Kitchen and bathroom refits in a high-rise flat: when do you need BSR approval?

A new kitchen or bathroom is the most common refurbishment in a flat. In a higher-risk building (HRB) in England, a building of at least 18 metres or 7 storeys with at least two residential units, it can also be the point where a simple job turns into a Building Safety Regulator (BSR) application.

The answer depends less on the size of the job than on what the work touches. Swapping a basin is exempt. Moving the basin, adding a circuit by the shower or cutting a new duct through a fire-separating wall is not. This guide goes through kitchen and bathroom work item by item. It is general information, not legal advice or a building control decision.

The short answer

• Like-for-like replacements are often exempt. GOV.UK lists replacing baths, toilets, basins and sinks as exempt work, along with most repairs and like-for-like replacements (GOV.UK).
• New services usually are not. New drainage, electrical work around baths and showers, new circuits, and heating system or fuse box replacement are building work.
• If any part of the job needs approval, the whole job goes in the application. GOV.UK says exempt or competent person scheme work that forms part of a wider project must be included in that project's application.
• The category matters. Work that changes the layout or affects fire safety is Category A, with the fuller set of documents.

Why the rules are stricter in a high-rise block

For an existing HRB, you must get BSR approval before starting building work. The only exceptions are work that is only exempt work, competent person scheme work, certain fibre optic cabling work, or an emergency repair (GOV.UK). Carrying out building work without the required approval is a criminal offence.

In a house, a kitchen fitter might simply notify the council. In an HRB, local authority building control and private approved inspectors cannot approve the work. BSR is the building control authority.

Kitchen and bathroom work, item by item

This table shows the usual position. It is a starting point, not a ruling: details on site can change the answer.

"A scheme" means a competent person scheme (see below).

Kitchens: the open-plan question

Most kitchen refits that cause trouble involve layout, not appliances. Many flats are designed with a protected entrance hall: a route from the bedrooms and living room to the front door that is separated from the kitchen by fire-resisting walls and doors. Knocking through to make an open-plan kitchen, or removing a kitchen door, can change that route.

Under regulation 12(6) of the Building (Higher-Risk Buildings Procedures) (England) Regulations 2023, work that changes the internal layout, or affects passive or active fire safety measures, is Category A. That is true whether or not the wall is load-bearing. See Can I remove or move a wall in a high-rise flat?

Also look at what sits above the units. Kitchen extract ducts, new pipe runs and recessed lighting can all pass through walls or ceilings that form part of the flat's fire separation. Work that affects fire stopping around new openings is Category A.

Bathrooms: where the water goes

A bathroom refit with every fitting in its original place, using the existing wastes, can often stay within the exemptions. Two changes tend to bring it into building control:

1. Moving fittings. A new position usually means new drainage. In a block, that can mean new connections to a shared soil stack, often in a riser that is part of the building's common parts.
2. Showers and electrics. Electrical work around baths and showers is outside the exemption. An electric shower usually needs a new circuit too.

Turning a bathroom into a wet room, or moving a bathroom into another room, needs careful thought. It can involve new drainage, new floor build-ups or penetrations, and sometimes a layout change.

Competent person schemes in a high-rise block

Electricians and heating engineers registered with a competent person scheme can normally self-certify their own work. In an HRB, GOV.UK says you should check with the scheme provider whether it covers work on HRBs (GOV.UK).

The client also has a duty here. Since October 2023, where self-certified work relates to a higher-risk building, the client must make the installer aware that the building is higher-risk (The Building Regulations etc. (Amendment) (England) Regulations 2023, regulation 12).

Do not assume a scheme route is open. Some schemes have stepped back from work in taller buildings, as the window schemes have. See Replacing Windows in a High-Rise Flat. And remember the rule above: if the scheme work is part of a bigger project that needs approval, it goes in that application.

Category A or Category B?

If your refit needs approval, test it against the nine Category A descriptions in regulation 12(6). A refit that moves walls, affects fire-resisting construction, alters detection or touches a riser or other common part is Category A.

A refit that needs approval only because of, say, a relocated basin within the same room may fall into Category B, with a lighter application. GOV.UK warns that applying under the wrong category is likely to lead to rejection (GOV.UK). See Category A or Category B? How BSR classifies work in a high-rise flat.

The government is minded to take most work inside flats out of Category A, but no new regulations have been made and no timetable has been given (Charles Russell Speechlys). Plan on the current rules.

How long approval takes

For work to an existing HRB, BSR has up to 8 weeks to decide, unless you agree a longer period. In practice it takes longer. BSR's own data for the 12 weeks to 5 October 2026 shows a median of 31 weeks for internal refurbishment applications, or 21 weeks for applications submitted in 2026 (BSR data). See How long does BSR approval take?

Before you book the fitter

1. Confirm the building is higher-risk. See How do I find out whether my building is higher-risk?
2. Write down every item of work. Include strip-out, new pipe and cable routes, ducts, ceilings and making good.
3. Sort each item: not building work, exempt, scheme work, or needs approval.
4. Ask for the fire information. The accountable person or managing agent should be able to tell you which walls, doors and ceilings are fire-resisting.
5. Check your lease. Freeholder consent is a separate requirement from BSR approval. See Lease consent, freeholder consent and BSR approval: what is the difference?
6. If anything needs approval, apply before you start, and build the decision time into the programme.

The bottom line

A like-for-like kitchen or bathroom refit in a high-rise flat can often go ahead without a BSR application. Moving fittings, new circuits, work around the shower, heating changes and anything that opens up fire-separating construction usually cannot. Sort the work item by item before anyone starts stripping out.

Sources

• GOV.UK: Building control approval for higher-risk buildings (updated 1 October 2026)
• legislation.gov.uk: The Building (Higher-Risk Buildings Procedures) (England) Regulations 2023, regulation 12
• legislation.gov.uk: The Building Regulations etc. (Amendment) (England) Regulations 2023, regulation 12
• GOV.UK: Preparing information for a building control approval application
• Making Buildings Safer: BSR building control approval application data
• Charles Russell Speechlys: Building safety update, including the recategorisation of certain higher-risk building works