulators, including Singapore’s BCA.

Impact: a more predictable, faster BSR that relieves the worst delays while maintaining the existing institutional structure. But it does not address the deeper architectural flaws of the UK system, nor the fire-service accountability deficit.

Option 2: Radical Singapore-Style Overhaul - A Structural Redesign of the UK Safety Regime

This pathway fundamentally realigns accountability, responsibility and regulatory function, mirroring the system that allows Singapore to approve building plans in 7 to 20 working days.

1. Replace the Gateway System with Professional Accountability

· Abolish the Gateway 2 freeze and shift to legally accountable professional sign-off by licensed engineers, architects and fire engineers.

· BSR transitions from pre-construction gatekeeper to auditor-enforcer, dramatically reducing delays.

2. Establish an Integrated Fire & Building Safety Authority (FBSA)

· Merge BSR building-control functions with a new statutory regulator for fire services.

· Create dual certification for higher-risk buildings:

1. Building safety compliance

2. Fire-service operational readiness

· Corrects the structural disconnect that allowed fire-service failures to persist unreformed after Grenfell.

3. Introduce Licensing and Criminal Liability for Safety-Critical Professionals

· Require statutory registration for:

· Fire engineers

· Façade engineers

· Senior fire officers responsible for evacuation doctrine

· Gold/Silver incident commanders

· Negligent or reckless declarations become criminal offences, mirroring Singapore’s Fire Safety Act.

4. Adopt Continuous, In-Construction Inspection and Randomised Audits

· Shift from heavy front-loaded approvals to ongoing inspection, ensuring non-compliance is caught early without halting construction unnecessarily.

· Mandate minimum inspection frequencies in statute.

5. Build a Singapore-Style CORENET Digital Ecosystem

· A national, legislated platform integrating:

· Plan submissions

· Multi-agency review

· Licensing

· Construction-phase audits

· Enforcement records

· Ensures transparency, interoperability and a single authoritative dataset.

6. Create a ‘Code-Compliant by Default’ Approval Pathway

· Standardised designs meeting prescriptive codes receive automatic approval unless the regulator flags concerns within a statutory window (e.g., 10 working days).

· Shifts the regulatory presumption from delay to delivery.

7. Legislate Statutory Timeframes Across the System

· Approval windows for compliant designs capped at 7 to 20 working days (as in Singapore).

· Automatic approval if regulators do not respond within statutory deadlines.

· Mandatory inspection cycles during construction.

Impact: a fast, accountable, integrated regulatory model that eliminates stop-start construction, embeds responsibility with professionals, introduces meaningful oversight of fire-service preparedness, and aligns the UK’s building-safety regime with international best practice.

Summary Conclusion for Policymakers

Britain’s post-Grenfell building safety system has created a paradox: hundreds of existing buildings remain unsafe, while thousands of new homes are stalled in a regulatory bottleneck. This situation is neither safe nor sustainable. The UK now faces a strategic choice: persist with a regime that delivers paperwork without outcomes, or reform it into a coherent, high-performance system capable of both protecting lives and enabling housing delivery.

Three imperatives emerge.

1. Accelerate remediation of unsafe buildings.

· The pace remains unacceptably slow, leaving thousands of residents exposed to known risks. Government should treat remediation as a public-safety emergency: deploy dedicated taskforces, fund works upfront where necessary, and recover costs later. Every year of delay is a year of avoidable danger.

2. Reform the Building Safety Regulator to deliver clarity, proportionality and speed.

· The current Gateway process has become a structural brake on development. Legislated approval deadlines, risk-based pathways, and fully digitalised concurrent reviews are essential. A regulator must ensure safety - not halt construction by default.

3. Close the fire-service accountability gap.

· The Grenfell Inquiry exposed systemic operational failings, yet the fire services remain outside the new accountability framework applied to everyone else. A modern system requires statutory oversight of fire-service preparedness, licensing of senior officers, and legal responsibility for critical safety decisions, mirroring international best practice.

The UK now has two clear reform pathways: incremental improvements to stabilise the current regime, or a radical Singapore-style overhaul that integrates building and fire regulation, embeds professional accountability, mandates statutory timeframes, and uses continuous oversight rather than front-loaded bureaucracy. Only the latter fully resolves the contradictions that have paralysed both remediation and construction.

The policy choice is ultimately simple: a system that produces safe buildings, or one that produces delay. To honour the 72 lives lost at Grenfell and protect the millions living in high-rise homes today, the state must adopt a model that delivers safety and delivery, not one at the expense of the other.

The promise of “never again” cannot survive as an uncosted sentiment and an unowned process. It must be built into law: fixed deadlines, named liability, continuous inspection, and fire-service oversight with real teeth. If we will not decide, guidance will, markets will freeze, and residents will keep paying the price.

This is the moment to choose outcomes over delay. And that is the only path forward.

