What Are the Requirements for a Fire Risk Assessment?
If you manage, own, lease, or control non-domestic premises in the UK, you are likely under a legal duty to carry out a fire risk assessment. Understanding the fire risk assessment requirements is critical for protecting life, complying with legislation, reducing business disruption, and avoiding enforcement action.
A fire risk assessment is not simply a checklist exercise. It is a structured review of the fire hazards within a building, the risks those hazards create, the adequacy of existing fire precautions, and the additional actions required to keep people safe.
In England and Wales, the legal requirement primarily arises under the Regulatory Reform (Fire Safety) Order 2005. Article 9 requires the responsible person to make a “suitable and sufficient” assessment of the risks to relevant persons exposed to fire.
This article explains the key fire risk assessment requirements, who must comply, what a suitable and sufficient assessment involves, how standards such as PAS 79-1 and BS 9792 apply, and what dutyholders must do to remain compliant.
What Is a Fire Risk Assessment?
A fire risk assessment is a systematic review of a building and the activities within it to identify:
- Fire hazards
- People at risk
- Existing fire safety measures
- Deficiencies in fire precautions
- Actions required to reduce fire risk
PAS 79-1 defines a fire risk assessment as:
“the process of identifying fire hazards and evaluating the risks to people arising from them, taking into account the adequacy of existing fire precautions, and deciding whether or not the fire risk is acceptable without further fire precautions.”
The assessment must focus on life safety. It is not primarily a property protection exercise.
What Legislation Requires a Fire Risk Assessment?
England and Wales
The principal legislation is the Regulatory Reform (Fire Safety) Order 2005.
The legislation requires the responsible person to carry out a suitable and sufficient fire risk assessment to identify the general fire precautions needed.
The Fire Safety Order applies to virtually all non-domestic premises including:
- Offices
- Shops
- Warehouses
- Factories
- Hotels
- Restaurants
- Schools
- Healthcare premises
- Common parts of residential blocks
- HMOs within scope
- Entertainment venues
Scotland
In Scotland, the duty arises under the Fire (Scotland) Act 2005 and the Fire Safety (Scotland) Regulations 2006.
Northern Ireland
In Northern Ireland, the requirements arise under the Fire and Rescue Services (Northern Ireland) Order 2006 and associated regulations.
Who Is Responsible for the Fire Risk Assessment?
The legal duty falls on the “responsible person” or dutyholder.
This may include:
- Employers
- Building owners
- Landlords
- Managing agents
- Facilities managers
- Occupiers
- Anyone with control over premises
PAS 79-1 notes that multiple dutyholders can exist within the same premises.
For example, in a multi-let office building:
- Each tenant may be responsible for their own demise
- The landlord or managing agent may be responsible for common parts
The duty cannot simply be delegated away. Even where a third-party assessor completes the FRA, the dutyholder remains legally responsible for its adequacy.
What Does “Suitable and Sufficient” Mean?
One of the most important fire risk assessment requirements is that the FRA must be “suitable and sufficient”.
This phrase appears repeatedly within UK fire safety guidance and enforcement practice.
A suitable and sufficient assessment should:
- Identify significant fire hazards
- Identify people at risk
- Evaluate the adequacy of fire precautions
- Record significant findings
- Include an action plan
- Be proportionate to the building and risks
- Remain current through regular review
PAS 79-1 explains that the assessment should determine whether fire risk is acceptable and what additional precautions are required.
An inadequate FRA commonly fails because it:
- Uses generic templates
- Omits inspection of key areas
- Lacks sufficient detail
- Ignores vulnerable occupants
- Fails to identify compartmentation issues
- Does not provide actionable recommendations
- Is not reviewed following changes
What Buildings Require a Fire Risk Assessment?
The fire risk assessment requirements apply to almost all non-domestic premises.
Examples include:
Commercial Buildings
- Offices
- Retail units
- Industrial premises
- Warehouses
- Leisure facilities
Residential Buildings
The common parts of residential buildings require fire risk assessments, including:
- Blocks of flats
- Apartment buildings
- Student accommodation
- Sheltered housing
- Care homes
Hospitality and Public Buildings
- Hotels
- Bars
- Restaurants
- Theatres
- Event venues
Healthcare and Education
- Hospitals
- GP surgeries
- Schools
- Universities
- Nurseries
Vacant Buildings
Vacant buildings still require fire risk assessments where the legislation applies.
What Are the Main Components of a Fire Risk Assessment?
PAS 79-1 provides a structured methodology using nine steps.
A compliant fire risk assessment normally includes the following key elements.
