The Golden Thread Explained: What the Building Safety Act 2022 Means for Council Estates

The Golden Thread Explained

In 2018, Dame Judith Hackitt’s review into building safety emphasised how easily critical information can be lost, scattered or simply never recorded.

The Building Safety Act 2022 changed that, making the golden thread a statutory obligation.

For council estates with high-rise residential blocks built across different decades, under different regulations, and passed between contractors, housing associations and in-house teams along the way, getting this right is rarely straightforward.

This article covers the higher-risk building regime in England. During occupation, a building is generally in scope if it is at least 18 metres high or has at least seven storeys, and contains at least two residential units. Detailed rules govern how certain types of buildings, height and storeys are assessed, and certain types of building are excluded during this phase of the property's lifecycle. The definition also differs between the design-and-construction and occupation phases.

At SFG20, we work with local authorities and housing providers across the country to help them manage their compliance. Here’s what the golden thread duty actually involves, who’s responsible for it, and what it means for landlords and residents.


What is the Golden Thread and Why Does it Exist?

The Building Safety Act 2022 followed the independent review led by Dame Judith Hackitt, commissioned after the Grenfell Tower fire. That review identified a recurring problem: building safety information was often incomplete, filed across different formats, inaccurate, or simply lost over a building’s lifetime, particularly where it had been through multiple handovers. When it mattered most, no single, reliable record existed of how a building had been designed, what materials it contained, how its safety was being managed, or who was accountable.

The golden thread is the response to that problem. In plain terms, the golden thread, also known as the golden thread of information, is an accurate and accessible digital record of the critical safety information about a building, maintained and updated throughout its lifecycle, from design and construction, through to occupation and management.

The legal requirements are spread across the Building Safety Act 2022 and supporting regulations. Requirements applying during the design and construction of higher-risk buildings came into force on the 1st of October 2023. The occupation-phase duties for Accountable Persons, including those under Section 88 of the Act and the 2024 information regulations, came into force on the 16th of January 2024.


Does the Golden Thread Apply to Every Building?

The golden thread duty is targeted at "higher-risk buildings" (HRBs), so the first practical step for any landlord is to work out whether a given block is actually in scope.

    Under Section 65 of the Act, a building qualifies during its occupation phase if it is:
  • at least 18 metres tall, or has at least seven storeys; and
  • contains at least two residential units.

Some building types, including care homes, hospitals and hotels, are generally excluded during occupation.

For council estates, this usually means the mid- and high-rise residential blocks that make up a large part of social housing in large towns and cities, while low-rise terraced or street-level housing typically isn’t.

It’s important to note that the golden thread isn't simply another compliance requirement. It underpins the safety case for councils, demonstrates regulatory compliance, supports maintenance planning and provides evidence that building safety risks are being actively managed.

Council building 2


What Does the Golden Thread Have to Contain? 

It helps to stop thinking of the golden thread as a single document. It's closer to a structured, digital record that provides a single source of truth for everyone responsible for a building throughout its lifecycle. This includes:

  • How the building was designed and how those choices were made
  • The products, materials and systems installed
  • The methods of construction
  • The plant and equipment installed
  • The operation and maintenance information needed to keep it all safe over time
  • How critical systems are maintained
  • Significant changes made during occupation

The legislation doesn't prescribe a particular software or format. What it does require is that the information is kept digitally, stored securely, kept up to date, and made accessible and understandable to the people who need it. The precise list of what must be held (specifically regarding information that Accountable Persons and Principal Accountable Persons must keep during occupation) sts in Schedule 1 of the Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2024.

For many landlords, this overlaps significantly with the work of building and maintaining a built asset register.

A reliable asset register can support the golden thread, particularly by providing accurate information about relevant plant, equipment and maintenance activity. However, it is only one part of a much wider body of design, construction, risk-management and building-safety information.

