What is cladding remediation?

Cladding remediation means removing and replacing unsafe external wall materials, along with any associated works needed to make the wall safe. In practice that can include the outer panels, insulation, cavity barriers, fire stopping and sometimes balconies - not just the visible cladding itself.

Does remediation include more than cladding?

Yes. Recent Tribunal guidance has confirmed that where additional works are needed to address a relevant building safety risk, they can form part of the remediation project. The scope is set by what the building actually needs, informed by a proper fire risk appraisal of the external wall, not just by what is visible on the outside.

Will leaseholders have to pay?

The Building Safety Act protects qualifying leaseholders from many remediation costs, and government funding routes such as the Building Safety Fund and Cladding Safety Scheme cover eligible works. Directors should always take specific advice before demanding contributions - the rules on what can and cannot be passed on are strict.

PAS 9980 is the recognised code of practice for carrying out a fire risk appraisal of external walls. A competent professional uses it to judge whether the external wall presents a tolerable, medium or high risk and to recommend proportionate remediation - avoiding both under- and over-reaction.

Do all buildings need an EWS1?

No. EWS1 was introduced for lender purposes and is not a legal requirement. Since RICS updates and the Building Safety Act, many buildings do not need one at all, and a PAS 9980 assessment is often more useful for genuine safety decisions. Whether an EWS1 helps depends on the building and the lender.

A Fire Risk Appraisal of External Walls (FRAEW) is the technical assessment output that follows a PAS 9980 investigation. It records what the wall is made of, the risks identified and the recommended actions - and forms the evidence base for any remediation project and funding application.

When should an RTM Company seek professional advice?

As soon as fire safety, external walls or building safety questions arise - ideally before any works are commissioned or leaseholders are asked to contribute. Early advice helps directors scope the right investigations, access funding where eligible and avoid decisions that create liability later.

Building safety professional inspecting the external wall and cladding of a UK residential apartment building

Building Safety Act

Building Safety Act: What Counts as Cladding Remediation?

Recent Tribunal guidance confirms that making a building safe may involve more than simply replacing external cladding. Here's what RTM Companies and RMC directors need to know.

Speak to Our Team Request a Management Proposal

Key takeaway

Making a building safe may involve more than replacing external cladding. External walls are systems rather than single materials, and how a fçade performs depends on several elements working together.

For leaseholders, RTM companies and RMCs, that means the scope of remediation work is shaped by the wall system as a whole, not only the visible cladding panels.

Why Was the Building Safety Act Introduced?

The Act is the product of a decade of reform. The path from Grenfell to today's leaseholder protections runs through five key steps.

1
Grenfell
A tragedy that exposed serious failings in high-rise fire safety.
2
New legislation
Government commits to reform of building safety and remediation.
3
Building Safety Act
New duties, funding routes and a Building Safety Regulator.
4
Stronger leaseholder protections
Qualifying leaseholders shielded from many remediation costs.
5
Safer residential buildings
A framework for identifying and fixing relevant safety risks.

Is Cladding the Only Issue?

External walls are systems, not single materials. A safe façade depends on how several elements work together.

Cladding

The outer façade panels most commonly associated with remediation.

Fire Stopping

Seals around service penetrations that stop fire spreading between compartments.

Cavity Barriers

Barriers within wall cavities designed to slow the spread of fire and smoke.

Balconies

Combustible balcony structures and finishes can create additional risk.

Insulation

Behind-the-panel insulation may itself be combustible and require attention.

External Wall Systems

The wall as a whole system, not just the visible outer skin.

The Tribunal's Decision

In plain English

Remediation under the Building Safety Act is not limited to replacing the visible cladding. Where additional works are necessary to address a relevant building safety risk - such as fire stopping, cavity barriers or supporting elements - they can properly form part of the remediation.

Scope follows the risk. The right question is what makes the wall safe, not which layer is on the outside.
Investigations matter. A proper PAS 9980 appraisal, and often intrusive opening-up, is essential before scoping works.
Leaseholder protections apply. Directors must respect the Act's cost-recovery rules when planning remediation.

What This Means

For RTM Directors

Better project planning. Scope the whole wall system before committing to works.
Professional investigations. Rely on PAS 9980, FRAEW and intrusive surveys - not guesswork.
Long-term compliance. A well-planned project keeps the block compliant for years, not months.

For Leaseholders

Improved building safety. Works are scoped around the risks that actually matter to residents.
Statutory protections. The Building Safety Act limits what qualifying leaseholders can be asked to pay.
Greater clarity. You should receive clear information about the scope, funding and timeline.

Professional Assessments

Serious remediation decisions rest on competent, independent assessment. These are the specialists and assessments a well-run project typically involves.

