The gateways move your money, not just your programme
On a higher-risk building the gateways are hard stops. The lawyers read them as compliance. The QS should read them as dates that decide when cash comes in.
QScope Team · 27 June 2026 · 7 min read
The Building Safety Act 2022 sets up a separate regime for higher-risk buildings. Roughly, that means a building of at least 18 metres or seven storeys, with at least two residential units. The Building Safety Regulator, sitting inside the HSE, oversees them.
Most of the commentary on the Act reads it as a legal and safety matter. It is both. It is also, for the quantity surveyor, a set of dates that decide when money moves. That is the part the cost plan has to absorb.
Three gateways, two of them hard stops
The regime runs through three gateways across the life of the project.
| Gateway | Stage | What it does |
|---|---|---|
| 1 | Planning | Fire safety considered at the planning application stage |
| 2 | Before construction starts | Building control approval from the Regulator is required before work begins |
| 3 | Completion, before occupation | Sign-off required before the building can be occupied |
Gateway 2 and Gateway 3 are hard stops. Work does not start without the first, and the building is not occupied without the second. Neither is a formality that runs in the background while the job carries on.
A stop on the programme is a stop on the cash
A payment application values work done. Work does not get done during a hold. So a gateway hold does not just move a milestone to the right, it flattens the valuation curve for as long as it lasts.
Two points bite here.
- Gateway 2 sits before construction. If approval slips, the start slips, and every receipt in the cash flow slips with it. The forecast that assumed a spring start against a spring approval is wrong from the first line.
- Gateway 3 sits before occupation, which is often the moment a residential developer starts taking sales income or a purchaser completes. A hold there defers the inflow the whole deal was built to reach.
What the QS has to carry in the estimate
The Act creates real work, and real work has a cost. The dutyholder roles under the building regulations, the client, the principal designer and the principal contractor, mirror the CDM roles and carry their own duties. The golden thread of information has to be created and maintained. None of that is free, and none of it belongs only to the lawyers.
In cost terms, the items to name rather than bury are:
- Preliminaries that run across a gateway hold, because time-related cost keeps accruing while the valuation curve is flat
- The cost of preparing and assembling the information each gateway requires, as work in its own right
- Design and verification effort attached to the dutyholder duties, priced rather than assumed
- The financing cost of receipts that arrive later than the base programme said they would
Forecast against the gateway, not around it
The instinct on a hard stop is to leave it out of the forecast because the date is uncertain. That produces a cash flow that looks confident and is quietly wrong. The better move is the opposite: put the gateway on the timeline at the current best date, run the receipts off it, and update the date as it firms up.
That way the forecast shows the shape of the risk. If Gateway 2 approval is a month later than planned, the person reading the cash flow sees the start move and the first receipts move with it. If Gateway 3 sign-off is at risk, they see the sales income defer before it defers on the bank statement.
The check before you issue the forecast
- Is each hard-stop gateway on the timeline with a date, not left implicit?
- Do the receipts sit after the gateway that unlocks them, not before?
- Are preliminaries carried across any expected hold, rather than stopping when the valuation curve flattens?
- Is the cost of producing the gateway information priced as work, not assumed into overheads?
If all four hold, the forecast reflects the regime the building actually sits under. If the gateways are missing from the timeline, the cash flow is describing a project that is not governed by the Act, and this one is.
QScope builds cash flow on real dates, so a gateway hold that pushes receipts to the right is visible in the forecast before it lands on the account.