Upstream Risk Intelligence supports Principal Accountable Persons in discharging their statutory duties under the Building Safety Act 2022. We are an AI-native building safety practice — combining deep statutory expertise with AI-augmented compliance management to deliver Building Safety Case development, golden thread architecture, and regulatory engagement at a standard and pace that conventional approaches cannot match.
Building safety compliance done properly is not a precondition for good estate management — it is good estate management. An HRB that lacks a defensible Building Safety Case, a functioning golden thread, and competent duty-holder oversight is not being managed — it is being administered. We deliver building safety and estate management as a single integrated service, with BSA 2022 compliance as the structural foundation on which everything else is built.
The non-delegable PAP duties under the Building Safety Act 2022 are the bedrock of safe HRB management. We support PAPs across the full statutory compliance cycle — Building Safety Case development, golden thread architecture, fire strategy governance, MOR frameworks, resident engagement, and direct BSR engagement. Without this foundation, nothing else is compliant.
Estate management of an HRB is qualitatively different from conventional property administration. Service charge governance, contractor procurement, planned maintenance, and Section 20 consultation must be structured around the building's compliance obligations — not treated as separate functions. Because our BSA 2022 foundation is already in place, our estate management is genuinely compliance-led: the golden thread, the risk register, and the contractor governance framework are not add-ons. They are the operating infrastructure.
The same statutory intelligence that powers our BSA compliance work informs every decision in our estate management — this is what compliance-led management actually means in practice.
The Building Safety Act 2022 and the Building Safety Regulator have created a regime in which the competence and accountability of those responsible for higher-risk buildings is no longer assumed — it must be demonstrated.
Building Safety Cases must be maintained as live documents. Golden thread obligations require systematic information architecture. Resident engagement duties are statutory. The consequences of failure are personal, serious, and enforced.
"We are an AI-native building safety practice — compliance-first by design, technically rigorous by necessity, built around the statutory duties created by the Building Safety Act 2022."
We operate at the level the PAP duty demands. Every service is grounded in the legislation and delivered by an AI-native team — combining direct statutory experience across one of the largest HRB portfolios in England with AI-augmented document management, compliance tracking, and regulatory analysis.
BSA 2022 compliance is not a prerequisite for estate management — it is the infrastructure on which competent estate management of an HRB is built. These two service areas are described separately below, but they are delivered as one.
The Building Safety Act 2022 places non-delegable duties on the Principal Accountable Person of every registered higher-risk building. Those duties cannot be transferred — but the PAP must be supported by competent persons with demonstrable expertise across each element of the compliance cycle. We provide that support directly — as an AI-native practice — with the technical depth, regulatory literacy, and document management capability the BSA 2022 framework demands.
Our BSA service covers the full statutory compliance cycle: from initial building registration and BSC development through to ongoing golden thread maintenance, regulatory submissions, and resident engagement. Every engagement begins with a structured gap analysis against the BSA 2022 duty framework and produces a Statement of Works that the PAP can rely on as a defensible compliance record. We maintain active engagement with the BSR at a senior level — including live Building Safety Case submissions and Mandatory Occurrence Reporting — and operate across environments where the legal boundaries of the BSA 2022 are being tested at the highest judicial levels. This depth of regulatory exposure directly informs how we structure compliance programmes for clients.
Any building in England that is a higher-risk building as defined under s.65 BSA 2022 — a multi-occupied residential building of at least 18 metres or 7 storeys containing at least two residential units. URI has live operational experience at both portfolio scale (68 HRBs across a single interconnected estate) and individual registered HRB level, with active BSC development in progress for a client building.
URI is developing a managing agent capability grounded in building safety compliance, not conventional property administration. The distinction matters: estate management of an HRB requires a managing agent that understands the statutory framework it is operating within — including the relationship between the service charge regime, planned maintenance obligations, and the building's ongoing compliance position under the BSA 2022.
Our estate management proposition is compliance-led from the outset. Service charge governance, contractor procurement, planned maintenance scheduling, and Section 20 consultation are structured around the building's compliance obligations, not separate from them.
Residents' Management Companies (RMCs), Right-to-Manage companies, and freehold-owning entities seeking a managing agent that treats building safety compliance as a first-order obligation, not an afterthought.
Upstream Risk Intelligence (URI) is a building safety management practice operating under the Building Safety Act 2022 regulatory framework. URI was established to provide competent, accountable, and technically rigorous building safety management to higher-risk residential buildings in England — a sector where the gap between regulatory demand and management quality is significant and consequential.
