Guidance

Impact Assessment: factsheet

Updated 5 April 2022

This guidance was withdrawn on 25 July 2022

This guidance is withdrawn as it is no longer current. Please see the latest guidance on the Building Safety Act.

The following document is a summary of the key information in the Impact Assessment for the Building Safety Bill.

All figures are up to date and utilise the best available information and appropriate assumptions at time of publication. However, these may be subject to change during the passage of the Building Safety Bill. These assumptions and figures will also be refined, and may change, during the detailed planning of implementation and development of the detailed regulations that sit under the primary legislation.

For greater detail, the full Impact Assessment can be found at: https://bills.parliament.uk/bills/3021.

What are we going to do?

1. The Grenfell tragedy should never have happened, and it brought the need for building safety reform sharply into focus. In its wake we grant-funded remediation of unsafe cladding on high-rise buildings, provided expert advice on assessing building risks and asked the fire service to accelerate inspections of all high-rise buildings. We banned the use of combustible materials on the external walls of high-rise buildings and, recognising that we needed wider system reform, appointed Dame Judith Hackitt to conduct a review of the regulatory regime and provide robust recommendations for reform.

2. Dame Judith Hackitt’s Independent Review provides the basis of the new regime now being introduced by the Building Safety Bill – a strengthened regulatory regime for high-rise residential and other in-scope buildings, improving accountability, risk-management, and assurance. The Independent Review pointed to an industry that needed significant culture and regulatory change to be fit for purpose and the Building Safety Bill will support and deliver the changes needed.

3. Through the Building Safety Bill, the Government is setting out to strengthen the whole building regulatory system. The new Building Safety Regulator will enforce a new, more stringent regulatory regime for high-rise residential and other in-scope buildings (of at least 18 metres or 7 storeys) and oversee the safety and performance of all buildings. The Bill will also strengthen oversight and protections for residents in high-rise residential buildings.

4. The new regime will encourage action to reduce risks, but in a way that is proportionate to the potential impact and associated costs of any mitigating actions. The new regime will do this by embedding and ensuring proportionate steps are taken to deal with buildings risk through prevention, control, mitigation and ongoing management. This will result in major fire and structural hazards being mitigated in a manner that focuses on safety and cost.

5. The Building Safety Bill will:

• Establish the Building Safety Regulator within the Health and Safety Executive to provide oversight across the regulatory regime for all buildings and to introduce a more stringent regime for higher-risk buildings during design, construction, and refurbishment;
• Introduce amendments to the Defective Premises Act 1972 to allow claims to be brought forward where there are historical defects that make a dwelling unfit for habitation, extending the limitation period from 6 years to 30 on a fully retrospective basis. The Bill also extends the application of the Defective Premises Act beyond work to ‘provide’ a dwelling to all work on residential property, where the work makes a dwelling unfit for habitation;
• Introduce a stronger and clearer framework for the regulation of construction products and pave the way for a National Regulator for Construction Products to be established in the Office for Product Safety and Standards; and
• Introduce wider improvements including changes to the Architects Act 1997, the Regulatory Reform (Fire Safety) Order 2005 (the Fire Safety Order) and the Housing Act 1996, and provisions to establish a New Homes Ombudsman.

Approach to evidence and analysis

6. The Impact Assessment measures the impact of these policies against what would have happened without the intervention; this consideration is the policy counterfactual. Some of the activities that we are now requiring in law, (for example engaging with residents and managing the risks in their buildings) would likely occur without the new regime being introduced by the Bill. Therefore, we have costed these specific requirements as new costs, after adjusting our estimates of the extent to which this best practice is happening already (based on input from expert consultants). As such, the costs set out as part of our analysis are those that arise from the new regime, and do not include costs that are incurred from work that would already be required under existing legislation or that is already carried out voluntarily.

7. Analysis presented in the Impact Assessment has drawn significantly on the experience of client work on higher-risk buildings of PRP Architects and modelling by Adroit Economics as part of a consortium contracted by the Ministry of Housing, Communities and Local Government. Cost estimates for the Building Safety Regulator have been aligned as far as possible with financial and operational modelling by the Health and Safety Executive. Similarly, cost estimates for the National Regulator for Construction Products have been informed by the Office for Product Safety and Standards.