Endnotes

1. Hong Kong races to remove scaffolding nets blamed for fuelling deadly fire[5][7]. Reuters, 4 December 2025.

2. Ibid. Description of arrests and suspects (15 construction firm staff for manslaughter, 6 fire contractor staff for fraud)[7].

3. Ibid. Investigators identify substandard plastic mesh and foam insulation as accelerants; fire alarms failed to operate[8].

4. Ibid. Authorities order immediate citywide removal of scaffolding netting; contractors to bear removal costs[5][6].

5. National Audit Office (NAO) press release via Leasehold Knowledge Partnership: NAO calls cladding crisis a “seven year story of non-starts, false starts… and a desperate failure to admit fault”[27]; up to 60% of dangerous-cladding buildings not yet identified; remediation likely to continue to 2035[26][25]. 30 October 2024.

6. “Cladding disaster will cost £16.6 billion… million people stuck in dangerous homes… 2035 end date…,” Leasehold Knowledge Partnership[25][27]. Reporting NAO findings and Pete Apps estimates (750k–1m people affected).

7. Tribunal orders firms to pay £18m for cladding works at former Olympic Village – Triathlon Homes LLP v. Stratford Village Develop. Partnership, First-tier Tribunal (Property Chamber), 19 January 2024[13][11]. First use of a Remediation Contribution Order (RCO) under the Building Safety Act 2022, a non-fault-based remedy to force developers/owners to fund remediation.

8. Ibid. Tribunal’s reasoning: RCO is an “independent” remedy not requiring proof of fault[11]; policy intent that original developer (and its associates) bear primary cost[18]; Building Safety Fund is last resort[12].

9. Evening Standard – “Owner of Olympic Village flats to pay £18m to fix flammable cladding” (23 Jan 2024). Court ruled Get Living and subsidiary must pay ~£18m; Triathlon Homes calls it a precedent to end delays causing “misery” for residents[20][21]. Get Living “disappointed” at being held liable given it “did not build the development” (not involved in design/construction)[22].

10. Ibid. Defects found in 2020 included combustible insulation in cladding, flammable timber balconies; an independent report put remedial costs at ~£24.5m[15][17]. Tribunal decided it was just and equitable for the current developer/owner (and parent company) to contribute £18m[13][14].

11. Leasehold Knowledge Partnership – NAO report on cladding: total remediation cost ~£16.6bn; taxpayer exposure capped at £5.1bn (with new developer levy and recoveries intended for remainder)[70][71]. Notes government’s efforts (developer pledges, Building Safety Fund) and the slow progress to date.

12. Ibid. Pete Apps on NAO report: first honest assessment of scale of building safety mess; still “far to go”[72]. Apps’ estimate: 750k–1m people in affected blocks (above 11m) still living in crisis[73].

13. The Developer – “Building Safety Regulator delays ‘challenging, frustrating and costly’,” James Wilmore (22 Sept 2025). Reports average Gateway 2 approval time ~36 weeks (vs 12-wk target)[32]; nearly 35k residential units awaiting BSR decisions[33]; only ~30% of cases decided within target timeframe[33].

14. Ibid. Quote from Matt Voyce (Quintain construction director): dealing with BSR has been “challenging, frustrating and costly”[34]. Cites lack of communication and under-staffing at BSR; some housing assoc. schemes waited 42 weeks for approval[74].

15. Ibid. Andy Roe (BSR chair) told Parliament in Sept 2025: without “very significant change” by year’s end, BSR risked “losing the complete confidence of everyone in the regulatory regime”[38]. Government responded by overhauling BSR’s structure and leadership in June 2025[39].

16. UK Government – Written Statement (30 June 2025) on Building Safety Regulator reforms. Announces removal of BSR from HSE to new MHCLG executive agency[39]; appointment of Andy Roe (former LFB Commissioner) as BSR Chair and Charlie Pugsley as CEO[40][41]; introduction of “fast-track” Gateway process to clear backlog[75].

17. Charles Russell Speechlys briefing (Nov 2025) – Updates on BSR backlog clearance. Confirms median Gateway 2 processing times at 43 weeks (UK) and 48 weeks in London[4]; BSR aiming to clear 91 legacy applications (~33,000 housing units) by end of 2025[76]. Quote: Roe noted average wait ~43 weeks, 48 in London[77].

18. BCA Singapore – Building Plan Submission guidelines. States BCA approves standard building plan applications within 7 working days if all clearances in order[3]. Under new integrated CORENET process, joint cross-agency review takes up to 20 working days[45]. (Singapore’s efficient building control vs. UK’s protracted Gateway system).

19. LABC (Local Authority Building Control) guidance – Full Plans applications must be decided within 5 weeks (extendable to 8 weeks with agreement) by local authorities[46]. Pre-2023, this was the typical statutory timeframe for building control approval in England, highlighting the contrast with current BSR delays.

