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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Fabric Specification at Each RIBA Plan of Work Stage

The key decision points: Stage 2 establishes palette and mood. Stage 3 fixes performance requirements. Stage 4 produces the procurement specification. Stage 5 manages delivery and installation.
The most common error: Leaving detailed fabric specification to Stage 4 without having confirmed fire standard, Martindale requirements, and cleaning compatibility at Stage 3. Late changes at Stage 4 cause programme delay and cost increase.
For architects: The RIBA/BIID contract schedule of services explicitly covers FF&E specification. Understanding where fabric decisions sit in the Plan of Work helps coordinate the design team’s responsibilities.

The RIBA Plan of Work is the standard framework for organising building projects in the UK, used by architects, interior designers, contractors, and clients to structure the design and construction process from inception to completion. It divides a project into eight stages numbered 0 to 7. Fabric specification decisions are made at different stages with different levels of detail and different commercial consequences. Understanding which decisions belong at which stage prevents the most common fabric specification failures: late changes that cause cost overruns, incomplete fire certification documentation at handover, and procurement without confirmed dye lot availability.

This guide is relevant to both interior designers using the RIBA Plan of Work as a project framework and to architects who carry interior design services within their scope under the RIBA/BIID professional services contracts.

Stage 0: Strategic Definition

Stage 0 is the briefing stage, before the design team is formally appointed. Fabric specification is not a Stage 0 activity, but the strategic brief established at this stage determines the fabric specification constraints that will apply throughout the project.

Key questions that should be answered at Stage 0 and that directly affect later fabric decisions include: Is the building subject to specific fire safety regulations beyond standard Building Regulations — a hotel, a healthcare facility, a licensed premises? Will the interior be maintained by in-house staff or a facilities management contractor, and what are their cleaning capabilities and product preferences? What is the refurbishment cycle — how long must the interior last before planned replacement? Are there sustainability or environmental certification requirements for the project?

These answers will constrain the fabric specification options available at later stages. A project requiring BREEAM Excellent with Oeko-Tex or GOTS certification requirements for textiles should establish this at Stage 0, not discover it during Stage 4 procurement when the chosen fabric ranges may not hold the required certifications. For sustainability certification guidance, see our fabric sustainability certifications guide.

Stage 1: Preparation and Briefing

Stage 1 develops and finalises the project brief. For projects with significant interior design content, Stage 1 should establish the performance requirements that will govern fabric specification at later stages. This is not a stage for selecting specific fabrics, but it is the correct stage to establish the specification envelope within which fabric selection will occur.

Establish the fire standard applicable to each area of the building at Stage 1. For a hotel this means confirming the applicable BS 7176 hazard category for each room type. For a healthcare project it means confirming the HTM 05-03 requirements and the relevant BS 7176 hazard category. For guidance on fire standards, see our Crib 5 guide and hotel fabric specification guide.

Establish the Martindale rub count requirement for each area at Stage 1. The Martindale threshold is a function of the anticipated use intensity. See our Martindale rub test guide for threshold recommendations by room type.

Establish the cleaning regime requirements at Stage 1. Confirm with the client or facilities team what cleaning products will be used in each area, how frequently, and who will apply them. This information is essential for fabric cleaning code compatibility assessment at later stages.

Stage 2: Concept Design

Stage 2 is where the design concept is established and the spatial, material, and aesthetic language of the project is defined. Fabric decisions at Stage 2 are directional rather than specific. The concept palette might establish that lounge seating will be in a warm neutral mohair velvet, dining chairs in a deep blue contract textile, and bedroom headboards in a coordinating soft texture. These are design direction statements, not procurement specifications.

The Stage 2 concept design report should note — even at this directional level — which areas will require Crib 5 certified fabrics, which will require specific Martindale thresholds, and which will require specific cleaning code compatibility. This ensures the Stage 3 specification work begins with the performance envelope already established.

At Stage 2, initiate contact with key fabric suppliers to confirm that fabrics in the intended style and performance category are available within the project budget range. A concept that requires 100,000 Martindale mohair velvet in 40 colourways from a single supplier that does not offer that performance level will fail at procurement regardless of how well it is designed. Early supplier engagement at Stage 2 prevents this.

Stage 3: Spatial Coordination

Stage 3 is the most important stage for fabric specification. This is where specific fabrics are selected, performance criteria are confirmed against the Stage 1 brief, and the information required for cost planning and procurement is assembled. Errors or omissions at Stage 3 are the primary cause of fabric specification failures at Stages 4 and 5.

Confirm the specific fabric range, colourway, and width for every fabric in the scheme at Stage 3. Obtain the relevant technical data sheets from the supplier and confirm that each fabric meets the performance requirements established at Stage 1. For fire rating, obtain the test certificate — not just a supplier’s statement of compliance — and confirm that it covers the filling and construction being used in the specific project. For Martindale, confirm the rub count for the specific colourway ordered, not just the range average.