8. Where we have calculated cost on a per-building basis those costs have been based on a series of assumptions that we estimate represent the average. Where buildings have been well managed and operated in line with current legislation, the costs are likely to be lower. Conversely if a building has been badly managed or is operating outside the current rules the costs to that building are likely to be higher.

The counterfactual

9. As part of our analysis, we have considered a counterfactual. This has been done in two ways:

• A proportion of buildings are already undertaking activities that will be new requirements under the bill and so the total cost has been discounted by this proportion.

• We have only considered the cost incurred from the additional time and resources required to perform new requirements of the Bill.

10. This approach ensures that, as far as possible and where appropriate, we are only costing the new burdens that buildings face. We are also only costing additional time and are not costing time for activities that are already being done. This means that we have not explicitly costed all the counterfactual (as only additional time to undertake new burdens has been considered for some elements).

What are the benefits?

11. The Bill will ensure clearer oversight and accountability for the safety of buildings. This is expected to reduce the risk of major fire and structural incidents in in-scope buildings, in turn leading to reduced fatalities and casualties, property damage and other associated costs.

12. Not all the benefits from the new regime are quantifiable. The new system will ensure more frequent, more detailed inspections and reviews by more capable and more independent regulators, and cover a wider set of building safety risks than is currently the case. These inspections and reviews will be more transparent to residents, and those undertaking them will have more ability to hold to account, including taking enforcement action where needed, those who break the rules. Residents will have certainty over who is accountable, and who they can turn to if those who are responsible do not do what they are supposed to do. This will better incentivise industry to fix the issues that need to be fixed and give residents much greater confidence that their homes - and families – are in safe buildings, and that their properties will not become valueless or attract huge insurance premiums.

13. We expect that the Bill will reduce the likelihood of systemic safety issues arising in buildings going forward, reducing the need for future widescale remediation and associated costs.

14. The new regime will mean design and construction workers will benefit from a more transparent operating environment, as a result of a consistent accountability framework accomplished through new dutyholder requirements for design and construction, resulting in safer buildings and reduced long-term maintenance costs.

15. Other non-monetised benefits of the regime include offering assurance over building safety to the mortgage and insurance markets. This will provide greater mortgage provider/insurer confidence, and thus the availability and value of these products to leaseholders. Currently most lenders are not willing to lend on properties in high-rise buildings without proof that there is no flammable cladding. Similarly, insurers are asking for higher premiums for buildings insurance because they struggle to differentiate between safe and unsafe buildings. Improved confidence will be achieved through the introduction of the safety case approach as part of the more stringent regulatory regime. Furthermore, the Building Safety Regulator’s oversight of the built environment should minimise ambiguity around compliance and in turn further improve confidence in the industry.

16. We also expect there to be benefits in terms of cost savings to the construction industry during the construction process, driven by the new regulatory regime, as well as potential benefits in terms of greater innovation and productivity in the construction industry.

17. Wider benefits may also be realised from productivity gains for the construction industry. Affected UK industries would be able to gain skills and expertise which could enhance their international competitiveness. Additionally, improved systems, processes and techniques that may be adopted by industry in response to regulator activities will drive innovation across the industry resulting in productivity gains/ further cost saving.

18. There may also be wider benefits from additional exports for construction products. It is assumed that due to increased safety brought about by the introduction of both the National Regulator for Construction Products and the new Construction Products Regulatory Regime, exports for construction products may increase.

19. Overall, we estimate that the Bill will yield monetised benefits worth between £159m and £635m per year.

How much will this cost?

20. The detailed estimates for the costs and benefits of all parts of the Building Safety Bill are outlined in the Impact Assessment which can be found at https://bills.parliament.uk/bills/3021.

21. This Impact Assessment has been published to support Parliamentary scrutiny of the Building Safety Bill and has been updated since the draft Building Safety Bill was published for pre-legislative scrutiny in July 2020. This Impact Assessment appraises the impact of implementing the reforms under the Building Safety Bill through legislation. Where necessary, this assessment is based on current assumptions about measures that will be taken through secondary legislation. We have committed to publishing the details of key secondary legislation during the passage of the Bill, and where appropriate, this assessment will be updated to reflect those details. Further detailed assessments will be carried out, where relevant, for secondary legislation in the future.

