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BSR Gateway 2 and 3: What the Wait Costs a Developer

Written by Justin, Principal · 15 March 2026 · Updated · 6 min read

Our guides are researched and drafted with digital tools, then written and approved by Justin, Principal, from his own experience.

The BSR's latest median for new higher-risk buildings is 23 weeks, against a 12-week statutory period (BSR data, July to September 2026 release, correct to 5 October 2026).

Picture the day your technical design is signed off. The team is ready, the contractor is lined up, the first tranche of the facility is drawn. Then you wait. You cannot start work until the Building Safety Regulator says yes, and the interest meter keeps running.

The 30-second version

  • What it is: Gateway 2 is building control approval from the Building Safety Regulator before work starts. Gateway 3 is the sign-off before anyone moves in.
  • What it costs you: time, and so interest: about 23 weeks at the BSR's latest median.
  • The catch: you cannot start on site until approval is in.
  • What to do: put the wait into your programme and your facility term before you sign, not after.

Who this covers

Gateway 2 (building control approval from the Building Safety Regulator before work starts) applies in England to higher-risk buildings: at least 18m tall or at least 7 storeys, with at least 2 residential units (care homes and hospitals too; hotels are excluded).

Below those lines, the standard building control route applies. Tall purpose-built student accommodation that meets the same tests is in scope.

Where does your scheme sit?

Your scheme What it means Your next move
18m or taller, or 7 storeys or more, with 2 or more homes, in England Gateway 2 and Gateway 3 both apply Plan for the BSR median, not the 12-week statutory period
Under 18m and under 7 storeys, or fewer than 2 homes Gateway 2 does not apply Standard building control; check the height and storey count with your design team
A care home or hospital of that height The rule covers these too Ask your principal designer to confirm the route
Anywhere outside England This guide describes the rule in England Check the rules where your site is
A complex scheme The BSR median for complex cases is longer Build in extra time and ask your lender about it early

Gateway 2: before construction starts

Gateway 2 is the checkpoint before building work begins. You apply to the BSR with the full design and wait for approval. The BSR can ask for more information, and complex cases take longer. Ask your design team and principal designer what the application needs. The gap between finishing design and starting on site is the part that costs you money.

What the wait costs: a worked example

Illustrative, not a quote. Take £1.6m of senior debt already drawn, at around 7.5% a year on average (our lender data, October 2026), simple interest. That is £10,000 for every month of waiting.

Wait Interest while you wait
3 months £30,000
5 months £50,000
6 months £60,000

The BSR median of 23 weeks is just over five months. That is interest on money sitting still, before any arrangement or monitoring fees.

Put the wait into the appraisal as a pound figure.

Gateway 3: before anyone moves in

Allow for Gateway 3 in your exit timetable. The same maths applies as at Gateway 2: between practical completion and sign-off, nobody can move in, so sales completions and rent wait while the loan still costs money.

Record-keeping

The Building Safety Act also requires a record of key building safety information to be kept through design and construction. Ask your team who keeps it, and from which day.

The Building Safety Levy

A Building Safety Levy is being introduced in England. Check the current position and put any levy in your appraisal alongside CIL and Section 106.

What this means for your funding

  • Facility term. The wait before and after construction pushes your facility term out, so size the term with both gateways in it.
  • Professional fees. Reflect the extra design and record-keeping work in your cost plan.
  • Timing of submission against drawdown. Where you can, line up the Gateway 2 submission with the date you draw, so you are not paying interest on idle money.

What I am seeing on live schemes

Gateway 2 costs can be heavy, and a contractor who comes in as a joint venture partner can change the picture. We have three such schemes running now, two of them Gateway 2 schemes: one around £20m, one well over £50m. The contractor is assured of the work, helps fund the Gateway 2 costs and takes a profit share. It also defers part of its build cost until the lender is repaid: the full 3% retention, plus part or all of its profit. That eases cash flow a great deal and ties the builder in, which lenders like to see.

My view: approvals are coming through slowly and a backlog is building. If that holds, new builds to the latest Building Safety Act standards will be scarce in two to three years, and the schemes that do get built should be very attractive to buyers on a yield sale. That is my view, not a prediction, a guarantee or advice to buy or invest.

Before you submit: five questions

  1. Is the design complete, and has your team said so in writing?
  2. Have you used the BSR's current median in the programme, not the 12-week statutory period?
  3. Does your facility term still work if Gateway 2 takes six months?
  4. What does a month of interest cost on your loan, in pounds?
  5. Who keeps the building safety record, and from which day?

Next step

Tell us the scheme, the height and storeys, where you are with Gateway 2 and how you plan to repay. We will talk through the funding and the timetable. It is a confidential, no-obligation chat.

Discuss your scheme · 0330 223 7873

Related guides: Development Finance Rates in 2026 · Forward Funding Explained · Development finance

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