“It’s a huge piece of legislation that’s been enforced for three years now,” said Paul Nash, construction consultant, Jansons Property. “And a common misconception is that it doesn’t apply to hotels.” This misunderstanding stems from the fact that Grenfell Tower was a residential building.

What counts as a higher-risk building?

The Act sets out stringent obligations for the developers and owners of higher risk buildings; defined as 18 metres or more in height, at least seven storeys, and primarily residential. These obligations clearly apply to student accommodation, serviced apartments, and co-living.

If a hotel includes at least two serviced apartments or is part of a mixed-use development that qualifies as a higher-risk building, then the obligations apply too.

The Shard, a famous landmark in the London skyline, consists of 26 floors of offices, three floors of restaurants, 19 floors of hotel accommodation (Shangri-La) and 13 floors of residential apartments (the upper-level homes).

Because of its residential apartments, the Shard is now classified as a higher-risk building. At an industry event, a representative of the developer Sellar Property Group cast doubt on whether the Shard would get built today, given new post-Grenfell requirements. On balance, the benefits of having the residential units at the top would need to be weighed up against a whole range of implications for the rest of the building.

New rules apply to new builds and existing assets

In addition to the new legislation related to higher-risk buildings, the Building Safety Act has resulted in sweeping changes to all building regulations, which apply equally to existing and new projects.

This means that if you are interested in buying even relatively new assets, they may no longer comply with the new safety standards.

“I was talking to someone looking to acquire a co-living building in London and it is less than ten years old, but it doesn’t comply. They will need to reclad the entire building. They’re seeing it as an opportunity to make improvements and they’re going to install a sprinkler system as well,” said Nash.

It is now even more important for developers and owners to know as much as possible about their existing assets and their future projects.

“Understand your building or building project and if you’ve got non-compliance issues,” said Nash. “Because investors are going to ask those questions when they look to fund a project. Obviously, there’s a price tag and there are viability issues.”

Rethinking projects

The Building Safety Act is conditioning how developers and investors configure new projects. More than seven storeys? Think again.

Soraiya Salemohamed, ESG director, 4C Group, said: “We are starting our first PBSA tomorrow and obviously we had to consider the Building Safety Act from a development and financing point of view, and it was quite difficult.” The design was changed to a six-storey property so as not to meet the higher-risk building threshold.

Andy Illingworth, head of interior design, HLM Architects, said the Building Safety Act was “much needed.” It has changed the attitudes of designers and the construction industry “for the good,” and spells higher standards.

However, the new legislation requires certificates and documents that prove compliance at every stage, and this takes time.

Stakeholders and developers need to be aware of the Act’s impact on workflows: “It just means that the process is slower, more methodical, and I think that needs to be built into programmes right from the start,” he said.

Refurbishments uncover unknowns

New, slower workflows apply equally to refurbishments and conversions. “There's a massive number of existing buildings, all different ages and types of construction that have probably been built poorly over the years. And, you go into what looks like a quite straightforward interior design refurbishment, and then you unravel loads of things that were never known about at the start,” commented Illingworth. When refurbishing a hotel that is staying open for business, this can create a very tricky process, he added.

Salemohamed shared the same experience when dealing with a conversion. 4C Group secured financial backing to repurpose a new building plus planning permission to add further units. “But then when you start to investigate, you realise that there could be leakages or certain regulations or certain compliance hasn't been met, even with a new building, which is what happened to us,” she said.

The Building Safety Act has ushered in a new development reality for UK hotels. Hotels are not automatically exempt, and the Act applies more widely than many assume. Mixed-use schemes can trigger higher-risk building rules, adding significant complexity.

Developers must invest earlier in surveys, documentation, and compliance. Refurbishments may unearth unknowns that can transform viability. And it is not just building safety regulators who are enforcing the Act. It is insurers and lenders too.

All quotes taken from the ‘Balancing budget with innovations, ESG, safety and performance’ session at the Annual Hospitality Conference 2025 in Manchester.

The Shard, a famous landmark in the London skyline, consists of 26 floors of offices, three floors of restaurants, 19 floors of hotel accommodation (Shangri-La) and 13 floors of residential apartments (the upper-level homes).

Because of its residential apartments, the Shard is now classified as a higher-risk building. At an industry event, a representative of the developer Sellar Property Group cast doubt on whether the Shard would get built today, given new post-Grenfell requirements. On balance, the benefits of having the residential units at the top would need to be weighed up against a whole range of implications for the rest of the building.

New rules apply to new builds and existing assets

In addition to the new legislation related to higher-risk buildings, the Building Safety Act has resulted in sweeping changes to all building regulations, which apply equally to existing and new projects.

This means that if you are interested in buying even relatively new assets, they may no longer comply with the new safety standards.

“I was talking to someone looking to acquire a co-living building in London and it is less than ten years old, but it doesn’t comply. They will need to reclad the entire building. They’re seeing it as an opportunity to make improvements and they’re going to install a sprinkler system as well,” said Nash.

It is now even more important for developers and owners to know as much as possible about their existing assets and their future projects.

“Understand your building or building project and if you’ve got non-compliance issues,” said Nash. “Because investors are going to ask those questions when they look to fund a project. Obviously, there’s a price tag and there are viability issues.”

Rethinking projects

The Building Safety Act is conditioning how developers and investors configure new projects. More than seven storeys? Think again.

Soraiya Salemohamed, ESG director, 4C Group, said: “We are starting our first PBSA tomorrow and obviously we had to consider the Building Safety Act from a development and financing point of view, and it was quite difficult.” The design was changed to a six-storey property so as not to meet the higher-risk building threshold.

Andy Illingworth, head of interior design, HLM Architects, said the Building Safety Act was “much needed.” It has changed the attitudes of designers and the construction industry “for the good,” and spells higher standards.

However, the new legislation requires certificates and documents that prove compliance at every stage, and this takes time.

Stakeholders and developers need to be aware of the Act’s impact on workflows: “It just means that the process is slower, more methodical, and I think that needs to be built into programmes right from the start,” he said.

Refurbishments uncover unknowns

New, slower workflows apply equally to refurbishments and conversions. “There's a massive number of existing buildings, all different ages and types of construction that have probably been built poorly over the years. And, you go into what looks like a quite straightforward interior design refurbishment, and then you unravel loads of things that were never known about at the start,” commented Illingworth. When refurbishing a hotel that is staying open for business, this can create a very tricky process, he added.

Salemohamed shared the same experience when dealing with a conversion. 4C Group secured financial backing to repurpose a new building plus planning permission to add further units. “But then when you start to investigate, you realise that there could be leakages or certain regulations or certain compliance hasn't been met, even with a new building, which is what happened to us,” she said.

The Building Safety Act has ushered in a new development reality for UK hotels. Hotels are not automatically exempt, and the Act applies more widely than many assume. Mixed-use schemes can trigger higher-risk building rules, adding significant complexity.

Developers must invest earlier in surveys, documentation, and compliance. Refurbishments may unearth unknowns that can transform viability. And it is not just building safety regulators who are enforcing the Act. It is insurers and lenders too.

All quotes taken from the ‘Balancing budget with innovations, ESG, safety and performance’ session at the Annual Hospitality Conference 2025 in Manchester.

By Ben Walker