We are not a generalist property management business. Our practice is structured around the duty framework created by the BSA 2022 and has been built — as an AI-native capability — to support PAPs in discharging their non-delegable statutory responsibilities at scale. The service proposition is compliance-first by design, not by aspiration — founded on direct operational experience at PAP level across one of the largest HRB portfolios in England, and delivered through an AI-augmented platform that brings statutory precision and operational efficiency to every engagement.
Our commercial model is live and operational. We are the appointed building safety manager for a registered HRB, with full BSC development and golden thread remediation in progress. This runs in parallel with a building safety management engagement covering 68 higher-risk buildings across a single interconnected residential estate — one of the most complex HRB portfolios under active management in England. We support the PAP across the full statutory compliance cycle, maintain active engagement with the Building Safety Regulator at a senior level — including live BSC and MOR submissions — and operate in environments where the legal application of the BSA 2022 is being tested at appellate court level.
Our team brings together practitioners with direct experience across the full building safety management discipline — from supporting PAPs in discharging their statutory duties and Building Safety Case development through to fire engineering oversight, structural assessment, and legal governance. We have been operational since the Building Safety Act 2022 came into force, built around its requirements from the outset, not retrofitted to meet them.
Our background spans safety-critical asset management in high-hazard industries, structured audit and assurance methodology, and senior-level engagement with regulators, boards, and institutional clients. This breadth distinguishes us from practitioners who have entered the building safety sector from a conventional property management background — the analytical and governance disciplines are different in kind, not just degree.
We work with specialist fire engineers, structural engineers, and legal advisers as part of an integrated delivery model. These relationships are established and operational, not sourced reactively. Every engagement draws on the appropriate discipline at the appropriate point in the compliance cycle.
Effective building safety management under the BSA 2022 framework demands competence across a range of disciplines that rarely sit within a single practice. We have structured our delivery model to ensure each is covered — either directly or through established specialist relationships.
| Discipline | Application | Delivery |
|---|---|---|
| Building Safety Management | Supporting PAPs in discharging their statutory duties — BSC development and maintenance, golden thread architecture, MOR framework, resident engagement, regulatory submissions | URI core — operational across 68 registered HRBs and a standalone registered HRB since BSA 2022 commencement |
| Safety-Critical Asset Management | Risk governance, permit-to-work frameworks, contractor supervision, safety case methodology in high-hazard environments | URI core — background in high-hazard industrial environments directly transferable to HRB management |
| Audit & Assurance | Evidence-based BSC governance, golden thread documentation standards, compliance gap analysis, structured reporting | URI core — structured assurance methodology applied to building safety compliance |
| Fire Engineering | Fire strategy governance, cause-and-effect commissioning, FRA oversight, multi-consultant dispute resolution | Specialist relationships — established fire engineering input to URI engagements |
| Structural Engineering | Structural appraisal reports for BSC, assessment of structural risk within the safety case narrative | Specialist relationships — structural engineering input procured and overseen by URI |
| Legal / Regulatory | BSA 2022 duty interpretation, director liability, s.161(4) protocols, leasehold and service charge disputes | Specialist relationships — legal input integrated into URI compliance frameworks |
| ESG & Institutional Governance | Senior management engagement, board-level reporting, regulatory disclosure frameworks | URI core — background in institutional ESG and governance at board level |
Most building safety management propositions are untested at the point of instruction. Ours is not. We are an AI-native building safety practice — our compliance programmes, golden thread architecture, and regulatory submissions are built on an AI-augmented platform that delivers a standard of documentation and analytical rigour that conventional approaches cannot replicate. We provide active building safety management support across two distinct HRB environments — one at portfolio scale, one as a standalone registered HRB under active BSC development — with direct experience of the full PAP duty cycle in both contexts.
The following is a structured summary of URI's current operational evidence base. Client-confidential details are not disclosed. The facts set out below are verifiable.
We provide building safety management support to the PAP across a portfolio of 68 registered HRBs on a single interconnected residential estate. This is one of the largest concentrations of registered HRBs under active management in England, with a complex multi-stakeholder governance structure involving institutional shareholders, a professional managing agent, and multiple specialist consultants.
We are the appointed building safety manager for a Residents' Management Company operating a registered HRB. The building presented significant historical compliance gaps — no O&M records, no golden thread infrastructure. We produced a structured Statement of Works, deployed a Resident Engagement Strategy, established an MOR framework, and is progressing BSC development alongside a s.161(4) Director Protection Protocol for the RMC board.
