Fire Risk Assessment Review: When, Why, and How to Keep Yours Fully Compliant

If you’re a landlord, housing provider, or facilities manager, a “fire risk assessment review” isn’t a nice-to-have - it’s a legal duty and a frontline control that protects lives and assets. In England and Wales, the Regulatory Reform (Fire Safety) Order 2005 requires you to keep your assessment up to date and to review it regularly, especially when anything significant changes. British Standard BS 9792:2025 turns that duty into practical, risk-based review intervals and concrete triggers. Scotland and Northern Ireland apply equivalent duties to assess and review risks under their own legislation.

Fire Risk Assessment Review - What the Law Actually Says

England & Wales (RRO 2005): You must make a “suitable and sufficient” fire risk assessment (FRA), review it regularly to keep it up to date, and immediately if there is reason to suspect it’s invalid or if there has been a significant change to the building, people, or fire precautions. You must also record the assessment or review and its significant findings.

England (extra duties in high-rise housing): The Fire Safety (England) Regulations 2022 add operational checks and information duties in high-rise residential buildings (e.g., plans in a secure information box and monthly checks of lifts for firefighters and essential firefighting systems). These checks create obvious review triggers if faults or changes are found.

Scotland: The Fire (Scotland) Act 2005 and associated regulations require dutyholders to carry out and review a fire risk assessment. Guidance advises review at regular intervals or when findings are out of date or circumstances change.

Northern Ireland: The Fire Safety Regulations (Northern Ireland) 2010 likewise provide for assessment and review duties.

Bottom line: Across the UK, you must review your FRA at sensible intervals and whenever change happens. The standard that helps you turn “regularly” into a plan is BS 9792:2025.

The gold standard: BS 9792’s risk-based review and replacement cycle

BS 9792:2025 recognises there’s no one fixed frequency that suits every building. Instead, it asks you to set an explicit review interval and a separate replacement interval (full reassessment), and to justify both based on risk, building height, age, and the likelihood of change. Its Step 9 gives clear examples:

Low-risk, modern, low-rise blocks (≤3 storeys, ~last 20 years): Review every 2 years; replace after 4 years.

Higher-risk blocks and/or >4 storeys: Review annually; replace after 3 years.

Highest-risk premises: A simple “review” may be insufficient—carry out a full reassessment, potentially annually.

BS 9792 also lists three universal triggers that can invalidate your FRA at any time, requiring an immediate review: (a) a material alteration, (b) a significant change in the “given” factors (e.g., occupants, use), or (c) a significant change in fire precautions.

Tip for asset planners: Put both dates—next review and next replacement—on the cover page of your FRA and in your asset register. That transparency helps demonstrate due diligence to auditors and the fire and rescue service.

Immediate review triggers you should never ignore

Use this checklist. If any apply, start a fire risk assessment review now:

Building alterations or refurbishment that could affect compartmentation, travel distances, detection/alarms, emergency lighting, smoke control, or means of escape.

Occupancy profile changes—e.g., increased resident numbers, different use (general needs → supported), higher prevalence of mobility aids or oxygen use, or altered staffing patterns.

External wall or balcony works—over-cladding, panel replacements, balcony construction, PV installation, or new attachments/living walls.

Fire protection systems added, altered, or degraded—alarms, emergency lighting, automatic suppression, smoke control, EAS (BS 8629), fire mains/hydrants, firefighters’ lifts, wayfinding signage, or SIB content. New installs or maintenance findings are review triggers.

Regulatory duties in England’s high-rise housing—monthly checks reveal faults with firefighters’ lifts, evacuation lifts, or essential firefighting equipment; you must act and inform FRS if not rectified within 24 hours. Changes or persistent faults should feed back into your FRA review.

Enforcement action or formal advice from FRS or the regulator—deficiency letters, enforcement/alterations/prohibition notices. These are classic triggers to revisit your assessment and action plan.