PAS 9980

The industry standard for assessing fire risk from external walls.

FRAEW

Fire Risk Appraisal of External Walls - the technical output of a PAS 9980 assessment.

Fire Risk Assessment

The building-wide FRA covering communal areas, escape routes and controls.

EWS1

External Wall System certificate used by lenders where required.

Structural Engineer

Advice on load-bearing elements, brackets and structural implications.

Fire Engineer

Bespoke fire-safety strategies where a standard approach isn't enough.

Intrusive Surveys

Opening up sections of the wall to confirm build-up and defects.

How East Valley Properties Helps

Building Safety Advice

Practical guidance on duties, funding routes and leaseholder protections.

Major Works

Planning and running remediation projects from scoping to completion.

Consultant Coordination

Managing surveyors, fire engineers and specialists as one project team.

Leaseholder Communication

Clear, honest updates so residents understand what's happening and why.

Compliance Management

Ongoing fire safety, building safety and statutory compliance for the block.

Project Oversight

Independent oversight of costs, timescales and contractor performance.

We coordinate specialist consultants, run the project transparently and keep leaseholders informed at every stage - so directors are never left carrying the technical detail alone.

What does this mean in practice?

Building safety work is won or lost on record-keeping and sequencing long before anyone appoints a contractor.

If you are one of the rtm directors

Establish what the external wall is actually made of, in writing, before debating who pays. Assumptions about the build-up are the usual source of cost surprises.
Keep every survey, intrusive inspection and fire risk assessment in one place with dates. This is the first bundle any funder, insurer or buyer's solicitor asks for.
Treat interim measures - alarms, waking watch, compartmentation repairs - as a live budget line, not an emergency spend.

If you are one of the rmc directors

Check whether the building falls within the higher-risk category before assuming which regime applies.
Make sure the fire risk assessment actions have owners and dates. Open actions with no owner are the pattern we see most often on takeovers.

If you are one of the freeholders

Scope surveys around the wall as a system, including cavity barriers and insulation, rather than the visible panel alone.
Record what was investigated and what was not. A partial survey presented as a full one causes problems later.

If you are one of the leaseholders

Ask what has been physically inspected rather than inferred from drawings.
Ask which funding routes have been explored before any service charge contribution is proposed.

Common mistakes

Treating the cladding panel as the whole problem
An external wall performs as a system. Replacing the visible layer while leaving barriers or insulation unresolved can leave the building no safer.
Relying on drawings instead of opening up the wall
As-built rarely matches as-drawn. Where budgets have gone badly wrong, the cause is usually a build-up nobody verified.
Letting fire risk assessment actions stay open
An assessment with unclosed actions is evidence against you. Each action needs an owner, a date and a completion record.
Starting remediation before funding routes are checked
Some costs are recoverable elsewhere. Committing service charge money first can close doors that were open.

When to seek professional advice

Most questions on this topic are management questions rather than legal ones, and the two are worth separating. A managing agent can tell you how something works day to day and what it will cost. A solicitor tells you what your rights are and how a Tribunal is likely to view them.

Speak to a managing agent when

You need a compliance schedule that shows what is due, when, and who is responsible.
Fire risk assessment actions have built up and need closing out in a defensible order.
You need remediation and interim measures reflected properly in the budget and reserves.

Request a free block review

Take specialist legal advice when

Liability for remediation costs between freeholder, developer and leaseholders is in dispute.
You are dealing with leaseholder protections, remediation orders or contribution orders.
An enforcement notice or a formal claim has been received.

East Valley Properties provides management expertise, not legal advice. Where a matter turns on the wording of your lease or on formal proceedings, we will say so and work alongside your solicitor.

Primary sources

The official material behind this guide. We summarise it in plain English rather than reproducing it.

Building Safety Act 2022 (legislation.gov.uk)
The primary legislation, including the leaseholder protections and remediation provisions.
Fire Safety Act 2021 (legislation.gov.uk)
Confirms that external walls and flat entrance doors fall within the fire safety order.
Building safety guidance (GOV.UK)
Government guidance on duties, higher-risk buildings and remediation funding.
Upper Tribunal (Lands Chamber) decisions (GOV.UK)
The published decisions on scope of remediation, read in full rather than in summary.

Frequently Asked Questions

Written by Romain Maillard - Director, East Valley Properties

Romain manages residential blocks and estates for RTM companies, residents' management companies, share of freehold developments and freeholders across East London and Essex.

Published 11 July 2026

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Building Safety Act: What Counts as Cladding Remediation?

Key takeaway

Why Was the Building Safety Act Introduced?

Grenfell

New legislation