Total costs

22. We expect the Building Safety Bill to impose costs on both industry and regulators. These are the costs arising from the implementation, operation and maintenance associated with the Building Safety Bill. We expect two types of costs:

• Annual costs, which are annually recurring costs of the new regulatory regimes. These include costs related to newly constructed buildings, recurring annual admin costs on all buildings and costs related to the construction products regime.
• Transitional costs, which are required to ensure the management of existing buildings are compliant with the new regulatory regime, as well as familiarisation and training costs.

23. We estimate the total annual recurring cost of the new regulatory regime to be £426.8m.

24. From the £426.8m, we estimate that £411.2m will arise directly from the Bill. Of that, we estimate that:

• £283.7m will fall on industry (see below for discussion of building safety costs in the service charge)

• Regulators will incur £127.5m (before cost recovery – see below for discussion of cost recovery by the Building Safety Regulator).

• We expect £15.6m will come from other requirements including; the New Homes Ombudsman, Mandating Plan Certificates and the Fire Safety Order.

• We expect one-off transitional costs incurred in the first two years of the new regime, to total £812m. Of this, we estimate that £731m will fall on industry and regulators will incur £81m.

• The total annual recurring cost of £426.8m can be broken down into 5 main components. These costs will represent the total annual cost incurred by both industry and regulators (excluding transition costs and cost recovery).

• Building Safety Regulation - £342.3m. We expect the main drivers of cost from the new regime to be from:
  • Safety Cases (existing and new buildings) - £91.8m, safety cases are a requirement of the accountable person/s to verify they have identified and assessed the building safety risks relating to the building, and taken reasonable and practicable steps to prevent a building safety risk materialising. The majority of costs will arise from producing and maintaining a Safety Case Report (a document that explains how the building safety risks in a building are being effectively managed on an ongoing basis, with an explanation and justification of the approach being taken to manage risks, the compilation of which might require contracting a team of technical experts). We expect that the costs of the safety case will be higher in the first two years of the new regime as a result of transitional costs.
  • Gateways (new builds only) - £54.4m, Gateways will act as hard stops throughout the design and construction phase of a new building to ensure the dutyholder possesses the required documentation for each new building in scope and that the building meets the prescribed standards. The Gateways will require developers to demonstrate compliance by providing key documents (e.g. golden thread) at various gateway points. The level of completeness of each component will be dependent on the gateway in which they are checked. The regulator also has the right to inspect any development.
  • Other costs - £196.1m. The other costs are made up of: dutyholder responsibilities, wider dutyholder activities, registrations, mandatory occurrence reporting, residents engagement strategy, residents complaints handling and escalation, refurbishments, sanctions, oversight, high rise residential building management, ensuring industry competence and training costs.
• Construction Products Regulation - £69.0m
• New Homes Ombudsman - £1.6m
• Mandating Plan Certificates - £2.9m
• Fire Safety Order Amendments - £11.0m

Key areas of the new regime

25. We have set out some of the key aspects of the new regime in the following sections, to aid understanding of the impact that they will have.

Establishing the building safety regulator

26. The Bill establishes the new Building Safety Regulator. The Building Safety Regulator’s aims will be to secure the safety of people in or about buildings; and improve the standard of buildings across the built environment.

27. To ensure that new and existing regulations are complied with the Building Safety Regulator will be able to issue compliance notices (requiring rectification of non-compliance with duties within a set time) and, in design and construction, stop notices (requiring work to be halted until serious non-compliance is addressed). Misinforming the Building Safety Regulator or obstructing its work will be punishable by fines or up to two years imprisonment.

28. The Building Safety Regulator will oversee the performance of Building Control Bodies (registered building control approvers and local authority building control departments) through a robust process of monitoring, analysis and reporting and will have the power to intervene and direct Building Control Bodies to immediately rectify unsafe practices.

29. Where appropriate the Building Safety Regulator will also work to ensure that there is an appropriate level of competence across the sector.

30. Taken together this means that the new Building Safety Regulator will be able to ensure that individuals are complying with regulations and step in to ensure that problems are fixed when they arise.

Costs

31. We estimate the average annual cost to the Building Safety Regulator to be £85.8m (excluding cost recovery). This cost is split by:

• Building Safety Regulator, £60.1m
• Local building control bodies, £9.6m
• Local Fire and Rescue Authorities, £13.2m
• Local Environmental Health Officers, £2.9m

32. The majority of the costs to the Building Safety Regulator arise from implementation of reforms and enhanced enforcement of the regulatory regime. Where costs will be created for local authorities, these will either be funded through the Building Safety Regulator where they relate to the BSR’s regulatory functions (i.e. participation in a Multi-Disciplinary Team) or in line with the New Burdens doctrine.