Fire incidents or near misses—any event indicating drift from the intended fire strategy or maintenance regime warrants an immediate review.

How often to plan a Fire Risk Assessment Review (by risk and stock type)

Use BS 9792’s cadence as your default, then adjust based on your stock:

General needs, low-rise, modern blocks: Review every 2 years; replace every 4 years.

Higher-risk or taller buildings (>4 storeys), older stock, complex systems: Review annually; replace every 3 years.

Highest-risk or unstable risk profile: Consider a full reassessment annually rather than a light-touch review.

In Scotland and Northern Ireland, the legislation is different but the underlying duty is the same: assess and keep risk assessments under review. Align your intervals with BS 9792’s risk-based approach and your local enforcement guidance.

What a high-quality review covers (so it actually improves safety)

A review is not a rubber stamp. Map it to BS 9792’s structure so you catch drift:

Premises & occupants: Has building height/use changed? Are there new vulnerabilities (e.g., mobility aids, oxygen, powered medical equipment)? Are staffing and resident engagement arrangements still appropriate?

External walls & attachments: Has any cladding, balcony, spandrel, or PV work occurred? Do you hold current evidence or an FRAEW where applicable? If evidence is lacking, the action plan should require an FRAEW to PAS 9980.

Protection measures: Detection & alarms, emergency lighting, signs/wayfinding, smoke control, suppression, fire doors/compartmentation. Validate that systems still support the fire strategy.

Facilities for firefighters: wet/dry risers, hydrants, appliance access, firefighters’ lifts, SIB, EAS, wayfinding, comms, high-voltage switches. Verify testing and maintenance arrangements are in place.

Management & information flows: Training (induction and refreshers), drills, contractor controls, resident engagement, information to residents and FRS (plans, SIB, lift faults). Evidence monitoring and review of preventive and protective measures.

Action plan health-check: Re-prioritise open items; add interim measures where long-lead actions exist (e.g., temporary detection, waking watches only where justified). Document priorities (immediate/short/medium/long) and owners.

Documentation hygiene: Record who reviewed, when, with whom you consulted, and the next review date. Keep a clear lineage of reviews since the previous FRA.

UK-wide nuances you should know

England: For high-rise residential buildings, keep floor plans and a building plan in the secure information box, keep those plans up to date, and inspect the SIB at least annually. These are not just admin tasks; changes in layouts or systems should trigger an FRA review.

Scotland: Dutyholders must undertake and regularly review risk assessments and take measures to keep people safe from fire; local guidance reinforces the need to review when time has elapsed or circumstances change (e.g., alterations, new hazards).

Northern Ireland: The NI Regulations require assessment and review and are enforced by the Northern Ireland Fire & Rescue Service (NIFRS), whose guidance reiterates maintaining a current risk assessment.

Common mistakes that sink a fire risk assessment review (and how to avoid them)

Desk-only reviews: If you only re-read last year’s report, you’ll miss changes. Validate on site - especially compartmentation, fire doors, service risers, and any ad-hoc alterations in common parts.

Ignoring external wall/balcony changes: Even minor balcony works or added attachments can change spread risk. Always refresh the external wall section and check whether an FRAEW (PAS 9980) is required or needs updating.

No replacement cycle: Reviews aren’t forever. Build in complete reassessments (replacement) at the intervals BS 9792 recommends (e.g., 4 years low-risk; 3 years higher-risk).

Not linking maintenance findings to review: If monthly checks find lift or system faults (England high-rise), don’t just log them—recheck your FRA assumptions and interim measures.

Action plans with vague “recommendations”: Necessary measures must be provided to comply with fire safety law—state them clearly, prioritise, and set deadlines.

Weak audit trail: Failing to record who reviewed, when, and the next review date undermines compliance and continuity. Capture that every time.

A simple, risk-based schedule you can drop into your policy

Policy statement: “We will carry out a fire risk assessment review at the interval set below, and immediately when any review trigger occurs.”

