This article is based on Quelfire’s London Build 2025 panel discussion, titled Gateway 2: What We Know Now.
Craig Wells, Quelfire, was joined by Graeme Whitty, Willmott Dixon, and Nasar Ishfaq, R5 Consultants, to discuss Gateway 2 and what they have learned since its introduction.
This article also explores why you should look beyond Gateway 2 to Gateway 3, and explains how to prepare for it.
Panel Speakers:
- Craig Wells – Sales Director, Quelfire [moderator]
- Graeme Whitty – National Product Director, Willmott Dixon
- Nasar Ishfaq – Director, Architect, and Principal Designer, R5 Consultants
What Did Gateway 2 Teach Us About How the System Works?
Has Gateway 2 Become the “New Normal”?
In many ways, yes. It’s already changing the industry for the better, especially for teams that genuinely want to get things right.
That said, the industry isn’t fully there yet. Some still hold the mindset of “we’ve always done it this way” and approach the Gateway regime as something they have to do, rather than as something that can make a difference in how we design and construct buildings.
From our perspective at Quelfire, it’s a much-needed change that is pushing the industry toward better decisions and safer buildings – which can only be good things, surely?
What Surprised the Industry Most in Early Applications?
Ishfaq was surprised by the disconnect between the Building Safety Regulator (BSR) teams and the construction industry.
He highlighted that there seemed to be no established process; some BSR teams used staged applications, while others required full submissions.
Some submissions completed in early Stages 3/4 with no contractor details were approved in 12 weeks, whereas other T1 contractors, for instance, provided thorough information on specific parts of the build and waited about nine months for approval.
Ultimately, this suggests that the BSR was still very much working out its processes during this stage.
How Things Are Starting to Stabilise
However, Ishfaq is finding that there is now more consistency with expectations. The BSR is now working directly with contractors and answering their questions to ensure a smoother delivery of Gateway 2 projects.
There are also clear signs that progress is being made within the BSR. Here are just a few examples:
- On 27th January 2026, the regulator became a standalone body, leading to greater focus on Gateway 2, remediation delays, and uncertainties around Gateway 3.
- As of March 2026, the backlog for legacy Gateway 2 projects was cleared.
- The BSR is also looking to improve guidance to help applicants reduce the number of invalid submissions.
Why Gateway 3 Is Now the Bigger Unknown
Because the introduction of the Gateways was such a significant change for the industry, the focus has naturally been on the first stop-and-go Gateway, Gateway 2.
However, as the built environment transitions beyond this, the next unknown is Gateway 3, which introduces a new level of uncertainty. 
Ishfaq raised concerns about potential delays from Gateway 3, especially given the delays experienced with the second Gateway. He believes it hasn’t been “road tested enough yet” to know what it will entail; the industry is still waiting for feedback.
Where Are Projects Still Falling Short at Gateway 2?
Design Coordination, Missing Information, and Disconnect Between Teams
Typically, R5 Consultants will distribute their project schedule to key parties, ready for submission at Gateway 2.
However, upon receiving the completed schedule, the team often finds gaps in expectations and information, with each party often having different ideas about elements of the project.
He said, “The challenge with firestopping is that it’s one of the few elements of construction that is genuinely collaborative. The architect will set their position of all these walls, the structural engineer will dictate what size the openings and letterboxes can be, and then the M&E engineer needs to tell you what is actually passing through and where, and then you can come to a resolution on what the firestopping needs to be.”
What Ishfaq and his team are finding is that they're getting pushback from consultants due to tight deadlines and rising costs, because they haven’t given enough time to Gateway requirements.
Late-Stage Surprises
Furthermore, Whitty argued that contractors “can’t play the system anymore” and that part of the Gateway regime is about making concrete decisions and following them through on-site.
He said that it’s the hidden costs that weren’t accounted for and having to redesign a project two or three times that slow development and cost a lot of money to resolve.
Who Really Owns What?
The Principal Designer’s Role in Driving Coordination
As mentioned previously, while there has been some debate about design liability, Ishfaq views the Principal Designer’s (PD) role as one that drives coordination and helps identify gaps among stakeholders. He and his team take on responsibility and leadership.