We manage fire strategy governance across complex scenarios, including cases where multiple fire engineering consultants have issued conflicting strategies for the same building. This requires technical literacy in fire engineering outputs, understanding of Regulation 3 sequencing risk, and the governance capability to establish a definitive engineering instruction with regulatory defensibility.
Our regulatory engagement extends beyond routine submissions. We are actively engaged with the Building Safety Regulator at a senior level — including live Building Safety Case submissions, Mandatory Occurrence Reporting, and direct engagement with BSR's operational and enforcement functions. We operate within the Change Control regime under the Higher-Risk Buildings Procedures Regulations 2023 and has managed active LFB Deficiency Notice responses with structured remediation programmes. The breadth of this engagement — across a portfolio of 68 registered HRBs — places us among a small number of practices with direct, sustained experience of the BSR's regulatory expectations in practice.
We have designed and are implementing golden thread remediation programmes for buildings with no historical O&M records — the hardest starting position under the BSA 2022 framework. This includes fire alarm panel configuration records, as-built drawing inventories, fire strategy document version control, and cause-and-effect commissioning records.
URI is an AI-native building safety practice. Our compliance programmes, Building Safety Case development, golden thread architecture, and regulatory submissions are built on an AI-augmented platform — delivering a standard of documentation, analytical rigour, and version control that conventional approaches cannot replicate at comparable speed or scale. This is not AI as a productivity tool layered onto a traditional practice. It is the operational foundation of how we work.
We have produced and implemented contractor governance frameworks across a large residential estate — including permit-to-work scripts, pre-registration controls for contractor access to HRBs, toolbox talk programmes for site staff, and structured safety concern reporting mechanisms. These are operational documents, not templates.
We operate in environments where the legal boundaries of the Building Safety Act 2022 are being actively tested at the highest judicial levels. This includes direct operational involvement in matters engaging the courts on questions of relevant defect definition, the retrospective application of BSA 2022 remediation obligations, and the scope of accountable person liability. Our engagement with proceedings of this character — including cases before appellate courts — informs a compliance posture grounded in the current state of the law, not a static reading of the statute.
The following table sets out the principal statutory duties that URI supports PAPs in discharging. It is included here not as a credential claim, but as a precise statement of the regulatory environment in which URI's operational capability has been developed and tested.
| Duty / Obligation | Statutory Basis | Operational Context |
|---|---|---|
| PAP Duty Support | BSA 2022 s.68 | We support the PAP in discharging non-delegable duties across 68 registered HRBs — including downstream duty-holder management, competent person oversight, and regulatory accountability. The PAP retains the duty; we provide the competent person support required to discharge it. |
| Building Safety Case maintenance | BSA 2022 s.83 | Live BSC maintenance across portfolio. Includes annual review cycle, iterative development, and submission to BSR on request. |
| Golden Thread | BSA 2022 ss.88–90; HRB Procedures Regs 2023 | Structured information management programme — fire strategy documents, O&M records, panel configurations, as-built drawings. |
| Resident Engagement Strategy | BSA 2022 s.91; RES Regulations 2023 | Statutory RES deployed across client portfolio. Resident engagement discharge managed across all registered HRBs under URI management. |
| Mandatory Occurrence Reporting | BSA 2022 s.87; MOR Regulations 2023 | MOR framework designed and operational across client portfolio. Escalation route to BSR in place. |
| Competent Person Appointments | BSA 2022 s.68(2); PAS 8673:2022 | Assessment and ongoing oversight of fire risk assessors, structural engineers, building safety managers across portfolio. |
| Change Control | HRB Procedures Regs 2023 Part 4 | Change control governance across portfolio. BSR submissions managed directly. |
| Director Liability Protection | BSA 2022 s.161(4) | Director Protection Protocol structured and deployed for RMC client boards. |
URI accepts instructions from RMC directors, freeholders, developers, and their professional advisers. Initial enquiries should briefly describe the building type, location, and the nature of the instruction sought.
URI operates across England. For higher-risk buildings, please include the BSR building registration reference if the building is already registered.
The BSA 2022 regulatory framework continues to evolve — through secondary legislation, BSR guidance, and enforcement practice. The following reflects URI's current operational understanding of key developments.
On 27 January 2026, the Building Safety Regulator formally separated from the HSE to become a standalone executive non-departmental public body sponsored by MHCLG. The transition implements Grenfell Inquiry recommendations and signals a more assertive enforcement posture. Dutyholders and PAPs should anticipate increased regulatory scrutiny and more targeted engagement as the new body matures.