Obtain sample cuttings and confirm sample availability for mock-up testing if required. For large-scale hospitality or commercial projects, testing a mock-up panel or sample assembly to the required fire standard before committing to procurement is standard practice and eliminates certification risk at Stage 5.

Confirm lead times for every fabric at Stage 3 and identify any long-lead items. Specialist fabrics, bespoke colourways, and fabrics from European mills with minimum order requirements may have lead times of twelve to sixteen weeks or more.

Produce a fabric schedule at Stage 3. The schedule should list every fabric in the scheme with its supplier reference, colourway, width, fire certification reference, Martindale count, cleaning code, lead time, and the locations in the building where it will be used.

Stage 4: Technical Design

Stage 4 converts the Stage 3 fabric schedule into procurement specifications — quantities, dye lot requirements, delivery programme, and coordination with the upholstery and curtain making workrooms.

Calculate fabric quantities at Stage 4 using confirmed cut sizes, seam allowances, and — critically — pattern repeat allowances for any patterned fabric in the scheme. See our pattern matching guide for the correct method of calculating pattern repeat allowances. Ordering without pattern repeat allowance is the single most common fabric quantity error and is discovered only when the workroom runs short.

Confirm dye lot availability with suppliers at Stage 4 before issuing purchase orders. For large quantities of a single colourway — a hotel project requiring 800 metres of a specific mohair velvet — confirm that the required quantity can be produced in a single dye lot. Dye lot variation between separately produced batches of the same colourway is visually detectable and will not be acceptable in a high-quality interior.

Coordinate the fabric delivery programme with the upholstery and curtain making workrooms at Stage 4. For upholstery, allow a minimum of four to six weeks between fabric delivery and installation for standard pieces. For complex bespoke upholstery, allow eight to twelve weeks. Build these lead times into the Stage 4 programme and work backward from the site installation date to establish the required fabric order date.

Stage 5: Manufacturing and Construction

Stage 5 is the construction and manufacturing stage. The designer’s role at Stage 5 is quality assurance and programme management rather than specification — the specification was established at Stages 3 and 4.

Inspect fabric on delivery to the workroom before cutting begins. Check the colourway against the approved sample under the lighting conditions of the finished room. For guidance on colour matching and metamerism, see our colour naming and specification guide. Check for any visible defects in the fabric surface. Check that the dye lot reference matches the order. Defects identified before cutting are the supplier’s responsibility to remedy.

Obtain all fire certificates and technical data sheets at Stage 5 and compile them into a building user guide or handover file. For commercial buildings, the Regulatory Reform (Fire Safety) Order 2005 requires the responsible person to be able to demonstrate that all furnishings comply with the applicable standards. The test certificates are the evidence of compliance and must be retained throughout the life of the installation.

Stage 6: Handover

Stage 6 is practical completion and handover to the client. The fabric-specific deliverables at Stage 6 are the fire certification documentation compiled at Stage 5, the fabric schedule updated to reflect the as-installed specification including any late changes, cleaning and care instructions for every fabric in the scheme, the supplier contact details for future reorders, and a maintenance schedule specifying when FR certification should be reviewed.

Frequently Asked Questions

At what RIBA stage should I select specific fabrics?

Specific fabric selection — confirming the range, colourway, and technical data for each fabric — belongs at Stage 3. The design direction is established at Stage 2 and the procurement details are fixed at Stage 4, but Stage 3 is where the specific selection must be confirmed and tested against the performance requirements established at Stage 1. Leaving specific fabric selection to Stage 4 compresses the time available to identify and resolve problems with fire certification, Martindale counts, and lead times.

When should I order fabric for a large project?

Calculate the required order date by working backward from the site installation date. Allow for workroom production time — typically four to eight weeks for upholstery and curtains. Allow for fabric delivery from the supplier — typically two to four weeks for stock fabrics, up to sixteen weeks for made-to-order or specialist fabrics. Add the pattern repeat allowance calculation time. On a large hospitality project, the fabric order may need to be placed at or immediately after Stage 4 completion to meet a Stage 5 installation programme.

What documents should I hand over to the client at Stage 6?

Fire test certificates for all upholstered seating and curtains, cleaning and care instructions for each fabric in the scheme, the as-installed fabric schedule with supplier references and colourway codes for future reordering, and a note of any re-treatment or re-certification requirements during the life of the installation. The responsible person for the building requires the fire certificates to demonstrate compliance under the Regulatory Reform (Fire Safety) Order 2005.

For Building Safety Act 2022 documentation requirements across all RIBA stages, see our Building Safety Act and fabric specification guide.

For fire certification guidance, see our Crib 5 guide and hotel fabric specification guide. For Martindale thresholds by room type, see our Martindale rub test guide. For pattern repeat allowance calculation, see our pattern matching guide.

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