Aipedia: Building control approvers

AI review of Gateway 2 applications

Aipedia, by the Apex broking team · Last reviewed 2026-10-30

AI can help triage the thousands of pages in a higher-risk building application, but the inspectors and specialists assessing it for BSR remain accountable for their recommendations. A missed non-compliance in a Gateway 2 review is a serious exposure.

Part of: AI in building control approvers

In short

For higher-risk buildings, BSR is the building control authority and assesses building control approval applications, often called Gateway 2, using multidisciplinary teams that include registered building inspectors. Applications can run to thousands of pages, so AI summarisation and compliance-checking tools are attractive. The RBI code still applies: only class 3 category H inspectors are registered for HRB work (Annex 4), work beyond competence must be supervised (3.3), and each inspector is accountable for recommendations (4.2). Security-sensitive and golden thread information also needs careful handling.

How AI is used in Gateway 2 review

Under the higher-risk building regime, work on HRBs needs building control approval from BSR before it starts. Applications include design and building work drawings, fire and emergency files, competence declarations, construction control plans and many supporting reports. Reviewers drawn from local authorities, RBCAs and specialist disciplines assess them for BSR.

AI tools can index the documents, summarise each report, cross-reference the fire strategy against the drawings and list apparent gaps. A construction trade title reported in February 2026 that one developer of an AI compliance checker for Building Safety Act submissions wanted to run an exercise with BSR; any time savings claimed are the developer's own figures. BSR has published no guidance on AI in its own assessment process. On 9 July 2026 it announced a more proportionate and targeted approach to HRB assessments.

The duties that apply

The relevant duties are:

RBI code 3.1 and Annex 4: HRB work is within class 3 category H registration, covering all building types with no height limits, including HRBs.
RBI code 3.3 and 3.6: work beyond your competence must be supervised, and supervisors must ensure the competence of those they oversee.
RBI code 4.2 and Annex 1.2: accountability for recommendations, and records showing how they were reached.
RBI code 4.5: enough time and resources to do the work, which AI triage cannot replace.
Information rules: the Higher-Risk Buildings Procedures Regulations 2023 (regulation 31) deal with golden thread and security-sensitive information.

See the RBI code of conduct.

What can go wrong

Summaries lose detail by design. A summary of a fire strategy may correctly state the evacuation approach but omit an assumption about sprinkler coverage that the drawings contradict. Cross-referencing tools may match document titles without detecting that a structural report relates to an earlier scheme. Submissions may themselves be partly AI-written; CROSS-UK Report 1554 suggested approving authorities may wish to ask how far AI contributed.

Illustrative: a reviewer uses an AI tool to summarise the fire and emergency file for a residential HRB and to compare it with the drawings. The summary reports consistent compartmentation. The reviewer recommends approval with conditions. During construction, a discrepancy appears between the stair pressurisation design and the strategy, requiring redesign. The applicant complains about delay and cost, and the review file shows reliance on the summary rather than on the underlying report.

How PI usually responds

Where a reviewer works for BSR through an employer or contract, how liability falls depends on those arrangements, so check who carries the risk and whether your PI covers that role. For RBCAs and self-employed RBIs, a negligence allegation is usually handled under PI subject to the terms, and HRB work is commonly subject to specific underwriting questions and fire safety restrictions. Insurers may ask whether you undertake HRB assessment and how AI is used. See does building control PI cover AI errors?.

Practical controls

Practical controls include:

Read the fire strategy and structural reports in full; use summaries only for navigation.
Record which documents and versions were reviewed, and by whom.
Keep AI triage within the competence of the reviewer, and escalate specialist issues.
Check that the AI tool and its hosting are approved for security-sensitive material.
Ask the applicant how far AI contributed to key design documents.
Note in your recommendation any matters not fully reviewed.

The applicant's side is covered in AI in Gateway 2 applications for principal designers. See also AI plans assessment, AI and applicant confidentiality and the AI in building control hub. Apex arranges PI for building control professionals, and a broker can check how your policy treats HRB work and AI-assisted review.

Sources

Frequently asked

Who can assess Gateway 2 applications?

BSR is the building control authority for higher-risk buildings and uses multidisciplinary teams. Under the RBI code, HRB work falls within class 3 category H registration, and anyone working beyond their competence must be supervised. AI tools do not change those registration limits.

Has BSR said anything about AI in Gateway 2?

The BSR had published no guidance on AI in Gateway 2 assessment as at October 2026. BSR announced a more proportionate and targeted approach to HRB assessments on 9 July 2026, but that announcement does not address AI.

Can I put HRB applications into a public AI tool?

Treat this with great care. HRB applications can contain security-sensitive information, and the 2023 HRB procedures regulations deal with golden thread and security-sensitive information. Confidentiality duties in the RBI code also apply, so use only approved, secure tools.

Should reviewers ask whether AI wrote parts of an application?

The CROSS-UK safety panel, in Report 1554 of 16 July 2026, said approving authorities may wish to ask how far AI contributed to submissions and that designers should disclose AI-assisted outputs. This is a panel view, not a BSR rule, but it is a sensible question on complex HRB applications.

Check your PI covers how you use AI

Tell us about your firm and the work you do. A broker will review how your current PI treats AI-assisted work, or arrange new cover. No fee for a quote. Or call 0117 325 0027.

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Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales, company number 07014570. This page is general information about how AI is used in the profession and how insurance may respond. It is not legal, regulatory or insurance advice on your circumstances, and it does not guarantee that cover will be available or on what terms.