Grenfell Phase 2 Progress Report: Three Developments Shaping Building Safety Reform

On 17 December 2025, the Government published the third progress report on the Grenfell Tower Inquiry: Phase 2 recommendations. These progress reports provide updates on the actions that have been taken after the Government accepted all of the findings by the Grenfell Inquiry and committed to taking action on all 58 recommendations to improve the building regulatory system. Here we explore three of the most significant updates in the third progress report.

Single Construction Regulator Consultation

The first recommendation in the Inquiry’s Phase 2 report was for the creation of a single construction regulator to bring together various functions of the industry, including buildings, products, and professionals.

On 17 December 2025, the ‘Single Construction Regulator: Consultation Document’ was published. This is the latest in a series of steps that have already been taken in an effort to reform the regulation of the construction industry, which have included strengthening the Building Safety Regulator (BSR), and the  transfer of building safety functions from the Health and Safety Executive to a new arm’s length body (which was completed on 27 January 2026).

The regulation of buildings, products, and professionals were three of the topics covered in the 55-page Consultation Document. In addition, the Consultation Document covers digital, data and efficient regulatory delivery, as the Government considers these to be “crucial enablers” of the regulation of buildings, products, and professionals. The fifth topic addressed in the Consultation Document is related to residents, with the Government saying that the protection of residents is a priority for reform. The Government says that the responses to the consultation’s questions on these topics will be used to inform the creation of the new regulator and wider regulatory reform.

The consultation is open under 20 March 2026.

Higher Risk Building Definition

The Building Safety Act 2022 and its supplementary regulations define a higher-risk building (HRB) as a building that is at least 18 metres in height or has seven storeys; contains at least two residential units; and does not comprise entirely of a named type of accommodation. HRBs are subject to additional regulatory requirements during design, construction and upon completion.

The Inquiry’s Phase 2 report recommended that the HRB definition should be urgently reviewed, as the Inquiry felt that nature of the use of a building and the likely presence of vulnerable people was more relevant than height alone. This review was undertaken by the BSR and published in February 2025.

The review considered current statistics, vulnerable occupants, the impact that changing the definition of a HRB would have on industry and the safety aims of the regime, the interaction with other safety regulation, cost implications, the capability and capacity of the regulator and the wider building control sector, and stakeholder views.

Based on the data available when the original HRB definition was formulated, together with the new data, the review concluded that the definition of HRB still focused on the appropriate categories of buildings. The difficulty of using vulnerability as a legislative criterion was noted, but the other steps that have been taken to protect vulnerable people following the Grenfell tragedy were taken into account.

However, the BSR will conduct an ongoing review of the definition of HRB, to reflect the impact of new developments and changes in risk. In particular, the review noted that more evidence of the risk of the impact on vulnerable people should be sought, and that this may feed into future reform.

The ongoing review will consider, at least once a year, evidence including new data on fire safety; any emerging evidence on vulnerable people and how their safety is being impacted by reforms to the building safety system; any new and emerging risks in the built environment relevant to the spread of fire, structural failure, or the presence of vulnerable failure; assessment of whether changes to the definition would improve protection to residents or users (particulars those who are vulnerable) of a class of building; stakeholder views; an assessment of the implications of any changes on sector changes, the Regulator operations, government policy, or other areas.

The government emphasises that any proposals for change will be thoroughly tested with industry and stakeholders before implementation.

Authoritative Statement on expected skills and knowledge of competent fire engineers

Another action taken by the Government in response to the recommendations of Phase 2 of the Inquiry was to establish the Fire Engineers Advisory Panel in April 2025.

The Inquiry recommended that the Panel should produce an Authoritative Statement on the expected skills and knowledge of a competent fire engineer, as part of the broader recommendation that fire engineers should become a regulated profession.

The Panel’s Authoritative Statement outlines several key principles which should underpin future regulation and reform, including:

• The title and function of fire engineer should be regulated in statute
• The central, protected function of a regulated fire engineer should be preparing the fire safety strategy
• The development of a competent fire engineer should be a structured process, combining formally accredited education and supervised professional experience, in a manner similar to other engineering disciplines
• Fire engineers require deep understanding and knowledge of core architectural and engineering principles, fire science, human behaviour, and regulations relevant to buildings and fire safety
• Other built environment disciplines also need to acquire a more detailed understanding of fire engineering and the role of the fire engineer, to produce consistently fire safe buildings.

The Authoritative Statement also identified expanding the scope of buildings and critical infrastructure that require a fire safety strategy beyond HRBs and introducing a periodic review of the fire safety strategy during occupation as factors which are essential to managing increasing building complexity and reducing life-safety risks.

The Government published a ‘Next Steps’ paper alongside the Authoritative Statement, setting out the Government’s initial approach ahead of fuller proposals and detailed implementation options that will be developed and consulted on throughout 2026.

These initial steps include a commitment to regulating the title and function of “fire engineer”, identifying the most suitable home for the regulator, assessing internal market considerations, developing criteria for registration, and setting out a suitable implementation strategy.

The government has also committed to supporting a strong and sustainable pipeline of professionals, by exploring the development of higher education provision, the provision of bursaries, and support for research and academic capacity.

The Government will establish a Fire Engineers Transitional Board to guide them in the early stages of reform, but the ultimate responsibility for the profession’s standards will sit with the future regulator.

Next steps

The next update on the Inquiry’s Phase 2 report will be the first annual report, which the Government will provide to Parliament in February 2026. This should set out a wider overview of what the government set out to do in response to the Inquiry, and the progress that has been made so far, plans for the upcoming year, and their responsibility to provide lasting change. The next quarterly report will then be published in May 2026.