The introduction of the Building Safety Act 2022 and the new higher-risk building (HRB) building control regime has fundamentally changed how certain building work is approved in England. For organisations involved in replacing fire doors in higher-risk buildings, understanding the Gateway 2 process is essential.
One area that has attracted increasing industry attention is whether replacement fire doors can be self-certified, avoiding the need for Building Safety Regulator (BSR) approval. At present, there is no approved self-certification scheme that removes the requirement for building control approval for fire door replacements in higher-risk buildings.
What is Gateway 2?
Gateway 2 is the building control approval stage for higher-risk buildings. It is a statutory stop/go point, meaning that relevant building work cannot begin until approval has been granted by the Building Safety Regulator.
Gateway 2 replaced the previous building control deposit of plans stage for higher-risk buildings. Applications must demonstrate how the proposed work complies with the Building Regulations and include the information required by the Building Safety Regulator.
The Gateway process applies to both the construction of new higher-risk buildings and certain building work carried out on existing higher-risk buildings.
Fire Door Replacements
Replacing flat entrance fire doors or other fire-resisting doors within a higher-risk building may constitute controlled building work requiring Building Safety Regulator approval, depending on the nature and scope of the works.
The Building Safety Regulator’s guidance explains that applications for work on existing higher-risk buildings must be submitted before relevant building work begins and must demonstrate compliance with the Building Regulations.
Is Self-Certification Currently Permitted?
At present, no self-certification scheme exists that allows contractors to replace fire doors in higher-risk buildings without following the applicable building control approval process.
However, in 2026 the Building Safety Regulator launched a Call for Evidence as part of its review of the Conditions of Authorisation for existing self-certification schemes. As part of that review, the regulator is seeking evidence on the potential introduction of a future self-certification scheme covering fire doorset installations, maintenance and replacements in England and Wales.
The consultation specifically explores whether certain fire door works in both higher-risk and lower-risk buildings could, in future, be undertaken without formal building control approval where appropriate safeguards are in place. It is important to note that this is a consultation exercise and does not introduce any change to the current legal requirements.
Competence Remains Central
The higher-risk building regime places significant emphasis on competence. Dutyholders involved in higher-risk building work must demonstrate that they possess the appropriate skills, knowledge, experience and organisational capability for the work they undertake. These competence requirements form part of the wider regulatory framework introduced through the Building Safety Act.
Looking Ahead
The Building Safety Regulator continues to refine the Gateway 2 process and has reported improving approval rates alongside the publication of additional guidance and a remediation toolkit to assist applicants.
Should a dedicated self-certification scheme for fire door replacements be introduced following the current Call for Evidence, it would represent a significant development for the fire door industry. Until then, organisations carrying out fire door replacement work in higher-risk buildings should continue to follow the existing Building Safety Regulator approval process where it applies and ensure that all work complies with the Building Regulations.