1. Information Gathering
The assessor reviews:
- Building layout
- Occupancy profile
- Fire strategy
- Existing fire systems
- Operational activities
- Previous fire incidents
2. Identification of Fire Hazards
The FRA identifies:
- Ignition sources
- Fuel sources
- Oxygen sources
Common hazards include:
- Faulty electrics
- Cooking equipment
- Portable heaters
- Smoking materials
- Arson vulnerabilities
- Combustible storage
PAS 79-1 defines a fire hazard as a source or situation with the potential to result in fire.
3. Identification of People at Risk
The assessment considers:
- Employees
- Visitors
- Contractors
- Residents
- Disabled occupants
- Sleeping occupants
- Lone workers
Particular attention must be given to occupants especially at risk.
4. Assessment of Existing Fire Precautions
This includes review of:
- Means of escape
- Fire alarms
- Emergency lighting
- Fire extinguishers
- Compartmentation
- Fire doors
- Smoke control systems
- Signage
- Fire stopping
- Evacuation procedures
5. Evaluation of Fire Risk
The assessor considers:
- Likelihood of fire
- Potential consequences
- Adequacy of controls
- Residual risk level
PAS 79-1 distinguishes clearly between fire hazards and fire risk.
6. Action Plan
The FRA should contain a prioritised action plan that identifies:
- Deficiencies
- Recommended remedial works
- Management improvements
- Timescales
- Priority levels
7. Recording Significant Findings
The significant findings must be recorded where required by legislation.
In practice, virtually all commercial and managed residential premises should maintain written records.
8. Review Procedures
A fire risk assessment is not a one-off document.
It must be reviewed regularly and whenever:
- The building changes
- Occupancy changes
- Processes change
- Fire incidents occur
- Significant works take place
- Legislation changes
- The assessment may no longer remain valid
What Are the Competency Requirements for Fire Risk Assessors?
The Fire Safety Order does not require a specific qualification. However, the assessor must be competent.
PAS 79-1 places significant emphasis on competence.
A competent assessor should possess:
- Fire safety knowledge
- Relevant qualifications
- Practical experience
- Understanding of legislation
- Understanding of building construction
- Knowledge of applicable standards
Complex buildings often require specialist fire engineering expertise.
Examples include:
- High-rise residential buildings
- Hospitals
- Large mixed-use developments
- Care homes
- Complex industrial sites
PAS 79-1 and BS 9792: Understanding the Standards
One area that often causes confusion concerns PAS 79-1 and BS 9792.
PAS 79-1: Non-Housing Premises
PAS 79-1:2020 applies to premises other than housing.
This includes:
- Offices
- Shops
- Warehouses
- Factories
- Schools
- Hotels
PAS 79-1 provides a structured methodology and documentation framework for non-housing FRAs.
BS 9792: Housing Premises
British Standard BS 9792:2025 replaced PAS 79-2 for housing fire risk assessments.
BS 9792 applies to:
- Blocks of flats
- Residential common parts
- Sheltered housing
- Supported housing
- Other residential premises
The distinction matters because residential buildings require different evacuation considerations, compartmentation strategies, and management approaches.
Additional Requirements for Residential Buildings
Residential fire safety obligations have increased significantly following the Grenfell Tower fire.
The Fire Safety (England) Regulations 2022 introduced additional duties for responsible persons in high-rise residential buildings.
Requirements may include:
- Secure information boxes
- Floor and wayfinding signage
- Monthly checks of firefighting equipment
- Information sharing with fire services
- Resident information duties
Residential Evacuation Plans Regulations 2025
The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 introduced further obligations from April 2026.
The regulations apply to certain high-rise residential buildings.
Responsible persons must:
- Use reasonable endeavours to identify residents needing evacuation assistance
- Offer person-centred fire risk assessments
- Consider mitigating measures
- Prepare emergency evacuation statements
- Review evacuation arrangements annually
- Prepare building emergency evacuation plans
How Often Must a Fire Risk Assessment Be Reviewed?
There is no fixed review frequency in the Fire Safety Order. However, the FRA must remain current.
In practice, review frequency depends on:
- Building complexity
- Occupancy risk
- Changes within the premises
- Previous fire issues
Many organisations adopt:
- Annual reviews for standard premises
- More frequent reviews for higher-risk premises
- Immediate review after significant changes
A review is particularly important following:
- Refurbishment works
- Change of use
- Increased occupancy
- Fire incidents
- Enforcement action
What Happens If You Do Not Comply?
Failure to comply with fire risk assessment requirements can result in:
- Enforcement notices
- Alterations notices
- Prohibition notices
- Criminal prosecution
- Unlimited fines
- Imprisonment
- Civil claims
- Insurance complications
Fire authorities increasingly scrutinise poor-quality FRAs, particularly generic assessments that fail to reflect the actual building.
Common Problems Found in Fire Risk Assessments
Poor FRAs often contain recurring deficiencies.
Generic Assessments
Template-driven assessments that ignore the actual building create significant legal and safety risks.
