Change control between Gateway 2 and Gateway 3: major, notifiable, logged

What is change control under the Building Safety Act?

Gateway 2 approval fixes a design; buildings then get built by people who discover things. Change control is the regime that manages the gap. Between Gateways 2 and 3, changes to the approved design of a higher-risk building fall into controlled categories, and the discipline around them is written into the Building (Higher-Risk Buildings Procedures) (England) Regulations 2023, with the practical method set out across the CLC guidance suite.

The regime has three moving parts: major changes, notifiable changes, and the change control log that records everything. Getting the category right matters, because the categories carry very different programme consequences.

What is the difference between a major change and a notifiable change?

	Major change	Notifiable change
Approval needed first?	Yes, from the BSR	No, but the BSR can object
Typical wait	4 to 6 weeks	Proceed unless objection within 14 days
Work on the affected area	Stops until approved	May continue
Goes in the change control log?	Yes	Yes

A major change requires BSR approval before the affected work proceeds, and the wait is typically 4 to 6 weeks with work stopped on the affected area. That stoppage is the number that concentrates minds: a fire-critical substitution discovered late does not just cost the review time, it idles the trades standing on that part of the building.

A notifiable change is one the regulator must know about but does not need to pre-approve: you notify, and unless the BSR objects within 14 days, you proceed. Minor changes below both thresholds still belong in the log with a record of why they are minor.

Why is the change control log the document that decides your Gateway 3?

Because the completion assessment is, at its core, a comparison: the building the BSR approved against the building you actually built. The change control log is the audit trail connecting the two. The BSR has named weak change control records as one of the four reasons Gateway 3 applications stall, alongside documentation gaps, as-built discrepancies and commissioning evidence.

The failure pattern is rarely a rogue change nobody approved. It is a change that was handled properly in the moment, discussed, engineered, agreed, and recorded nowhere except a WhatsApp thread and someone's memory. Eighteen months later the as-built drawing differs from the approved drawing, the log is silent, and a completion certificate waits while the team reconstructs history.

How do you run change control that survives the build?

The teams doing this well treat the log as a live site document, not a monthly admin chore. Every design query that changes anything gets a log entry when it is raised, not when someone tidies up. Each entry carries the category decision and its reasoning, the evidence that the changed detail still complies, and the drawing revisions it triggered. The log cross-references the golden thread, so the document set and the change record move together.

Categorisation deserves particular care at the margins. Optimistic miscategorisation, calling a major change notifiable to dodge a six-week stop, is a false economy: the BSR sees the change eventually, at Gateway 3 if not before, and a wrongly categorised change discovered at completion is a far worse conversation than the one you avoided.

Contemporaneous records are the whole game here: a change logged the day it happened, with the site photos and the approval trail attached, is evidence; the same change reconstructed a year later is archaeology.