Cost recovery

33. The Building Safety Bill will give the Building Safety Regulator the ability to recover costs from those it regulates, within Managing Public Money guidance. We are assuming the following cost recovery rates across each of the functions for the Building Safety Regulator:

• We are assuming a year 1 cost recovery rate of 70% and year 2 onward cost recovery rate of 90% for the implementation of the new regulatory regime.
• We are assuming a 10% cost recovery rate for the oversight of the building safety and performance systems.
• We are assuming a 45% cost recovery rate for assisting and encouraging competence among the built environment industry and regulators.
• We are not assuming any central costs are recovered.

The higher risk regime

34. The Bill will introduce a new more stringent regime for buildings deemed to be at a higher risk from fire or structural collapse. The Bill defines higher-risk buildings as those being 18 metres or more, or 7 storeys or more (whichever is reached first).

35. The list of total costs above sets out some of the key costs to industry from the new higher risk regime. Where specific aspects were not set out above, we have highlighted costs on the relevant section.

36. The higher-risk regime will define an individual (or individuals) who can be held to account for the safety of in scope buildings. The Accountable Person(s) will be responsible for ensuring that the building is safe. The Accountable Person will ensure that the necessary steps are taken forward to ensure that defects are addressed, and residents’ concerns are listened to.

Buildings in scope

37. We estimate that there are approximately 12,000 residential buildings in scope (excluding c.500 student buildings), of which half are social and half private blocks. There will be some private leaseholds in otherwise social buildings and so in total we estimate there are about 444k privately owned dwellings in high-rise residential buildings.

38. All buildings should meet essential safety requirements regardless of their age, height or use and should be managed to ensure the safety of residents. The Building Safety Bill provides greater assurance of essential safety requirements for buildings in occupation and requires the Accountable Person to demonstrate they are actively managing safety risks within their building. The building safety regime, through introducing the safety case approach, may identify works and changes to management practices that building owners should introduce in order to ensure building safety risks are proactively reduced and controlled, and there will be strengthened powers for the Building Safety Regulator to enforce the safety requirements.

Accountable Person(s)

39. The Accountable Person must carry out an assessment of building safety risks in and around the building. They must take all necessary steps to control those risks and provide a report (the Safety Case Report) to the regulator.

40. To achieve this the Accountable Person will have had to identify the hazards within their building, decide who might be harmed by those hazards, evaluate the likelihood and consequence of those hazards becoming a major incident, decide on the measures needed to lower the risks of the hazards becoming a major accident to an acceptable level, implement them, and have a system in place to ensure those measures remain fit for purpose whilst the building is occupied.

41. Within this report, the Accountable Person will make a claim that the major risks in the building are being managed. The Building Safety Regulator will be able to either accept this approach or direct the Accountable Person to take the steps needed to prevent major hazards/accidents.

Safety case

42. The safety case delivers an outcomes-based regime whereby safety is demonstrated through documented assurance, supported by robust and reliable evidence, contained within the golden thread. The associated costs ensure there is a record of information, which is often not currently the case, that provides detailed knowledge of a building and an understanding of the measures in place for the ongoing management of building safety risks.

43. Accountable Persons will rely on expert individuals, including fire and structural risk assessors, with the competence to meet the specific requirements of the regime e.g. assessing the risk of fire spread in the building as opposed to assessing general fire precautions for the common parts (as required under the FSO).

44. To support the oversight and ongoing management of building safety risks, the Accountable Person will need to submit a Safety Case Report to the Building Safety Regulator for review, as part of their application for a Building Assessment Certificate.

45. The new ’safety case’ approach, and additional oversight by the Building Safety Regulator, will ensure that those who are accountable for managing building safety risks deliver on their existing and new duties, thereby ensuring that reasonable steps are taken to manage fire and structural safety risks through prevention, control and ongoing management. Through a proportionate regulatory approach this will take into account both building safety and cost. This will benefit residents by providing greater confidence that the right approach, supported by the right experts, is being taken to ensure their safety. Ensuring building safety risks are proactively managed is also likely to reduce longer term costs through reducing the likelihood of systemic safety issues arising in buildings going forward, and therefore the need for future widescale remediation and the costs associated with this.

