The O&M Reality Check part 1:
Common Handover Failures Driving the 2026 Shift
2026 is the year UK O&M handover stops being a “box of PDFs” and becomes evidence you can actually stand behind.
Right now, the industry is stuck in a dangerous contradiction: the regulatory direction of travel is toward accountable, auditable, digital evidence—but practical handover often still looks like a last-minute document dump. Building owners are being pressed to sign declarations and accept responsibility for compliance while being given impossibly short windows (sometimes 24 hours) to review tens of thousands of files. That’s not governance. It’s gambling.
And the uncomfortable truth is this: most contractors and most building owners don’t have the technology to validate O&Ms at scale. The default “solution” is to bring in specialist consultants—high quality, but expensive and slow—so checks happen late (or not at all), when change is hardest and risk is highest.
What changes in 2026 (and why it matters to O&Ms)
By 2026, the “paper handover” approach is going to break more often, more visibly, and with bigger consequences:
- Higher expectations of traceable compliance evidence at completion and in occupation—particularly for higher-risk buildings, where the completion gateway relies on a packaged set of information and declarations that support building regs compliance.
- More regulatory scrutiny in practice, not just in theory. The Building Safety Regulator’s published plan (2023–2026) makes clear this isn’t a slow transition; it’s a ramp-up in oversight and assessment activity through to 2026. (HSE)
- A tightening timeline for key safety changes, including the point at which new residential buildings above 18m must meet updated fire safety guidance (including second staircases) under transitional arrangements ending in 2026.
- The Building Safety Levy coming into force (2026) is another marker: the system is shifting from “encouragement” to “hard mechanisms” that assume better information, faster assurance, and clearer accountability.
The real issue: sign-off without visibility
An O&M set isn’t “complete” because a folder exists. It’s complete when you can answer, quickly and confidently:
- Do we have the full schedule of drawings—and are the referenced drawings present?
- Are products identified (make/model/spec), with datasheets and certification attached?
- Are assets located (floor/space/zone/system) so FM teams can operate and maintain?
- Do the documents cross-reference properly (drawing ↔ asset ↔ product ↔ test/commissioning ↔ warranty)?
- Is there a clear gap list before anyone is asked to sign anything?
If you can’t answer those questions in minutes, you don’t have an O&M you can rely on—you have a risk transfer exercise.
The reality check: the O&M errors we see again and again
If you’ve ever wondered why “we’ve issued the O&Ms” doesn’t translate into “the building is safe to operate and maintain,” it’s because the most common failure modes are painfully predictable. These aren’t edge cases—they’re routine, and they’re exactly why 2026 needs to be the turning point from document delivery to evidence assurance.
Common O&M errors we repeatedly encounter:
1) Wrong, empty, or unusable content
- O&M is for a different building
- O&M is an empty template
- Files provided are in a format the client can’t open
- Files have zero length
- Spreadsheet files contain macros (often blocked by client IT policy)
2) Who did what (and who is responsible) is unclear
- Contractor details are incomplete
- Sub-contractor details are incomplete
- Scope of works is missing or vague
- Areas of works are missing, incomplete, or vague
3) Product evidence is missing or doesn’t join up
- Schedule of product suppliers missing or incomplete
- Schedule of products missing or incomplete
- Schedule of product literature missing, or referenced documents not provided
- COSHH information missing for products/materials used in maintenance
4) Operational readiness evidence is missing
- Warranty schedule/descriptions missing or incomplete
- Maintenance instructions for products/systems missing, vague, incomplete, or referencing documents not provided
- Test & commissioning certificates missing or incomplete
- Health & Safety information for safe operation missing
5) Drawings and “as-built” integrity failures
- Schedule of drawings missing, or referenced drawings/documents not provided
- Referenced documents/drawings are not marked AS-BUILT
6) COBie solely from BIM that can’t be trusted as evidence
Another recurring problem is the assumption that “we’ve got COBie, so we’re covered.”
COBie is only as reliable as the evidential process that keeps the underlying BIM models aligned with the as-built reality delivered by construction subcontractors. In practice there is often a disconnect between the main BIM authors and the people actually procuring and installing products on site. Many products are not selected by the designers at all, but by subcontractors and the supply chain during construction, and these changes are rarely driven back into the model in a controlled way.
We’ve seen COBie drops where:
- There are no door or window numbers in the COBie data,
- There is no way to link COBie Door entries to the door manufacturer’s door schedule,
- Yet the original BIM models did contain door numbers.
In other words, the BIM/COBie export has not been maintained as an evidential record of the as-built works, so it cannot be relied upon for safety, maintenance, or regulatory sign-off without additional checking.
This is why the “24 hours to review 10s of thousands of documents” scenario is so dangerous: you can’t spot these issues reliably by eyeballing folders, and you can’t afford to find them after handover—when the building is occupied, the supply chain has moved on, and the risk sits squarely with the owner.
That’s also why 2026 is the moment for simple, smart, low-cost validation tools: automated checks that flag the problems above early, continuously, and with a clear exception list—so sign-off becomes evidence-based rather than deadline-driven.
What “good” looks like going into 2026
This is where the shift becomes practical: O&Ms must move from documents to data.
At Activeplan, we’ve built data-engineering workflows and smart AI that do what humans simply can’t do at scale, fast enough:
- Read and index O&M content to produce a coverage report (what’s there, what’s missing, what’s weak)
- Validate drawing schedules vs. provided drawings
- Check that products are described, datasheets exist, and drawings are referenced
- Identify locations and connect evidence back to floors/spaces/systems for FM use
- Produce a clear exception list so gaps are closed early—before handover pressure hits
Sources (URLs)
https://www.gov.uk/guidance/applying-for-a-completion-certificate
https://www.gov.uk/guidance/keeping-information-about-a-higher-risk-building-the-golden-thread
https://www.hse.gov.uk/building-safety/strategic-plan.htm
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