BSR standalone transition — GOV.UK →The BSR has published its first strategic plan as an independent body, covering April 2026 to March 2027. Five priority areas are identified, including a target to respond to non-complex Gateway 2 applications within 18 weeks. The plan signals continued focus on remediation, competence standards, and enforcement consistency. PAPs should review their compliance position against BSR's stated priorities.
BSR Strategic Plan 2026–27 — GOV.UK →On 25 March 2026, the BSR launched a 12-week consultation on proposed amendments to Approved Document B (Fire Safety), running until 17 June 2026. The consultation addresses long-recognised deficiencies in fire safety guidance — including revised guidance on external wall systems, combustible materials thresholds, and evacuation lifts in residential buildings above 18 metres. A significant early indicator of how the BSR is defining its regulatory priorities.
Approved Document B Consultation — DWF →Two recent decisions — one from the Technology and Construction Court, one from the First-tier Tribunal — illustrate the BSR's expanding enforcement toolkit in action. The Burstock Road case is the first test of the BSR's appeal powers under Reg 18A. Analysis from Gowling WLG notes that the Construction Products Reform White Paper also proposes tougher criminal sanctions, including up to two years' imprisonment and unlimited fines for product safety breaches.
BSR Enforcement Case Law — Gowling WLG →The BSR's latest Gateway 2 update (12-week period to 1 May 2026) reports 323 decisions with a 71% overall approval rate. Remediation approval rates are approaching the 65% minimum target for 2026. Legacy remediation applications have reduced from 42 to 20 since the start of 2026. The batching system is returning early assessments in a median of four weeks. A positive operational picture, though processing times for older applications remain extended.
Gateway 2 Update — Britbuild →The RIBA's April 2026 analysis of the BSR's strategic plan sets out five priority areas for April 2026 to March 2027 — including a target to respond to non-complex Gateway 2 applications within 18 weeks by March 2027. The plan also confirms the BSR's focus on upholding competence standards across the built environment, with mandatory qualifications for building managers coming into force later in 2026. Those supporting PAPs should ensure their competence position is documented and defensible.
BSR 2026 Plan — RIBA →The following are anonymised summaries of engagements drawn from URI's operational experience. Client and building identities are not disclosed.
Appointed as building safety manager for an RMC with no O&M records, no golden thread infrastructure, and no existing BSC. Building registered with the BSR but compliance programme not initiated.
URI produced a structured Statement of Works, designed and deployed a Resident Engagement Strategy meeting the statutory requirements of s.91 BSA 2022, established a Mandatory Occurrence Reporting framework, and initiated BSC development. A Director Protection Protocol under s.161(4) BSA 2022 was structured to protect unpaid RMC directors during the remediation period.
Outcome: BSC development in progress · RES live · MOR framework operational · Directors protectedSupporting the PAP across 68 registered HRBs on a single interconnected estate with institutional shareholders, a professional managing agent, and multiple specialist fire engineering and structural consultants. Active issues included conflicting fire strategies from multiple consultants, LFB Deficiency Notice response, and BSC submissions in progress.
URI managed fire strategy governance to establish a single governing engineering instruction, responded to the LFB Deficiency Notice with a structured remediation programme, and implemented contractor governance frameworks including permit-to-work controls and toolbox talk programmes across the estate.
Outcome: Governing fire strategy established · LFB notice response structured · Contractor governance liveFollowing a detailed survey identifying inaccuracies between fire alarm panel configurations and golden thread documentation across a portfolio of HRBs, URI designed and implemented a structured remediation programme. This included panel text correction, zone schedule reconciliation, cause-and-effect commissioning record updates, and version-controlled documentation architecture.
The programme produced a defensible, auditable golden thread record for each affected building, meeting the information management requirements under ss.88–90 BSA 2022 and the HRB Procedures Regulations 2023.
Outcome: Golden thread records corrected and version-controlled across portfolioA registered HRB with conflicting fire engineering instructions from two separately appointed consultants — a retrospective fire strategy and a subsequent design-stage strategy — with neither formally superseding the other. The building's O&M records referenced both, creating an unresolvable ambiguity in the operative fire strategy and a BSC narrative that could not be finalised.
URI managed the governance process to formally establish a single governing engineering instruction, addressed Regulation 3 sequencing risk, and updated the golden thread to reflect the definitive fire strategy with a clear audit trail.
Outcome: Single governing fire strategy established · BSC narrative unblocked · Regulation 3 risk resolvedThis notice explains how Upstream Risk Intelligence Ltd collects, uses, and protects personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
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