Residents engagement, obligations and ability to raise concerns

46. The Building Safety Bill will provide numerous benefits to residents living in high-rise buildings. Residents will have a greater say in how their buildings are being managed so they can have confidence their buildings are much safer. This will involve improved:

• Accountability
  • Greater accountability on those that manage the building. The Accountable Person will have clear responsibilities overseen by the new Building Safety Regulator.
• Engagement
  • A residents’ engagement strategy will be mandatory; requiring Accountable Persons to be transparent and promote the participation of residents and flat owners in the decision-making about building safety management in their building.
• Provision of information
  • Residents will be able to request further information about the safety of their building from the Accountable Person.
• Obligations
  • Clear obligations, and a requirement for these to be communicated by the Accountable Person, to ensure residents play their part in ensuring the safety of their buildings.
• Raising concerns
  • Clear processes for residents to raise concerns with their Accountable Person and have them dealt with, and if needed to raise them with the Building Safety Regulator.

Costs

47. The costs related to residents can be separated into two parts: Resident Engagement and Obligations and Residents Complaint Handling and Escalation. We estimate the average annual recurring cost to both industry and regulators to be £53.8m.

Leaseholders

48. The Building Safety Bill will bring the following benefits to leaseholders.

49. Enhancing rights to claim compensation for unacceptable work:

• The Bill substantially increases the period of time in which leaseholders can make a claim under the Defective Premises Act 1972 by extending the limitation period from 6 to 30 years. This means leaseholders will have 30 years from the completion date of work to bring a claim for compensation if their home is not fit for habitation. This change will be retrospective, meaning that leaseholders will be able to bring a claim if their home was built up to 30 years prior to the Building Safety Bill becoming law.

50. Delivering transparency on costs through the service charge.

• The Bill sets out what building safety costs can and cannot be passed on. For example, the costs of enforcement action against accountable persons can never be passed to leaseholders. This provides further protection against unfair costs.

• Leaseholders will have the ability to challenge the reasonableness of costs at the first-tier property tribunal.

• There are numerous powers in the Bill that will enable Government to limit the building safety costs that can be recharged to leaseholders. The Secretary of State may prescribe costs to be excluded in regulations.

51. Ensuring that landlords always first seek alternative means of funding remediation works. We are ensuring that landlords do not pass on the costs of remediation works (which will be defined in regulations) to leaseholders as a default; it is their responsibility to take reasonable steps to secure alternative funding including through government grant or finance, warranties, insurance and litigation. If this does not happen, leaseholders will be able to challenge these costs in the courts.

52. In addition, as residents of higher risk buildings, leaseholders will also benefit from the provisions in the Bill that ensure that residents’ concerns are listened to. The details of these benefits are set out in an earlier section.

Costs

53. As with existing service charge which requires leaseholders to pay for ongoing management of the building, the Accountable Person may seek to pass on to leaseholders the ongoing costs of implementing the new building safety regime. This is known as the Building Safety Charge. The Building Safety Bill does not make leaseholders liable for the costs of undertaking capital works, for example removing unsafe cladding. However, where existing leases allow for remediation costs to be passed on to leaseholders, we are ensuring that those responsible for management of the building have a responsibility to secure alternative funding, where available.

54. The Bill sets out certain obligations for the landlord to fulfil, including providing details of building safety costs together with a summary of their rights and obligations to leaseholders. In addition, it is our intention that landlords will have to provide an annual estimate of building safety costs.

55. We expect that over the first two years, the building safety costs will be higher due to transitional costs (e.g. setting up a safety case and establishing a golden thread). We estimate that over the fifteen-year appraisal period that the average monthly cost of the building safety measures will be £16 a month. The building safety costs presented here are not inclusive of costs relating to enhanced Fire Risk Assessments as operational policy and potential guidance around the required frequency of such assessments is under development.

Construction and planning

56. The Bill seeks to introduce a new building control process in design and construction for new high-rise residential buildings, care homes and hospitals which are 18 metres or more in height, or at least 7 storeys.

57. Currently developers can start building work when they have deposited plans and given the local authority notification of commencement or submitted a building notice. The new Gateways process will require building control approval to be obtained before starting building work, before significant changes are made during construction, and when building work is completed before occupants are moved in. This will strengthen regulatory oversight at key points in design and construction.

