Third Grenfell progress report – Key developments and implications
The Government’s Third Grenfell Progress Report, published on 17 December 2025, sets out a series of significant reforms designed to reshape the UK’s building safety landscape (Read the progress report here). Alongside the report, the Government published the Single Construction Regulator prospectus, fire engineering reform documents, and the review of the higher‑risk building (HRB) definition. Together, these publications provide a clearer direction of travel for regulatory change across the construction and real estate sectors.
This briefing summarises the key developments and highlights what clients should be preparing for.
The Government is moving ahead with plans for a new, integrated construction regulator, which is expected to combine the functions of both the Building Safety Regulator (BSR) and the National Construction Products Regulator (NCPR).
Key features include: Oversight of all construction products, not limited to those used in buildings, but including those used in infrastructure such as transport, energy, schools, hospitals, and prisons.
The new Single Construction Regulator is expected to take on regulation of building control, potential licensing of building control professionals and monitoring how building regulations operate in practice. This aims to move building control to an enforcement-led rather than advisory function.
Timeline:
- Consultation closes: 20 March 2026
- Government response: Summer 2026
- Legislation: 2027
- Regulator established: 2028 to 2029
Implication: A more centralised and comprehensive regulatory system is anticipated to oversee both construction activities and product compliance.
Following earlier recommendations, the Government is proposing a complete overhaul of the construction products system, including:
- Licensing of conformity assessment bodies
- Introduction of statutory codes and strengthened product certification
Timeline:
- White Paper due before Spring 2026
- Legislative programme between 2027 and 2029, with implementation beginning once the new regulator is operational
Implication: Manufacturers, suppliers, and contractors should anticipate more stringent product assurance requirements and begin assessing their supply chain readiness.
Despite concerns that a height‑based definition is overly simplistic, the Government has confirmed no immediate change to the definition based on the evidence available. However, the issue remains under active review, with a pledge for the definition to be reviewed at least once a year. The Government also notes that a review of the Building Safety Act 2022 will be undertaken at the 5-year mark, in 2027 (which looks likely to include consideration of the HRB definition and whether this is sufficient to protect vulnerable people).
Implication: Continue to apply the current HRB criteria but remain alert to future refinements, particularly those considering vulnerability of occupants and building use.
Fire‑related functions previously split across Government departments have now been consolidated within the Ministry of Housing, Communities and Local Government (MHCLG). Staff transfers are complete, with budget transfer pending Parliamentary procedure.
Implication: Clients can expect more consistent policy development and regulatory oversight in fire safety matters.
Two major reforms are advancing:
a) Fire engineers
The Government published the Fire Engineers Authoritative Statement, supported by a Next Steps Document. This was in direct response to several recommendations on professional competence. It is expected that:
- Professional standards and competency requirements become more stringent
- Government will engage with academia and industry to define core competencies
Consultation is planned for 2026 and legislation to follow from 2027 to 2029.
b) Fire risk assessors
- Mandatory independent verification of competency by a UKAS‑accredited body.
Consultation is planned for early 2026, with legislation and accreditation framework expected between 2027 and 2029.
Implication: Greater and more prescriptive standards on competence should be expected. Firms should review existing competencies and begin planning for upgraded qualification and accreditation requirements.
The Government intends to introduce a requirement for principal designers to confirm design compliance with building regulations as part of Gateway 2 applications, and explain how these duties were fulfilled at the end of their appointment.
Timeline: A voluntary interim scheme is being developed as a pathway to future mandatory certification obligations Further engagement with stakeholders is planned for 2026, with legislation possible between 2027 and 2029.
Implication: The heightened statutory duties and the need for certification will likely increase both the risk profile and the evidential burden on principal designers, likely resulting in higher insurance costs, more detailed policy terms, and a greater focus on compliance management and record-keeping. Insurers will expect principal designers to demonstrate robust systems for ensuring compliance and for documenting the steps taken to fulfil their statutory duties.
A mandatory licensing scheme will be introduced for principal contractors carrying out HRB construction or refurbishment. A review of the wider dutyholder regime is underway, with findings expected to be published in 2026.
Timeline: The legislative process is planned for 2027 to 2029, followed by implementation from 2028 to 2029.
Implication: The scheme will raise the bar for entry, competence, and accountability. Principal Contractors should monitor developments to ensure future compliance to obtain the licence. Increased regulatory scrutiny is likely to result in enhanced insurance requirements, and a greater emphasis on continuous professional development.
A new advisory panel is assessing the future of building control, including whether certain functions should move to a national authority.
Timeline: The panel’s report is due in the coming months, with the Government response expected in 2026.
Implication: The potential move to a national authority could significantly affect approval timelines but likely to standardise procedures.
The Government acknowledges practical challenges, particularly delays in obtaining BSR approval for routine works, and will consult in 2026 on proportionality improvements.
Implication: Opportunities may emerge to streamline approvals for certain categories of HRB work.
Summary
Substantial regulatory reform is underway, much of which will have material implications for the construction industry, developers, infrastructure providers, and public sector bodies. The period from 2026 to 2029 will be particularly significant as consultations conclude and primary legislation is introduced.
The first annual Parliamentary Report on building safety progress is expected in February 2026. Those within the construction sector should pay close attention to its findings, as it will act as an early indicator of the Government’s legislative priorities and the likely speed of implementation across the 2026 – 2029 reform window.
For more information or support in relation to these reforms, please get in touch with Li Yen Lim or Oliver King in our Construction & Engineering team.
The content of this page is a summary of the law in force at the date of publication and is not exhaustive, nor does it contain definitive advice. Specialist legal advice should be sought in relation to any queries that may arise.
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