The Ministry of Housing, Communities & Local Government (MHCLG) has published an update to its Remediation Acceleration Plan (RAP) which was originally published on 2 December 2024.

As explained in detail in our previous insight on the RAP, it sets out the Government's plan to accelerate the remediation of residential buildings over 11 metres in height with unsafe cladding in England.

The updated RAP outlines progress and new measures to meet three core objectives:

  • Fix buildings faster
  • Identify all residential buildings which are 11 metres (or above) in height with unsafe cladding
  • Support residents throughout the remediation process

In this article, we outline some of the key points arising out of the updated RAP and consider what this means for the UK construction and housing sectors. From the proposed Remediation Bill and new enforcement powers to improved building identification systems and resident support measures, we examine how these changes aim to accelerate the remediation of unsafe buildings over 11 metres and reshape the future of building safety regulation in England.

Fixing buildings faster

The updated RAP indicates that, to expedite remediation a new "Remediation Bill" will be introduced, establishing a "Legal Duty to Remediate", with criminal penalties for non-compliance. 

This will make it an offence for "any person to obstruct another from assessing or remediating an unsafe building over 11 metres in height, without a reasonable excuse."

Notably, by the end of 2029:

  • Any landlord who has failed to remediate a building over 18 metres - without reasonable excuse - will face criminal prosecution, with unlimited fines and/or imprisonment; and
  • Buildings between 11 and 18 metres that have not been remediated or scheduled for completion by the end of 2029 will be escalated for investigation and enforcement.

The timeline for introduction of the Remediation Bill is not yet clear: the RAP indicates that it will be brought forward "as soon as parliamentary time allows".

The updated RAP also outlines that:

  • New "Remediation Backstop" powers will be granted to local authorities and Homes England, who will be able to apply to the First-tier Tribunal for permission to undertake remedial works themselves directly (and recover the costs from the landlord), where enforcement options have been exhausted.
  • If those costs are not met, landlords could have their building subject to an enforced sale to fund repayment.
  • A Remediation Enforcement Unit will be established within the Building Safety Regulator to oversee enforcement for buildings 18 metres and above in height.
  • Regional coordination will be supported through Local Remediation Acceleration Plans, which will be delivered by Mayoral Strategic Authorities.
  • Statutory standards and oversight of Fire Risk Appraisals of External Walls (FRAEWs) will be tightened. FRAEWs will be legally required to follow the PAS 9980 framework (which itself is under review, with updated guidance expected in early 2026) and be conducted by assessors who meet specified requirements. Again, timing is unclear – the updated RAP indicates that this will also be done "when parliamentary time allows".

Identifying at-risk buildings

Progress has been reported following the launch of a "national identification drive" in November 2024.

Using Ordnance Survey data, Homes England has made rapid progress and completed a review of 212,000 records by March 2025, and is on track to identify the "vast majority of relevant 11m+ buildings with potentially unsafe cladding by the end of the year".

The updated RAP also highlights Home England's Tell-Us Tool, which allows residents, leaseholders and other stakeholders to report concerns about life-safety fire risks on the external walls of a building

In addition, one of the main barriers to identifying unsafe buildings over metres in height – namely, that their details are held across multiple databases at the national and local level – will be addressed.

The National Remediation System, run by Homes England, will become the single source of reference for all buildings over 11 metres. This will centralise data and improve oversight.

Supporting residents

Key initiatives include:

  • To ensure that cladding remediation funding is driven by risk, rather than an arbitrary height requirement, the updated RAP sets out the Government's intention to provide funding in those exceptional cases where multi-occupied residential buildings under 11 metres have life-critical fire safety risks from cladding and do not have an alternative route to funding.
  • Updates to the Code of Practice for the Remediation of Residential Buildings, to outline the health and safety information that residents should receive, from Autumn 2025.
  • Renewal of the industry-led Fire Safety Reinsurance Facility for a second year to support building owners trying to find the best deal for their residents.
  • Announcement of new funding for a longer-term and more sustainable approach to funding common fire alarms where they are needed, building on the success of the Waking Watch Replacement Fund.

The updated RAP also highlights the introduction of the Building Safety Levy which has now been confirmed will come into effect on 1 October 2026.

What the updated RAP means for the industry

As noted in our previous insight on the RAP, the industry has spent the last two and a half years familiarising itself with, and adjusting to, the Building Safety Act – which was arguably the biggest legislative change to building safety regulation in a generation.

However, both the original RAP and its update, together with the Grenfell Inquiry Phase 2 Report and the Government response on the Phase 2 Report, indicate that further change, and new legislation, is on the horizon.

Our leading Building Safety team, which advises on a myriad of issues relating to building safety and has expertise drawn from a specialist cross-discipline team, continues to monitor developments in this area and is available to advise our clients on the impacts for their business.

If you have any questions about the issues raised in this article, please get in touch with Gemma Whittaker or Natalie Barton-Howes.