58. New documents will be required as part of building control applications to demonstrate building regulations compliance and appropriate consideration of building safety. Building regulations compliance means meeting the technical requirements and the new dutyholder, competence, golden thread and mandatory occurrence reporting requirements. These work together to give industry the clear framework it needs to deliver more safe, high-quality homes and buildings, with clear responsibilities on those undertaking design and building work.

59. Getting things right as early as possible provides the opportunity to reduce additional time and costs at later stages while increasing quality standards. The new regime should improve efficiency, for example, during construction stringent change management requirements should minimise the need for reactive design changes to correct non-compliant or defective work. We expect the Gateways system will reduce the likelihood of systemic safety issues arising in buildings going forward, and that this will reduce the need for future widescale remediation and the costs associated with this. This will benefit future resident, and leaseholders, who will be able to have more confidence in the safety of their buildings, and value of their homes.

Costs

60. The design and construction regime will apply to new buildings and buildings that are converted to higher risk buildings. We estimate that this will add £113,000 to £265,000 to the cost of building a new building. These costs may be borne by developers in the form of reduced profits, passed on to landowners as reductions in land prices or included in the price of new flats. They will not result in ongoing increased costs to leaseholders.

61. Our analysis suggests that the increase in build costs caused by the new design and construction regime (£113,000 to £265,000) will not impact the viability of the average development proposal in scope in any region, nor will it lead to developers reducing the height of their developments to avoid the provisions of the Bill.

Developer levy

62. The Government has always expected that the industry should contribute to addressing these costs. To help ensure this, the Bill introduces provisions for a levy when developers seek building control approval to develop certain higher-risk buildings.

63. The revenues of the levy will be a cost to those paying but will be a benefit to those who would otherwise have had to pay to remediate historic building safety defects. In net terms, the levy will be a transfer and not a net cost.

Reforming redress

64. The Bill extends homeowners’ rights to redress for shoddy workmanship and serious defects.

65. The Bill extends the limitation period under section 1 of the Defective Premises Act 1972 from 6 to 30 years. This period will be extended retrospectively, meaning that, as well as applying to future work, it will also apply to work that took place up to fifteen years before the provision comes into force.

66. Additionally, the Bill amends the Defective Premises Act 1972 by expanding it to include work undertaken as part of refurbishments. This change will only apply to future work.

67. We will be commencing section 38 of the Building Act 1984, which allows a claim for compensation to be brought for physical damage (whether injury or damage to property) caused by a breach of building regulations. The Bill also extends the limitation period to 15 years. This change will only apply to future work.

68. These changes mean that in certain circumstances it will be possible for homeowners/leaseholders/building owners to bring claims against developers and contractors who have completed work with serious defects.

69. We are working to understand how many cases of historical defects might be affected by this change and are undertaking analysis to establish the scope of this provision to understand the impact.

The national regulator for construction products

70. The Bill will establish a new national regulator for construction products in the Office of Products Safety and Standards. The regulator will be responsible for the following:

• Market surveillance and oversight of local enforcement action, including maintaining a national complaints system and supporting local Trading Standards in dealing with complex issues;
• Enforcement action with manufacturers, where issues are judged to be national and/or significant;
• Providing advice and support to the industry to improve compliance as well as providing technical advice to the Government; and
• Working with other regulators to share emerging information and address emerging risks.

71. The Bill provides powers so that all construction products marketed in the UK fall under a regulatory regime. The regulator will be able to order their withdrawal from the market if they present a safety risk.

72. After an implementation period, the manufacturers of safety critical construction products will be subject to requirements including the labelling of products, declaring their performance, and ensuring that they consistently meet declared performance standards.

73. The regulator will be able to ensure that only those products that do not pose a risk to safety will be able to be sold and marketed in the UK.

74. We estimate the total annual recurring cost of the national regulator for construction products to be £18.5m (inclusive of transition costs).

Will you publish a further impact assessment for the amendments made to the Bill?

• We published an Impact Assessment alongside the introduction of the Building Safety Bill based on figures which were up to date, and utilised the best available information and appropriate assumptions, at time of publication. We acknowledged that these may be subject to change during the passage of the Building Safety Bill. We may also refine our assumptions and figures during the development of the regulations that sit under the primary legislation and in detailed work to plan and deliver implementation of the new regime.

• Where the amendments tabled at Committee or Report require secondary legislation, we will consider whether to update the impact assessment at that point.