It's also important to understand that the golden thread is an active duty, not a filing exercise. As we’ll explore next, those responsible have to seek out missing information, correct inaccuracies, and update records whenever the building or its safety arrangements change.

During design and construction, golden thread information supports the building control and completion certificate processes, including the stage commonly referred to as Gateway Three. This is the final post-construction checkpoint where the Building Safety Regulator (BSR) inspects this accumulated data and approves a completion certificate before the building can be occupied. During occupation, it supports the assessment and management of building safety risks and provides evidence for the safety case report. 

Failure to meet these duties can result in regulatory enforcement and, in some circumstances, prosecution. In particular, failure to transfer required information when responsibility changes can lead to a fine, imprisonment or both.


Who is Responsible for the Golden Thread of Information? 

This is where the detail matters most for council estates.

During the design and construction of new work, the duties fall on the dutyholders, principally the client, the principal designer and the principal contractor.

Once a building is occupied, responsibility shifts to Accountable Persons (APs):

  • An Accountable Person is an individual or organisation that owns, or has a relevant legal obligation to repair, any of the common parts of an occupied higher-risk building. This may be a local authority or housing association, although the building’s ownership, lease and repairing arrangements determine who holds the role.

  • Every higher-risk building has a Principal Accountable Person (PAP). Where there is only one AP, that person is also the PAP. Where there are several APs, the PAP is generally the AP responsible for the building’s structure and exterior. Each AP must keep and share information relating to the parts of the building for which it is responsible. The PAP has additional whole-building duties, including registration, preparing and updating the safety case report and resident engagement strategy, and overseeing key building-wide systems.

The Building Safety Regulator

The regulatory landscape itself has also just changed. The Building Safety Regulator (BSR) was originally set up inside the Health and Safety Executive, but on 27 January 2026, it moved out of the HSE to become a standalone public body sponsored by the Ministry of Housing, Communities and Local Government.

The government has framed this as a first step toward a single construction regulator, a lead recommendation of the Grenfell Tower Inquiry's Phase 2 report. The underlying duties have not changed, but the BSR now operates as a dedicated standalone regulator as the government develops its plans for a single construction regulator.


What Does This Mean for Council Estates and Residents? 

For councils and housing associations managing older buildings, the hardest part of the golden thread is often just the starting point.

Estates built decades ago rarely come with complete, accurate, digital records of their design, materials and modifications. This is because years of repairs, refurbishments and partial handovers tend to leave documentation patchy.

APs must take reasonable steps to locate missing information, correct known inaccuracies and keep the golden thread up to date. Where historic information cannot be obtained, they should be able to explain the gap and demonstrate how building safety risks are nevertheless being assessed and managed.

Rather than simply record what already exists, many landlords are facing a real exercise in surveying, gathering and validating data.

For buildings with long maintenance histories, that often starts with fixing the underlying asset register before the golden thread itself can be built on top of it. The regulations also give residents a clearer role and much more visibility. The Principal Accountable Person must:

  • Prepare and maintain a resident engagement strategy setting out how residents will be informed and involved in building safety decisions.
  • APs and the PAP must provide residents and owners with prescribed building safety information and respond to qualifying requests for further information.

This shift matters. SFG20’s own Building Safety Survey found that resident confidence in building safety is still rebuilding post-Grenfell - and a well-maintained golden thread, properly communicated, is one of the clearest ways landlords can demonstrate they’re on top of it.

Council building 1


Don’t Get Caught Out by the Golden Thread Duty 

The golden thread is both a compliance obligation and a practical safety tool. Meeting it comes down to clear accountability, reliable digital record-keeping, and treating safety information as an ongoing record rather than a tick box exercise.

The buildings most affected are exactly the ones where complete, accessible safety information matters most, and where, historically, it has too often been missing.

If you’re managing council housing and want a clearer view of how to run an efficient council estate to achieve compliance and safety, our e-guide is a good place to start. Or take a look at how SFG20 supports councils and local governments in keeping their buildings compliant and audit-ready.