Inadequate Inspection
Assessments may fail to inspect:
- Service risers
- Ceiling voids
- Roof spaces
- Fire stopping
- Compartmentation
Missing Fire Door Defects
Fire door failures remain one of the most common enforcement issues.
Lack of Follow-Up
An FRA alone does not achieve compliance. Dutyholders must complete the action plan.
Failure to Review
Many FRAs become outdated after refurbishments or occupancy changes.
How to Ensure Your Fire Risk Assessment Meets Requirements
To improve compliance and reduce risk:
Use Competent Assessors
Select assessors with:
- Relevant qualifications
- Demonstrable experience
- Appropriate insurance
- Third-party certification where appropriate
Use Structured Methodologies
Standards such as PAS 79-1 and BS 9792 help provide consistency and defensible documentation.
Complete Actions Promptly
An unresolved high-priority action can create enforcement exposure even where the FRA itself is adequate.
Keep Records
Maintain records of:
- FRA reports
- Completed actions
- Maintenance records
- Fire drills
- Staff training
- Alarm testing
- Emergency lighting checks
Review Regularly
Treat the FRA as a live management document rather than a static report.
Why Fire Risk Assessment Quality Matters
A poor-quality FRA can create false reassurance. That creates serious legal and life safety consequences.
A robust assessment helps you:
- Protect occupants
- Demonstrate compliance
- Reduce enforcement risk
- Support insurers
- Improve emergency preparedness
- Manage refurbishment projects safely
- Identify hidden fire safety defects
For residential buildings, competent fire risk assessment processes now form a critical part of wider building safety management.
Conclusion
Understanding fire risk assessment requirements is essential for every dutyholder responsible for non-domestic or managed residential premises.
The legal requirement extends far beyond simply obtaining a report. You must ensure the assessment is suitable and sufficient, completed by competent persons, regularly reviewed, and supported by effective action management.
PAS 79-1 provides the recognised framework for non-housing premises, while BS 9792 now supports housing fire risk assessments. Residential buildings also face additional obligations under the Fire Safety (England) Regulations 2022 and the Fire Safety (Residential Evacuation Plans) (England) Regulations 2025.
Ultimately, a fire risk assessment should provide a practical roadmap for managing fire safety, protecting lives, and demonstrating legal compliance.
FAQs
What are the legal fire risk assessment requirements?
Most non-domestic premises must have a suitable and sufficient fire risk assessment under the Regulatory Reform (Fire Safety) Order 2005. The assessment must identify fire hazards, people at risk, existing precautions, and required improvements.
Who is responsible for a fire risk assessment?
The responsible person or dutyholder is legally responsible. This may include employers, landlords, building owners, occupiers, or managing agents.
How often should a fire risk assessment be reviewed?
A fire risk assessment should be reviewed regularly and whenever significant changes occur. Many premises adopt annual reviews as good practice.
What does “suitable and sufficient” mean?
A suitable and sufficient FRA properly identifies risks, evaluates existing fire precautions, records significant findings, and provides a practical action plan.
Is a fire risk assessment a legal requirement for flats?
The common parts of residential blocks require fire risk assessments. Additional duties may apply under the Fire Safety (England) Regulations 2022 and the Fire Safety (Residential Evacuation Plans) (England) Regulations 2025.
What is the difference between PAS 79-1 and BS 9792?
PAS 79-1 applies to non-housing fire risk assessments. BS 9792 applies to housing fire risk assessments and replaced PAS 79-2.
Can anyone carry out a fire risk assessment?
The assessor must be competent. Competence depends on training, knowledge, qualifications, and practical experience.
What happens if you do not have a fire risk assessment?
Failure to comply can result in enforcement notices, prosecution, unlimited fines, imprisonment, and increased civil liability exposure.
What should a fire risk assessment include?
A suitable FRA should include:
- Fire hazards
- People at risk
- Existing precautions
- Means of escape
- Fire alarm provisions
- Emergency lighting
- Fire door assessment
- Compartmentation review
- Action plan
- Review procedures
Are fire risk assessments required for vacant buildings?
Yes. Vacant premises can still require fire risk assessments where fire safety legislation applies.
Need help with a Fire Risk Assessment FRA?
Anstey Horne’s expert team of fire safety professionals are here to assist with legally compliant fire risk assessments, retrospective fire strategies, and FRAEW appraisals for residential buildings across the UK. Whether you manage a single block or a national portfolio, we can help you stay safe and compliant.
Get in touch with us today to arrange a no-obligation consultation - please call 020 4534 3130.
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For further information on Fire Risk Assessment, Retrospective Fire Strategies, FRAEWs or advice in respect of your obligations as a building owner, developer or manager, please contact :
Sarah Taylor
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London