Accountable Person, Principal Accountable Person and Responsible Person: what is the difference?

In England, the Building Safety Act 2022 uses Accountable Person and Principal Accountable Person for higher-risk buildings; the Fire Safety Order uses Responsible Person in England and Wales. The labels sound similar, but they come from different regimes and can point to different people.

Who is the Accountable Person under the Building Safety Act?

An Accountable Person under the Building Safety Act is the person or organisation that holds a legal estate in possession in any part of the common parts of a higher-risk building in England, or has the relevant repairing obligation for those parts. Section 72 defines one route as “a person who holds a legal estate in possession in any part of the common parts,” and Part 4 is limited to a “higher-risk building” meaning “a building in England that—”. That England-only point matters: although the Act has an England-and-Wales extent label, the AP/PAP higher-risk-building regime is not operating for Wales, and Scotland and Northern Ireland do not use this Building Safety Act AP label. A maintenance contractor is not made an Accountable Person just because it is paid to look after the building: government guidance says, “A management company operating under a contract which requires it to carry out maintenance is not an AP.”

What is the difference between the Accountable Person and the Principal Accountable Person?

The difference between an Accountable Person and the Principal Accountable Person is that there can be several Accountable Persons for one higher-risk building, but there is only one Principal Accountable Person who leads the Building Safety Act registration and occupied-building duties. If there is only one AP, the statute says the PAP is “in relation to a building with one accountable person, that person;”. If there is more than one AP, the Principal Accountable Person under the Building Safety Act is the one connected with the structure and exterior: section 73 points to the AP who “holds a legal estate in possession in the relevant parts of the structure and exterior of the building”. In practice, the PAP is often an organisation rather than an individual owner; government guidance says, “The PAP is usually an organisation, like a commonhold association, local authority or social housing provider.” The key difference between accountable person and principal accountable person is therefore hierarchy, not a separate class of building owner.

What is the difference between an Accountable Person and a Responsible Person?

An Accountable Person is a Building Safety Act duty-holder for an occupied higher-risk building in England, while a Responsible Person is the Fire Safety Order duty-holder for premises in England and Wales where someone has control in connection with a trade, business or undertaking. The Fire Safety Order defines the Responsible Person route as “the person who has control of the premises (as occupier or otherwise) in connection with the carrying on by him of a trade, business or other undertaking,” whereas the Building Safety Act AP role is tied to legal estates or repairing obligations in higher-risk buildings. The roles stay legally separate: section 109 says, “The accountable person must cooperate with each responsible person for the purpose of each responsible person carrying out their duties under the Order.” In some blocks the accountable person vs responsible person question has the same practical answer, because guidance says, “In some buildings an AP or PAP will also be the Responsible Person.” Scotland instead imposes fire duties on the employer, and Northern Ireland uses the term appropriate person.

When must a Principal Accountable Person be appointed?

A Principal Accountable Person is not appointed at all: in England the PAP is identified automatically by section 73, either because there is one Accountable Person or, if there is more than one, because one has the structure-and-exterior role fixed by law. For a single AP building, section 73 says the PAP is “in relation to a building with one accountable person, that person;”. For a multi-AP building, the provision applies “in relation to a building with more than one accountable person,” and then selects the legally specified AP rather than allowing the parties to choose. The real timing point is not a PAP appointment deadline but registration before lawful occupation: section 77 says, “The principal accountable person for a higher-risk building commits an offence if the building is occupied but not registered.” For existing occupied buildings, section 77 was commenced on 1 October 2023, because the commencement regulations brought into force “section 77 (occupation: registration requirement);”.

What does the Principal Accountable Person have to register?

The Principal Accountable Person has to register the higher-risk building with the Building Safety Regulator, and the widely quoted £251 fee is not now set by the registration regulations because regulation 20 was omitted on 1 October 2023 and the fee sits under the separate regulator-charging regime. Section 78 says, “On an application by the principal accountable person for a higher-risk building the regulator may register the building.” The application must identify the accountable-person structure: where there is one AP, the regulations require “the details relating to the AP of the building,” and where there is more than one AP they require “confirmation of who is the PAP,”. The current GOV.UK registration page says, “You’ll also need a credit or debit card to pay the £251 application fee for each building.” Abodient can hold each building’s compliance obligations, certificate evidence and expiry status, which matters because registration is only one part of the ongoing higher-risk-building compliance record.

Last reviewed August 2026.

Sources

• Building Safety Act 2022 s.72 — “a person who holds a legal estate in possession in any part of the common parts (subject to subsection (2)), or” Source
• Building Safety Act 2022 s.65 — “In this Part “higher-risk building” means a building in England that—” Source
• GOV.UK guidance, safety in high-rise residential buildings: accountable persons — “A management company operating under a contract which requires it to carry out maintenance is not an AP.” Source
• Building Safety Act 2022 s.73 — “in relation to a building with one accountable person, that person;” Source
• Building Safety Act 2022 s.73 — “holds a legal estate in possession in the relevant parts of the structure and exterior of the building, or” Source
• GOV.UK guidance, safety in high-rise residential buildings: accountable persons — “The PAP is usually an organisation, like a commonhold association, local authority or social housing provider.” Source
• Regulatory Reform (Fire Safety) Order 2005 art.3 — “the person who has control of the premises (as occupier or otherwise) in connection with the carrying on by him of a trade, business or other undertaking (for profit or not); or” Source
• Building Safety Act 2022 s.109 — “The accountable person must cooperate with each responsible person for the purpose of each responsible person carrying out their duties under the Order.” Source
• GOV.UK guidance, safety in high-rise residential buildings: accountable persons — “In some buildings an AP or PAP will also be the Responsible Person.” Source
• Fire (Scotland) Act 2005 s.53 — “Each employer shall ensure, so far as is reasonably practicable, the safety of the employer's employees in respect of harm caused by fire in the workplace.” Source
• Fire and Rescue Services (Northern Ireland) Order 2006 art.38 — “In this Article, “appropriate person”, in relation to relevant premises, means a person subject to a requirement under Article 25 or 26 in relation to the relevant premises.” Source
• Building Safety Act 2022 s.77 — “The principal accountable person for a higher-risk building commits an offence if the building is occupied but not registered.” Source
• Building Safety Act 2022 commencement regulations, SI 2023/993 — “(q)section 77 (occupation: registration requirement);” Source
• Building Safety Act 2022 s.78 — “On an application by the principal accountable person for a higher-risk building the regulator may register the building.” Source
• Higher-Risk Buildings (Key Building Information etc.) (England) Regulations 2023 reg.11 — “11. Where there is only one AP for the building, the details relating to the AP of the building as follows—” Source
• Higher-Risk Buildings (Key Building Information etc.) (England) Regulations 2023 reg.12 — “(a)confirmation of who is the PAP,” Source
• Higher-Risk Buildings (Key Building Information etc.) (England) Regulations 2023 reg.20 — “Reg. 20 omitted (1.10.2023) by virtue of The Building Safety (Regulator's Charges) Regulations 2023 (S.I. 2023/965), regs. 1(5), 13(2)” Source
• GOV.UK guidance, applying to register a high-rise residential building — “You’ll also need a credit or debit card to pay the £251 application fee for each building.” Source