Main Contractors As the Ultimate “Holders of Responsibility”
In all of its projects, Willmott Dixon takes on the main coordinator role as the project teams are front and centre of decision loops.
By the time they pass on information to the PD, Whitty believes the main contractor should know each subcontractor’s responsibilities.
Of course, some contractor routes don’t facilitate that; Whitty said, “You might be given a design team that you’ve not worked with before, different expectations, different standards. You have to unpick that.”
As the Principal Contractor, the team signs a declaration at the end confirming that the project was built in accordance with regulations. Therefore, it is integral in ensuring responsibility sits with the right party.
Why Leadership Is the Missing Piece
Furthermore, Wells highlights that all parties will influence final passive fire protection decisions. That’s why there needs to be an open forum for all stakeholders to come together and have an input.
However, this can only be achieved through “true leadership”. Wells states that he has seen great examples from companies, like Willmott Dixon, who follow a standardised process; if there’s a mandate to make it work, it will work.
What Does “Good” Actually Look Like at Gateway 2?
Early Engagement and Honest Conversations Across Teams
The whole reason for the Building Safety Act 2022 and subsequent Gateways is to improve building safety and protect those in them.
Early fire stopping engagement is the only way to ensure this, as it brings all key parties together at the design stage to discuss key deliverables and how they’ll be achieved. 
It puts fire safety at the heart of every decision, ensuring the project is designed and then built around available fire stopping tested solutions.
Fully Coordinated, Complete Design Information
Ishfaq said that when looking at the mechanics of what you’re going to submit, it is about design procurement alongside product and system procurement. If contractors review the information and decide on deliverables, a systematic approach can be taken to articulate it to the regulator.
Further to this, Whitty stated that main contractors need to be clear about and commit to products and systems they want to see in the building.
He also raised that you’ve got to make it easy for the regulator to say yes. You’re taking the BSR on a journey – give examples, show the rationale behind the decisions.
This also includes being in dialogue with your regulator spokesperson and finding out what’s required of you: ask the questions.
Hurdles at Gateway 2
All panellists agreed that it is better for project teams to take their time at the design stage and focus on getting it right the first time. Multiple redesigns cost time and money, add project pressure and stress, and ultimately slow the whole project down. 
You might discover that the BSR will ask for additional information after submission. By putting in the effort beforehand, you give yourself an advantage.
Thorough design may take time upfront, but it pays off in the long run for business security and profitability. Not to mention it prioritises building safety!
Ishfaq said he has experienced many instances in which teams agreed on a submission date, only for information to be missing days before. He stressed that when the PD submits the information, if it doesn’t make sense to them, it won't make sense to the BSR either, so you’re likely setting yourself up to fail.
How Can Teams Start Preparing for Gateway 3 Now?
Building QA and Evidence Capture Into Delivery
Both Whitty and Ishfaq agreed that contractors need to improve their QA process.
Whitty also went on to say that it’s about the execution of what you set out to do. It’s about evidencing that what you have installed is as per what you submitted at Gateway 2.
You can’t leave it to the last minute to prove how your piling went in, for example, you’ve got to be thinking about all of these things from the get-go.
Ultimately, no one knows what Gateway 3 will fully entail, so if you’re not preparing for it, start now.
Aligning Site Processes With Design Commitments
Willmott Dixon is preparing for Gateway 3 by enhancing its pre-start procedures, working through key deliverables before construction even begins.
The team goes through what they are building, what they will be evidencing and how often, and what good looks like.
Whitty stated that having these early on-site conversations has been driving value in production and efficiency and that there is generally less conflict on site.
By working closely with supply chain partners, behaviours become apparent. Their willingness to collaborate, but also how they plan, prepare, and deliver to make Gateway 3 more achievable.
Are We Ready for What Comes Next?
While the built environment’s focus has been on Gateway 2, it highlights one question: Are we ready for what comes next?
Gateway 3 is currently the big unknown. The unknown can be scary, but especially for those unprepared.
“We’ll deal with it later” can no longer be an option, as evidence is crucial to demonstrating that what is built is what was designed for Gateway 2. That means thinking ahead now and applying all practices across all projects.
Because, at the end of the day, this is about whole building safety and protecting lives.
And sticking to the agreed plan.
If you need support with service penetration sealing, we’re here to help, don’t hesitate to contact us.