20. House of Lords Industry and Regulators Committee – Oral Evidence (July 2025). Melanie Leech (British Property Federation) on investor confidence: “Investors look at the uncertainties… and they say, ‘Why would I go anywhere near that?’”[31], noting that delays and unclear processes deter investment in new housing. Emphasizes need to restore confidence through faster, predictable regulation[78].

21. Ibid. Discussion on simplifying BSR process for minor works: Dame Judith Hackitt and others agree Gateway requirements could be streamlined for straightforward refurbishments (like fire door replacements) without compromising safety[79][80]. Notes that some 30% of Gateway 2 applications were for lower-risk Category B work being treated same as major new builds[80].

22. Ibid. Allan Binns (developer) stated older BSR approvals took “40 or 50 weeks” but newer cases show some speed-up, with improved engagement and communication from BSR, suggesting the system is learning and times are coming down (with a data lag in reported figures)[81]. Reflects late-2025 anecdotal evidence of BSR improvement.

23. Inside Housing – Peter Apps, “The moral imperative is too great to give up’: Andy Roe on the future of the BSR” (21 Nov 2025). Roe acknowledges criticisms of two ex-LFB leaders heading BSR; says he ran one of UK’s largest fire safety regimes (covering 3.8 million dwellings, 20,000 listed buildings) as LFB chief[53]. Admits “optics” issue but commits to openness, mixed expertise, and proving the value of BSR under his leadership[52][54].

24. Ibid. Roe on Grenfell lessons: recounts standing in front of Grenfell on 14 June 2017 seeing “the profound failure of everyone involved: the fire service, the regulatory system… constructors… managers… and Government itself. That is why the Act exists, and why the BSR exists.”[67]. Emphasizes that other countries manage to build safely at volume, so he “does not accept” there is an inherent trade-off between safety and building more homes[47].

25. Grenfell Tower Inquiry Phase 1 Report (Oct 2019) – Key findings on LFB: “stay put” policy was maintained far too long; Inquiry concluded more lives could have been saved if evacuation was initiated about an hour earlier[82][83]. Notably, “The ‘stay put’ concept had become an article of faith within the LFB… so powerful that to depart from it was… unthinkable”[48]. LFB had no plan for full evacuation of a high-rise, and senior officers were reluctant to consider it even as conditions deteriorated.

26. The Guardian, “Grenfell inquiry: the chair’s findings so far” (30 Oct 2019). Summarizes Moore-Bick’s critique of LFB’s lack of preparation and training: LFB’s planning was “gravely inadequate”; no contingency for building-wide evacuation; incident commanders had no training on risks of cladding fires; experienced LFB officers “had no conception” that a total failure of compartmentation could occur or that mass evacuation might be needed[84][85]. Information on Grenfell in LFB’s risk database was outdated (from 2009) and virtually useless on the night[84].

27. Ibid. Control room failures: emergency operators were overwhelmed by volume of 999 calls, often disbelieved callers’ reports of fire spread, and gave reassurances that help was coming based on personal assumptions rather than evidence[51][86]. Communication between the control room and the fireground was poor, and no live TV feed of the fire was monitored, hampering situational awareness[87]. These systemic command-and-control issues contributed to the disaster response shortcomings.

28. Guardian (Live blog, 5 June 2018) – Opening statements of Grenfell Inquiry Phase 1. Imran Khan QC (for some bereaved families) urged the inquiry to consider “institutional racism” as a factor, noting the disproportionately BAME resident profile of Grenfell and suggesting that the attitudes of the landlord (KCTMO) and council may have reflected racial and class bias[57][58]. The inquiry’s terms of reference did not explicitly include race or class issues, which was a point of contention; Khan likened it to the need for a Stephen Lawrence-style examination of institutional racism[88][89].

29. The Big Issue, “Grenfell survivors faced racism and discrimination in wake of fire, final report confirms” (4 Sep 2024). Notes that the Inquiry’s final Phase 2 report “found no evidence” that racial or social discrimination played any part in causing the disaster[90][59], though it acknowledged many who died were from ethnic minorities. However, the report did find that some survivors and bereaved families experienced racist or insensitive treatment by authorities in the aftermath (e.g. immigration issues, lack of culturally appropriate support)[91][92]. Campaigners like Runnymede Trust strongly disagree with the report’s conclusions, stating Grenfell was “marred at every point by structural and direct racism” and pointing to the broader context that people of colour in the UK disproportionately live in unsafe or poor housing[60]. Justice4Grenfell group criticized that social housing, inequality and discrimination were excluded from the inquiry’s scope, calling the final report’s focus too narrow[93].

30. Home Builders Federation press release – Neil Jefferson, HBF Chief Executive, on BSR reforms (30 June 2025): “We hope [these changes] will reduce the blockages industry currently faces and that [have] seen delivery of high rise developments grind to a halt.” Welcomes new leadership’s track record and industry’s commitment to work with them, in order that the BSR becomes an efficient safety overseer “and not a barrier to the Government’s housing ambition.”[35][94].