Aipedia: Principal designers and building safety

AI in Gateway 2 applications

Aipedia, by the Apex broking team · Last reviewed 2026-10-27

AI can speed up drafting a Gateway 2 application, but every statement must match the current design and stand up to Building Safety Regulator assessment. For principal designers, an inconsistent package can mean a failed application, delay and a claim from the client.

Part of: AI in principal design and building safety

In short

Building control approval applications for higher-risk buildings are made under SI 2023/909 reg 4 for new HRBs and reg 12 for work to existing ones. They must include documents such as the compliance statement, fire and emergency file, construction control plan and change control plan. AI tools can draft and cross-reference these quickly, but they can also produce fluent text that does not match the drawings. Under Part 2A reg 11M the PD coordinates design work so it would comply, so checking that the package is consistent remains a human task.

How AI is used on Gateway 2 packages

A building control approval application for a higher-risk building (HRB), often called Gateway 2, is a large document set. PDs may be asked to prepare or coordinate much of it. AI tools are being used to:

draft the Building Regulations compliance statement from specifications and design reports;
summarise the fire strategy into the fire and emergency file;
generate construction control and change control plans from templates;
check that every required document is present and that cross-references match.

The appeal is speed on a deadline. The risk is text that reads well but describes a design that does not exist. The AI for principal designers overview explains where this sits among other PD uses of AI.

The duties that apply

SI 2023/909 reg 4 (new HRBs) and reg 12 (work to existing HRBs) set out what an application must contain. Regulation 4 lists the accompanying documents: plans, a competence declaration, construction control plan, change control plan, mandatory occurrence reporting plan, Building Regulations compliance statement, fire and emergency file and, where relevant, a partial completion strategy.
Schedule 1 describes those documents. The compliance statement must explain the design approach and why it ensures compliance; the competence declaration is signed by the client.
Part 2A reg 11M: the PD must plan, manage and monitor design work and coordinate it so the design would comply if built.
Reg 11K: designers must provide sufficient design information and report compliance concerns to the PD.

The CROSS-UK Report 1554 panel suggested approving authorities may wish to seek clarity on how far AI tools contributed to submissions. Apex's guide to the higher-risk building regime summarises the wider approval process.

What can go wrong

Illustrative scenario. A PD uses an AI tool to draft the compliance statement and fire and emergency file for a residential building. The tool works from an early design report. A later revision changed the external wall build-up and the smoke ventilation approach, but the drafted documents still describe the earlier design. The inconsistency is picked up during assessment, the application is not approved as submitted, and the programme slips while the package is revised. The client alleges the PD failed to coordinate the submission and claims delay costs.

Other common failure modes:

generic narrative that could describe any building, with no link to the drawings;
references to standards or guidance editions the design team did not use;
a change control plan describing a process the project does not follow;
confident statements of compliance with no supporting evidence.

The BSR publishes quarterly building control approval data, which gives a sense of how applications are progressing.

How PI usually responds

A claim for redesign and delay costs caused by a deficient submission is usually framed as professional negligence, so a PD's PI would commonly respond, subject to the policy terms. Points to watch:

losses that arise only from contractual promises, such as programme guarantees, may fall outside cover depending on the wording;
HRB and fire safety work may be subject to restrictions or aggregate limits, so check how these apply to submission errors;
insurers may ask about HRB and cladding work at proposal stage; see proposal form disclosure for HRB and cladding work.

There is no statutory PI requirement for PDs, so the limit and scope depend on your profession's rules and the appointment.

Practical controls

Fix the design revision the package is based on and record it on every document.
Have a named person check each AI-drafted statement against the current drawings and specifications.
Cross-check the fire and emergency file against the fire strategy line by line (see AI review of fire strategies).
Strip out generic text that is not specific to the building.
Keep a note of which documents AI helped draft, so you can answer the question if asked.
Make sure the golden thread holds the same versions that were submitted (see AI and golden thread information).
Check that design coordination outputs feeding the package are reliable (see AI design coordination).

How Apex helps

Apex arranges PI for principal designers working on higher-risk buildings. A broker can check how your policy treats HRB submissions and fire safety work, and how to describe AI-assisted document preparation to insurers.

Sources

Frequently asked

Who is responsible for a Gateway 2 application?

The application is made by the applicant, usually on the client's behalf, and the competence declaration is signed by the client. The PD is commonly responsible for coordinating the design content, and reg 11M requires the PD to coordinate design work so the design would comply.

Do I have to tell the BSR that AI drafted parts of an application?

There is no legal requirement to do so. The CROSS-UK panel suggested approving authorities may wish to ask how far AI contributed, so keep a record of AI involvement and be ready to explain how outputs were checked.

Can AI check that an application is complete?

It can help confirm every listed document is present and cross-references match. Completeness is not consistency: a person still needs to confirm that the documents describe the current design and agree with each other.

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.