The Building Safety Act 2022 and Fabric Specification: What Interior Designers Need to Know
What the Act introduced: A Principal Designer role with legal duties to ensure all design work — including material specification — complies with Building Regulations. Operative from 1 October 2023 for all projects requiring building control approval.
Higher-risk buildings: Residential buildings 18 metres or more in height, or seven or more storeys. Additional, more stringent duties apply to all design work on these buildings.
What this means for fabric specification: Any designer specifying materials in a higher-risk building must be able to demonstrate competence in fire safety compliance. Every fabric specification decision that affects fire safety must be documented and retained as part of the building’s safety case.
Who this applies to: Interior designers, architects, and design-and-build contractors involved in any project requiring building control approval in England.
The Building Safety Act 2022 is the most significant change to the regulation of building design and construction in England since the 1980s. It was enacted in response to the Grenfell Tower disaster and introduced a comprehensive new duty-holder framework, new competence requirements, and a new regulatory body — the Building Safety Regulator (BSR) — with powers to scrutinise and approve higher-risk building work. Interior designers and fabric specifiers are affected by the Act in ways that are not always clearly communicated. This guide explains what the Act requires, what it means for fabric specification decisions, and how to document compliance.
What the Building Safety Act 2022 Does
The Act creates a new regulatory regime for all building work requiring building control approval in England, with additional and more stringent requirements for higher-risk buildings. It does three things relevant to interior designers and fabric specifiers.
First, it introduces a mandatory Principal Designer role for any project with more than one contractor, operative from 1 October 2023. The Principal Designer is responsible for planning, managing, monitoring, and coordinating the design work to ensure compliance with Building Regulations — including fire safety. This is a distinct role from the Principal Designer under CDM Regulations 2015, although the same person or organisation may hold both roles if competent to do so.
Second, it places a duty of competence on anyone carrying out design work. Section 35 of the Act defines competence as having the necessary skills, knowledge, experience, and behaviours. A designer who specifies materials — including fabrics and soft furnishings — in a building subject to the Act must be able to demonstrate that their specification decisions comply with the applicable Building Regulations fire safety requirements.
Third, it introduces a golden thread of information — a continuous, maintained record of design decisions relating to fire safety and structural integrity — that must be created during the design phase, updated through construction, and retained for the life of the building. For higher-risk buildings this is a formal legal requirement. For other buildings the principle of maintaining clear documentation of safety-related design decisions is strongly recommended and increasingly expected by the insurance market.
Higher-Risk Buildings: What They Are and Why They Matter
A higher-risk building (HRB) is defined under the Act as a building of at least 18 metres in height or at least seven storeys, containing at least two residential units. Most tall residential apartment buildings in England meet this definition. Many hotel developments, residential care buildings, and mixed-use developments with residential components also qualify.
For HRB projects, the Building Safety Regulator must approve the design before construction begins at Gateway 2. The Principal Designer must submit a detailed compliance statement demonstrating that the design meets Building Regulations requirements. All duty holders — including designers — must operate a mandatory occurrence reporting system and report any safety occurrence to the BSR.
A safety occurrence is defined as any aspect of the design relating to the structural integrity or fire safety of a higher-risk building that, if built, would present a significant risk of death or serious injury. A fabric specification that does not meet the applicable fire standard — or that uses a topical FR treatment that has degraded without replacement — could in principle constitute a safety occurrence in an HRB context. This is not a theoretical risk. It is the kind of documentation failure that the golden thread requirement is specifically designed to prevent.
What This Means for Fabric Specification
For most interior design projects, the Building Safety Act’s practical impact on fabric specification is not a change in the fire standards that apply — Crib 5, BS 7176, BS 5867 were the applicable standards before the Act and remain so — but a change in the documentation and accountability requirements around compliance with those standards.
Before the Act, a designer who specified a Crib 5-certified fabric for a hotel project was meeting the applicable fire standard. After the Act, that same designer must also be able to demonstrate: that they understood the applicable standard and specified correctly against it; that they obtained a valid test certificate from a UKAS-accredited laboratory; that they documented the specification decision and retained the certificate; and, if the project involves an HRB, that the fabric specification was included in the golden thread information provided to the Principal Designer and ultimately to the building owner.
The practical implication is that fabric specification documentation must be more systematic than it often has been. A verbal instruction to the upholsterer or a purchase order without fire certification reference is no longer adequate for projects subject to the Act. The fire test certificate must be obtained before installation, referenced in the specification document, and retained as part of the project file.
For full guidance on obtaining fire test certificates and what they must cover, see our Crib 5 guide, our hotel fabric specification guide, and our FR treatment guide.
The Principal Designer Role and Interior Design Services
The RIBA/BIID professional services contracts — updated in their 2024 amendments — include an expanded schedule of services that now explicitly references the Principal Designer role under Part 2A of the Building Regulations. An interior designer or architect carrying interior design services within their scope on a qualifying project may be asked to act as, or contribute to the duties of, the Principal Designer.
