The Building Safety Act 2022 was introduced to make buildings safer after the Grenfell Tower fire. A big part of this law is the creation of the roles of the Accountable Person (AP) and the Principal Accountable Person (PAP). These roles help make sure that fire and structural safety in higher risk buildings is properly managed.

This article will explain what APs and PAPs are, what they’re responsible for, and how we support their compliance with the law.

What Is an Accountable Person?

An Accountable Person (AP) is someone who owns or has a legal responsibility to repair or maintain any of the common parts of a building. These parts include shared spaces like hallways, corridors, staircases, plant rooms, and the structure and exterior of the building. 

The AP might be a landlord, freeholder, or property management company, depending on who holds these responsibilities under a lease or legal agreement. Their duties begin once a building is occupied and are focused on keeping residents safe from risks caused by fire, structural failure, or similar hazards. These duties apply to the parts of the building they are responsible for, and the law makes it clear that this role cannot be delegated, even if another person is hired to carry out tasks on their behalf.

The Principal Accountable Person (PAP)

In some buildings, more than one person or organisation might be an AP. When there are multiple APs for a building, one must be clearly identified as the Principal Accountable Person (PAP).

The PAP is the AP who is legally responsible for the structure and exterior of the building. If there’s only one AP, they automatically become the PAP. But when several APs are involved, the PAP is the one with the most control over the building’s main physical structure.

In many cases, the PAP will be an organisation like a housing association or local authority. However, an individual can be the PAP too if they meet the criteria (e.g., a building owner or leaseholder responsible for the whole structure).

The PAP cannot be chosen or nominated. It’s a legal status based on who has the main duty to maintain the building’s safety.

What APs and PAPs Must Do

Both APs and the PAP have serious legal duties under the Building Safety Act 2022. They are responsible for managing the risk of fire and structural issues in higher risk buildings—generally those over 18 metres high or with at least 7 storeys and two or more residential units.

Their core duty is to manage building safety risks, meaning they must:

• Regularly assess the fire and structural safety of the areas they manage
• Take reasonable steps to stop safety issues before they happen
• Limit the damage if an incident does occur

These duties cannot be handed off. An AP or PAP may hire a managing agent to help with tasks, but the legal responsibility stays with the AP or PAP.

They must also:

• Cooperate with other APs in the building
• Share information with the Responsible Person under the Regulatory Reform (Fire Safety) Order
• Make sure residents are informed and involved
• Keep clear records of what’s being done to keep the building safe

The PAP has extra responsibilities. They must register the building, prepare key safety documents, and coordinate all safety efforts across the building.

Registering the Building

The Principal Accountable Person must ensure that the building is registered with the Building Safety Regulator (BSR) before anyone can live in it. This is a legal requirement for all higher-risk buildings, and failure to register could lead to enforcement action or prosecution. 

Registration involves submitting key details about the building’s design, structure, and use, including information about the exterior of the building and any common parts. If anything significant changes after registration, such as a structural alteration or a change in the person responsible for the building, the PAP must notify the BSR as soon as possible.

Creating a Safety Case Report

Once the building is registered, the PAP must prepare a safety case report. This is a detailed document that shows how the APs are managing fire and structural risks.

The safety case report should include:

• A summary of all safety risks
• What’s been done to prevent them
• How incidents would be handled if they did happen

This report is vital. The Building Safety Regulator can ask to see it at any time. If it’s missing or poorly maintained, enforcement action could follow.

Understanding the Golden Thread

The golden thread refers to important safety information about a building that must be kept up to date, accurate, and available digitally.

It includes:

• Records of building design and materials
• Fire safety features and systems
• Inspection reports
• Changes made over time
• Who has made key safety decisions

This thread must follow the building from design to demolition. APs and the PAP are responsible for making sure this information is properly managed.

Our app helps maintain this golden thread by tracking changes, storing documents securely, and making them accessible to the right people when needed.

Keeping Residents Informed

Residents must be kept up to date with building safety matters. The PAP is legally required to develop a resident engagement strategy that clearly explains how residents will be informed about safety measures, what changes may be made to the building, and how they can share concerns or ask questions. This isn’t just a box-ticking exercise—engaging residents helps to build trust and makes sure they understand their role in maintaining building safety. 

In addition, the PAP must create a system for handling complaints that relate to safety risks or how the APs are performing their duties.

Working With Others

In many buildings, several people may share responsibility for safety. These could include other APs, the Responsible Person under fire safety law, or contractors hired to carry out works. Everyone involved needs to work together, especially when responsibilities overlap. 

For example, if one AP manages a specific section of the building while another manages a different part, they must cooperate on inspections and safety decisions. The same applies when handing over building safety information to new parties. Clear communication and collaboration are essential to keep the whole building safe and legally compliant.

Showing You’re Competent

All Accountable Persons and the PAP must prove they are competent to do their job. This includes having the right skills, knowledge, and behaviours to carry out building safety tasks effectively. It’s also important to assess and monitor the ability of any contractors or managing agents working on your behalf. 

Organisations need to show they have the internal processes, resources, and staff to meet these legal obligations. Standards like PAS 8673 can be used to help define and assess competence, though they’re not legally required. Our platform supports this by allowing you to record qualifications, assign duties, track tasks, and monitor who is responsible for what, so you always know where you stand.

Penalties for Non-Compliance

The Building Safety Regulator (BSR) has wide powers. If an AP or PAP fails to do their job, the BSR can:

• Issue a compliance notice
• Demand urgent action to fix serious issues
• Apply to replace them with a Special Measures Manager
• Start legal action, which could lead to fines or prison

The most serious breaches include:

• Failing to register a higher-risk building
• Not submitting or updating the safety case report
• Ignoring requests from the BSR
• Failing to manage serious safety risks

Compliance is not optional. It is a legal duty that must be taken seriously.

Can Managing Agents Be APs?

Only if they hold a legal obligation to repair or maintain the common parts of a building, simply being appointed under a contract isn’t enough.

This is different from the Responsible Person role in fire safety law, which can be assigned based on who controls the premises. In contrast, APs and the PAP cannot pass their legal duties to someone else.

Even if a managing agent carries out all the daily tasks, the AP or PAP is still legally responsible.

That’s why it’s so important to track who is doing what—and whether they’re qualified to do it.

What If There’s a Dispute?

Sometimes it’s not clear who the AP or PAP is, especially in complex ownership structures. If there’s a disagreement, anyone with an interest in the building can apply to the First-tier Tribunal to decide:

• Who the Accountable Persons are
• Who the Principal Accountable Person is
• Which parts of the building each AP is responsible for

It’s better to resolve these issues early. At MosaicGT, we encourage users to keep roles clearly mapped and responsibilities documented within the system, helping to avoid confusion and disputes.

Final Thoughts

The roles of Accountable Person (AP) and Principal Accountable Person (PAP) are now a key part of building safety in England. The law expects clear, ongoing oversight of fire and structural safety risks in all higher-risk buildings.

These duties are complex, but they don’t have to be overwhelming. With the right systems in place, building owners and managers can stay compliant, protect residents, and avoid penalties.

We provide the digital tools to help you manage everything from your safety case report and golden thread to resident engagement and ongoing inspections. Our platform is designed to keep you in control, even when duties are shared or outsourced.

Building safety is everyone’s responsibility—but with MosaicGT, you don’t have to manage it alone.