What is the Building Safety Act and Who Does it Apply to?

Despite the Building Safety Act being in place since April 2024, there continues to be confusion or misunderstanding around what projects are covered by the Building Safety Act and who within the construction supply chain the regulations apply to.

Prompted by a move from top tier contractors to make the Building Safety questions in the Common Assessment Standard mandatory for its supply chain and feedback from its membership, we teamed up with Constructionline and Once for All to run a series of webinars designed for subcontractors to answer key questions around the act and contractor roles and responsibilities.

The webinar sessions explored who and what the Building Safety Act applies to and how to navigate the building safety Common Assessment Standard questions, opening up conversations within subcontractors on how to change processes and operations to build in best practice.

Does the Building Safety Act apply to Subcontractors?

In short, if your project is covered by building regulations, as a contractor or subcontractor you are a duty holder with obligations under the act and therefore the act applies.

If you report to or contribute to the Principal Contractor, you are by definition a contractor

There are some exemptions, but in the main it applies. For more details you can access the first webinar in the series on demand here.

Common Assessment Standards (CAS) – Building Safety Questions

The Constructionline Common Assessment Standard (CAS) is an industry-wide, standardised pre-qualification questionnaire (PQQ) developed by Build UK in partnership with Constructionline, featuring an agreed question set and assessment standards for the construction sector. Its goal is to improve efficiency, reduce the administrative burden and lower costs for both suppliers and contractors by providing a unified framework for assessing companies' capabilities and compliance, replacing the need for multiple different assessments.

From October 2025 many top tier contractors have made the completion of building safety questions within the common assessment standard mandatory, to ensure safety standards throughout their supply chains. This means contractors tendering for work with these large construction firms through Constructionline Gold and other routes will have to demonstrate and evidence competency.

What are the issues around completing the CAS Building Safety Questions?

 Our series of Q&A webinars with Constructionline and Once for All looks at the most rejected question responses and why they lack the necessary details.

The most common reasons include:

• Not addressing all relevant legislation and standards: Where responses focus only on CDM Regulations and fail to demonstrate compliance with the Building Safety Act, Building Regulations and wider industry standards. Applicants must show how their systems and processes meet the full scope of applicable requirements, not just one regulatory framework.
• Lack of clarity on Quality Management: ISO 9001 is not the same as BS99001. BS 99001:2022 is a British Standard that supplements ISO 9001 by providing quality management system (QMS) requirements specifically for the built environment sector.
• Failure to fully read and respond to the question: Answers sometimes only provide partial information or discuss one aspect of the requirement. The questions specifically ask about arrangements for both the workforce and subcontractors, incomplete responses suggest a lack of attention to detail or understanding of the scope.
• Omitting one of the required groups: Many responses mention subcontractors but fail to explain how the direct workforce is managed, supervised, or supported. Both groups must be clearly addressed to show consistent arrangements across all roles under the applicant’s control.

Additional guidance on the questions in the Building Safety section of CAS can be found here.

How do Subcontractors demonstrate and evidence competency?

Many issues faced by those completing the questions are because people don’t think they have the necessary information to demonstrate or evidence competency and compliance.

In many cases, it is likely that they already have the required information in a different format but are not formalising it or recognising that this is what is required within their organisations.

• Skills Knowledge Experience and Behaviours: Show your process, how you demonstrate your obligations, how you would manage them and show intent. Industry trade bodies are working on this to support firms with a framework for demonstrating this. An example of this might be evidenced by a Training Matrix, Training Records, upcoming Training/CPD programmes.
• Acceptable Evidence: Think about the management of information. Monitor how you and your sub-contractors monitor your works. How do you deal with things internally? This is related to the scale of the business and should be proportionate to what you do. There are simple steps you can take to formalise and provide evidence to show how you communicate (or intend to communicate) with the client confirming that you are aware of their duties under The Building Safety Act and can demonstrate arrangements you have in place to plan, manage and monitor the  building work you undertake to ensure the work complies with relevant requirements in your duty holder role as a Contractor.

To watch an on-demand Q&A on the CAS Building Safety Questions, visit Constructionline.

If you would like to speak to Cube about how to build best practice into every element of your construction process, drop us a line at hello@cube-cc.co.uk.