The 2024 amendment to the RIBA/BIID contracts draws specific attention to the requirement for the designer to assess their competency to undertake the Principal Designer role before accepting it. Interior designers whose practice includes projects in higher-risk buildings should assess whether their competence in fire safety, structural safety, and the golden thread documentation requirements meets the standard required by PAS 8671, the publicly available specification setting out the minimum competence requirements for Principal Designers.
The Golden Thread and Fabric Documentation
The golden thread is a digitally maintained record of design decisions relating to fire safety and structural integrity. For fabric specification in a higher-risk building, it should contain the following for each fire-safety-relevant fabric decision. The fabric description — supplier, range name, colourway, width, and fibre composition. The fire standard the fabric is certified against — BS 7176 Medium or High Hazard, BS 5867 Part 2 Type B or C, or equivalent. The test certificate reference number and the name of the UKAS-accredited laboratory that issued it. The filling and interliner specified with the fabric, as the certificate covers the assembly rather than the face fabric alone. The date of installation and the location within the building. Any re-treatment or re-certification requirement and the recommended review date.
Building this documentation into the fabric specification process at Stage 3 of the RIBA Plan of Work — when specific fabrics are selected and technical data sheets are obtained — adds minimal time and significantly strengthens both legal compliance and the designer’s professional liability position. For guidance on fabric decisions at each RIBA stage, see our RIBA Plan of Work fabric guide.
Liability and the 30-Year Limitation Period
A 2025 Supreme Court ruling in URS Corporation Ltd v BDW Trading Ltd interpreted section 135(3) of the Building Safety Act to extend the limitation period for negligence claims relating to building safety from six to thirty years, including retrospective claims. This means that design decisions made today — including fabric specification decisions that affect fire safety in higher-risk buildings — could be subject to legal challenge for up to thirty years.
The practical implication for fabric specifiers is that the documentation of fire compliance at the time of specification — the fire test certificate, the specification schedule, the installation record — is evidence of due diligence that may need to be relied upon many years after practical completion. Maintaining systematic records of fire certification for all higher-risk building fabric specification decisions is strongly advisable.
What Interior Designers Should Do
Review your specification documentation process and confirm that it captures fire test certificate references, UKAS-accredited laboratory names, and filling and interliner details for every fabric specified in a fire-safety-relevant position. This applies to all contract projects, not only those classified as higher-risk buildings.
For any project that may involve an HRB — a residential building of seven or more storeys or 18 metres or more in height — seek advice from the Principal Designer appointed on the project about what fabric documentation is required as part of the golden thread. If you are the party being asked to act as Principal Designer, assess your competence against PAS 8671 before accepting the role.
Ensure your professional indemnity insurance covers the scope of design services you are providing on BSA-affected projects. The Act has introduced new and more extensive liabilities for designers, and cover that was adequate before 1 October 2023 may need to be reviewed.
When specifying fabric for fire-safety-relevant positions in higher-risk buildings, prefer inherently fire-resistant fabrics over those requiring topical FR treatment. Inherent fire resistance does not degrade with cleaning or over time and does not require re-certification during the building’s life. See our FR treatment and fibre compatibility guide for guidance on which fabrics carry inherent certification.
Frequently Asked Questions
Does the Building Safety Act apply to all interior design projects?
The duty-holder framework applies to all projects requiring building control approval in England where there is more than one contractor, from 1 October 2023. The additional and most stringent requirements apply to higher-risk buildings — residential buildings of at least 18 metres in height or at least seven storeys containing two or more residential units. Most interior refurbishment projects of individual apartments do not require building control approval and are not directly caught by the Act. Commercial fit-outs, whole-building refurbishments, and new build projects with residential use at seven or more storeys are more likely to be affected.
What fire standards apply to fabric in higher-risk buildings?
The Building Safety Act does not introduce new fire standards for fabrics. The applicable standards remain BS 7176 for upholstered seating, BS 5867 for curtains, and the Regulatory Reform (Fire Safety) Order 2005 for the responsible person’s ongoing fire safety obligations. What the Act changes is the documentation and accountability requirements around compliance with those standards — specifically the requirement to maintain a golden thread of fire safety design decisions for higher-risk buildings.
What is the golden thread and what fabric information does it need to contain?
The golden thread is a digitally maintained record of design decisions relating to fire safety and structural integrity. For fabric specification in a higher-risk building, it should contain the fabric description, the fire certification standard and certificate reference, the UKAS-accredited laboratory name, the filling and interliner details, the date and location of installation, and any re-treatment requirements. This information must be maintained for the life of the building.
Can an interior designer be the Principal Designer under the Building Safety Act?
Yes, if they have the necessary competence as defined by PAS 8671. An interior designer appointed as lead designer on a project with more than one contractor must assess whether their competence in fire safety, structural safety, and documentation management meets the standard required. For HRB projects, the competence requirements are more demanding and formal competence assessment against PAS 8671 is advisable before accepting the appointment.
For fire certification standards and test certificates, see our Crib 5 guide. For fabric documentation at each RIBA Plan of Work stage, see our RIBA Plan of Work fabric guide. For FR treatment and inherent fire resistance, see our FR treatment and fibre compatibility guide.
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