FIS is urging members to review and comment on its draft response to the Building Safety Regulator’s latest consultation on Category A and Category B works, ahead of a final submission at the end of May.

The consultation focuses on improving proportionality within the Higher-Risk Building (HRB) regime by reclassifying certain works and expanding the potential role of Competent Person Schemes (CPS). While the proposed reforms aim to reduce unnecessary bureaucracy and speed up delivery, they also signal a significant shift in how compliance is managed.

Following a detailed consultation workshop on 18 May, FIS members broadly welcomed the direction of travel, particularly the move to reclassify most in-flat works as Category B. This change is seen as long overdue, given that many routine activities – from internal partitions to fire door replacements – are currently captured within Category A, creating disproportionate levels of documentation and delay.

However, a number of critical issues were discussed that now form the core of the FIS response.

Mixed-use buildings – a key gap

One of the strongest themes from the meeting was the lack of consideration for mixed-use buildings.

The consultation currently focuses on residential units, but members emphasised that similar compartmented environments exist in other parts of buildings – including offices, retail spaces, and other commercial units. In these cases, comparable works could face very different regulatory treatment despite carrying similar levels of risk.

FIS is therefore questioning whether the current approach reflects modern building design and delivery, and is calling for greater consistency in how different unit types are treated. The response also highlights the need for clearer guidance to avoid confusion, particularly in projects where multiple uses sit within the same building.

Competence vs Capability – getting the balance right

Another key issue raised during the workshop was the shift towards competence-based regulation.

While members recognise the benefits of reducing reliance on prescriptive documentation, there is concern that current proposals place too much emphasis on individual competence, particularly through the expansion of self-certification schemes.

The FIS response stresses that successful delivery depends not only on skilled individuals, but also on organisational capability – including supervision, coordination, quality systems, and ongoing assurance. Existing certification schemes such as FIRAS and IFC were cited as providing this broader assurance, and members were clear that reforms should build on these frameworks rather than introducing new, overlapping accreditation requirements.

Guidance, clarity and practicality

Members also raised concerns about the practical implementation of the proposals, particularly around defining “small-scale” works using thresholds such as time and workforce. There was a strong view that these measures do not always align with real risk and could introduce further ambiguity.

As a result, FIS is calling for:

• Clearer, consolidated guidance
• Better alignment with real-world project delivery
• More practical examples to support consistent decision-making

Without this, there is a risk that the industry continues to default to Category A as a precaution, undermining the intended benefits of reform.

Have your say

FIS is now asking members to review the draft response and contribute any additional comments or examples from their own experience.

Deadline for comments: 26 May
Final submission: 28 May

This consultation represents a critical opportunity to shape how building safety regulation evolves, particularly for fit-out, refurbishment, and interiors work.

As Iain McIlwee commented during the session:

“This is about getting the balance right – reducing unnecessary burden without losing control of safety. But we need to make sure the system reflects how buildings are actually delivered.”

Members are encouraged to share feedback.  Details of the meeting and the draft response are available below.

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