Golden thread requirements: what dutyholders must do
The golden thread requirements are set out in the Building Safety Act 2022 and the 2023 higher-risk buildings procedures regulations: dutyholders must create, maintain and hand over prescribed safety information in an electronic facility, with change control, version history and secure access, from design through to occupation.
What the requirements actually say
During design and construction, golden thread information must be held in an electronic facility that is secure from unauthorised access, with change control that records who changed what and when. Regulation 31 of the Building (Higher-Risk Buildings Procedures) (England) Regulations 2023 is explicit that previous versions of any updated document remain part of the thread.
At completion, the information is handed over in full, filing structure intact (reg 38). In occupation, section 88 of the Building Safety Act 2022 requires the accountable person to keep prescribed information to prescribed standards, keep it up to date so far as possible, and obtain anything they do not hold unless that is not practicable.
The requirements are deliberately about the state of the information, not the software: accurate, current, findable, version-controlled and available to those who need it. For the full list of what must be held, see our golden thread document list and checklist.
Dutyholder obligations by stage
| Stage | Dutyholder | Golden thread obligations |
|---|---|---|
| Design | Client, principal designer | Plan and establish the electronic facility; ensure the design information needed for the golden thread is produced and structured |
| Construction | Client, principal contractor | Maintain the facility; record changes with version control; keep the information accurate and up to date as work proceeds |
| Gateway 2 / 3 | Client, principal contractor | Submit the documents required for building control approval; retain the approved set in the thread |
| Handover | Client / principal contractor | Transfer the complete thread to the accountable person, filing structure intact (reg 38) |
| Occupation | Accountable person / principal accountable person | Keep prescribed information up to date; obtain missing information unless not practicable (s.88); support the safety case report |
Sources: GOV.UK guidance; SI 2023/909 Part 4; CLC, Delivering the golden thread (PDF).
The standards the information must meet
- Electronic - held in an electronic facility, not paper files or personal drives
- Secure - protected from unauthorised access and tampering
- Version-controlled - previous versions of updated documents retained as part of the thread
- Change-controlled - an audit trail of who changed what and when
- Accurate and current - kept up to date so far as possible across the life of the building
- Transferable - handed over intact when responsibility changes, including on sale
The Construction Leadership Council's dutyholder guidance adds what this means in practice: a single source of truth that the accountable person and the regulator can rely on, with a clear structure so information is findable when the 28-day building assessment clock starts.
Where dutyholders fall short
- Scattered files - information across drives, inboxes and personal laptops with no single facility
- No version control - superseded drawings still circulating because changes were never recorded
- Inconsistent naming - the same document filed three ways, so nothing is findable under pressure
- Missing metadata - no dates, statuses or owners on records, so accuracy cannot be demonstrated
- No gap record - nothing documenting what is missing and what was done to find it
The Building Safety Regulator has described refusals of building assessment certificate applications as showing process compliance rather than effective management of safety. A structured, validated golden thread is what turns paperwork into evidence.
Meeting the requirements, practically
- Receive - we review supplied digital scans, PDFs and exports
- Structure and index - consistent naming, folder structure, and a document register with metadata
- Validate - gaps flagged against the prescribed information set, duplicates removed, versions reconciled
- Deliver - an indexed register and manifest you can hand to the regulator or load into your CDE
Questions, answered
Do the golden thread requirements apply to existing buildings?
Yes. Section 88 of the Building Safety Act 2022 is retrospective: accountable persons for occupied higher-risk buildings must hold prescribed information, keep it up to date so far as possible, and obtain anything they do not hold unless it is not practicable to do so. The Building Safety Regulator expects reasonable enquiries for legacy buildings, not perfect historical records.
What information must be held in the golden thread?
The prescribed information set is defined by regulation 31 of the 2023 procedures regulations, and the industry's prescribed information table is maintained by the Building Safety Alliance. It spans gateway submissions, design and construction records, and occupation records such as the safety case, fire risk assessments, compliance certificates and registers. See our golden thread document list and checklist for the full breakdown.
What are the penalties for failing to meet the requirements?
Key offences under the Building Safety Act carry penalties of up to two years' imprisonment on indictment, and the duty falls on named individuals such as the accountable person, not just companies. Occupying an unregistered higher-risk building carries a continuing daily fine.
Who is the dutyholder for the golden thread?
During design and construction: the client, principal designer and principal contractor. Once the building is occupied: the accountable person (AP), and the principal accountable person (PAP) where there is more than one AP. The PAP has additional duties including preparing the building safety case report.
Does meeting the requirements mean buying golden thread software?
No. The regulations require an electronic facility with change control and secure access; the Building Safety Regulator has said the golden thread can be held across multiple systems. The hard part is the state of the information - structure, version history, metadata and completeness - which is a processing problem, not a software purchase.
Related guides
- What is the golden thread? - the requirement and who it applies to
- Golden thread document list & checklist - what must actually be kept, by stage
- Golden thread for existing buildings - the retrospective duty in practice
Need help putting this into practice?
We process, structure and validate golden thread records so they answer the regulator's questions. Every project is scoped and quoted individually.