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Notifiable vs Major Changes: The Post-Approval Regime That Can Stop Work

Updated 13 September 2026 9 min read Change Control Reviewed 13 September 2026

The two-minute summary

On this page

  1. Agreed documents and controlled changes
  2. Notifiable changes: tell BSR before the work starts
  3. Major changes: approval before any work
  4. Product substitution: the three-tier rule
  5. What a change submission must contain
  6. The cost of misclassification

Agreed documents and controlled changes

Once an application is approved, the documents uploaded with it are known as the agreed documents. BSR's change-control guidance is categorical: you must comply with the agreed documents throughout the build. Any change to them is a controlled change, and you must:

Separately, BSR must be told about any change of client, principal designer or principal contractor, and about changes to application contact details.

Notifiable changes: tell BSR before the work starts

Changes that could impact compliance with building regulations are notifiable changes. Per BSR's guidance these include changes to:

SubjectScope
Construction control planAny change to it
Change control planAny change to it
Individual residential unitsLayout or dimensions, where common parts are not affected
Service penetrationsNumber or dimensions of openings in a wall, ceiling or other element for pipes, ducts or cables
Wall ties / restraint fixingsIn any wall, excluding external walls or proposed walls
Fire documentationAny other change to the fire and emergency file or fire compliance statement
Partial completion strategyIf one was submitted with the application
Staged work statementsFor buildings constructed in stages

The mechanics: you must submit the notifiable change to BSR before the change is carried out or any related work starts — but once submitted, you can proceed. BSR may request further information, and you do not have to stop while responding. However, if BSR tells you the change should have been a major change application, related work must stop.

Major changes: approval before any work

Major changes undermine the basis on which the project was approved. A material change of use of any part of the building (for example, commercial units becoming residential) is a major change — as is needing a partial completion strategy after approval was granted without one. BSR's list of further examples includes changes to:

Stop means stop: before carrying out any major change you must stop building work relating to it, submit the major change application, and obtain BSR approval before resuming that work.

Product substitution: the three-tier rule

SubstitutionClassificationAction
Same, or higher, specification or class (subject to the fire-performance and other major-change criteria)RecordableRecord in the change control log.
Different reaction-to-fire specification — even if higherMay be notifiableAssess and, where notifiable, tell BSR before the work.
Lower reaction-to-fire specification or performance classificationMajorStop related work; major change application; BSR approval before proceeding.

Procurement-driven swaps are where this rule meets reality: supply-chain substitutions arriving mid-build must be classified before installation, not after.

What a change submission must contain

For each notifiable or major change, BSR expects:

Submissions go through the online manage-a-building-control-application service (application reference plus the original application email). Some changes may also need planning permission.

The cost of misclassification

Classification discipline is therefore not bureaucracy — it is the difference between a managed variation and a compliance event. The mechanics of that Gateway 3 reckoning are covered in our completion certificate guide.

Frequently asked questions

Do notifiable changes need BSR approval before work proceeds?

No — they must be submitted before the work starts, but once submitted you can proceed. BSR may ask for further information (no stop required while responding), and work must stop if BSR says the change should have been major.

Who submits changes?

Through the online manage-a-building-control-application service, using the application reference and access to the email used for the original application — typically the client or its authorised representative.

What if we are unsure whether a change is notifiable or major?

Assess against BSR's published lists and the three-tier product rule, and record the assessment. Seek competent advice and clarification from BSR where classification remains uncertain; do not start affected work that may require major-change approval.

Does changing the principal designer need BSR notification?

Yes. Changes of client, principal designer or principal contractor must be reported to BSR, as must changes to application contact details.

Where do changes get scrutinised later?

At the completion certificate: BSR reviews the change control log and any changes submitted during the build, and compares the original approved documents against the updated versions.

Discuss your submission

Ask about a document readiness review against an agreed scope. Customer intake opens after service qualification and an accepted engagement. Gate Zero does not provide BSR approval or design certification. Please do not attach submission documents to your enquiry.

Discuss a readiness review →
Sources & further reading
  1. BSR: assessing, recording and submitting controlled changes
  2. BSR: change control review at completion

This article is general guidance and not legal or building-control advice. Regulatory references reflect the position at 13 September 2026.