Gateway 2 and the New Building Safety Levy: What Consulting Engineers Should Plan For

What the regulator’s figures show

The Building Safety Regulator’s building control approval data for July to September 2026, published on 9 October and correct to 5 October, covers the twelve weeks to that date. For new higher-risk buildings and conversions:

• 114 applications were received and 57 decisions made.
• 97% of decisions were approvals, covering 11,822 homes.
• The median approval time was 23 weeks.
• 186 cases were still in progress, covering 40,644 homes.

For external remediation work, the median approval time was 32 weeks, down from 33, with 313 cases in progress. Approval rates are high, but the timescales remain long, and every week between design and start on site is a week of design team cost.

A median is only a midpoint. A scheme that has to answer detailed queries on fire strategy or structure can take well beyond it, so design teams are wise to plan resources and fee stages around the range of outcomes rather than the average, and to agree with clients early how extra work during the approval period will be paid for.

The Building Safety Levy is now live

The Building Safety Levy Regulations 2025 came into force on 1 October 2026. As Leeds City Council’s guidance explains, the levy applies to most new residential developments in England of ten or more homes, or 30 or more student bed spaces, where a building control application is submitted on or after that date. It is paid by the developer and charged on floorspace at rates set by government.

The levy falls on developers rather than consultants, but it adds to scheme costs at a time when many are still weighing viability. Engineers may see clients revisit designs, stage appointments more cautiously or take longer to commit, all of which affect when fees are earned and paid.

Why it matters for consultancy cash flow

Structural, fire and building services engineers on higher-risk schemes often carry significant work through the Gateway 2 period, including responses to regulator queries, before construction begins. Where fees are tied to approvals or project milestones, that time sits as unbilled work. WIP finance and working capital are commonly used to bridge it, and aged debt and lock-up funding helps where invoices are slow to clear.

Higher-risk work also brings higher professional indemnity premiums. PII premium finance spreads the cost, and recruitment finance helps practices take on the fire and structural specialists the regime calls for.

Practical steps for consultancies

• Agree fee stages that reflect the Gateway 2 timetable, not just design completion.
• Track unbilled time on schemes awaiting approval.
• Budget for PII renewal with your higher-risk work in mind.
• Arrange facilities before a large scheme stalls, not after.

Our guides to reducing lock-up and PII premium finance go further, and managing cash flow brings the options together. Architects may also find our news on the RIBA Future Trends survey useful. We search the market across 300+ lenders for engineering consultancies, and Instant Quotes shows your matches in minutes, with no credit check.

Common questions

Published 16 October 2026. Figures and dates are taken from the sources named and were correct on that date. This article is for general information only and should not be treated as legal, tax, accounting or financial advice. Funding availability and lender requirements depend on individual circumstances.