Stock profile

Low-risk, modern, low-rise (general needs): Review every 2 years; replace at 4 years.

Higher-risk or >4 storeys: Review annually; replace at 3 years.

Highest-risk: Annual full reassessment.

Monthly/quarterly trigger scan

Building alterations, refurbishment, or change of use/occupancy.

System changes or maintenance findings affecting alarms, lighting, smoke control, suppression, risers/hydrants, firefighters’ lifts, SIB, EAS, or wayfinding.

Enforcement action, incidents, near misses.

Documentation

Update significant findings, action plan priorities and any interim measures, and publish the next review date.

Log the reviewer’s name, review date(s), consultation contacts, and number of reviews since the previous FRA.

Exactly what to check during your review (walkthrough)

Means of escape & compartmentation
Confirm travel distances, protected routes, lobby arrangements (as applicable), and that doorsets still perform as intended (condition, self-closing). Record any openings/penetrations and ensure fire stopping remains effective.

Detection, alarms & emergency lighting
Verify they suit the fire strategy and are maintained to the appropriate standards. Cross-check against maintenance records and test logs. Where systems compensate for other shortfalls (e.g., extended travel distances), validate the original design rationale.

Smoke control
Check that the cause-and-effect still matches the strategy; look for fault indications and any damage or inoperable vents; confirm maintenance is current.

Automatic suppression (if installed)
Confirm coverage, design standard, maintenance regime, and any management procedures if the system is out of service.

Facilities for firefighters
Record type/condition of dry/wet risers, hydrant access, appliance access, firefighters’ lifts, SIB, EAS, wayfinding, comms, and high-voltage switches. Verify testing and maintenance arrangements are in place.

Management systems
Evidence monitoring and review of preventive/protective measures, training (induction and refresher), drills where appropriate, and information to residents and FRS (plans, SIB, lift faults). Ensure contractor information and coordination arrangements are documented.

External walls & balconies
Update the description; note any combustible elements or attachments. If evidence on compliance is absent or out of date, raise an action for FRAEW (PAS 9980) and manage balcony storage risks.

Action plan
Use BS 9792’s priority framework: immediate (with interim measures), short (≈3 months), medium (≈3–6 months), long (align to refurb). Avoid “suggestions”—state the necessary measures to comply with the law.

FAQs on fire risk assessment review

Is an annual review mandatory?

No single frequency is set in law, but you must review regularly and when significant changes occur. BS 9792 converts “regularly” into risk-based intervals (2-year/1-year, with periodic replacement), which demonstrates good practice and due diligence.

What’s the difference between a review and a replacement (full reassessment)?

A review checks whether your current FRA and action plan are still valid; a replacement is a new, full assessment—recommended every 3–4 years depending on risk and height.

Do monthly checks (England high-rise) affect my review cycle?

Yes. Monthly lift and essential firefighting equipment checks are legal duties; recurring faults or changes should feed back into your FRA review and action plan.

Who can carry out the review?

Competence matters. BS 9792 sets expectations for assessors: understanding the legislation, building fire behaviour, evacuation strategies, legacy standards in older buildings, and evidence of CPD.

Do I need to revisit external walls every time?

Yes—confirm status and evidence (or commission/update an FRAEW). Also check balcony hazards and attachments.

Conclusion - Fire Risk Assessment Review

A robust fire risk assessment review routine is how you turn compliance into confidence. Set the right frequency, react instantly to change, and document everything.

Book a Compliant Fire Risk Assessment

Anstey Horne delivers thorough, legally compliant fire risk assessments across England & Wales. We reference the Fire Safety Order, the Fire Safety (England) Regulations 2022, and Section 156 changes to give you clear actions, practical timelines, and full documentation for audits and insurers.

To commission a Fire Risk Assessment (FRA) or a Fire Risk Appraisal of External Walls survey (FRAEW) please call 020 4534 3130.

For further information on FRA, FRAEW Surveys, PAS9980 or EWS1 forms please call one of our assessors for expert advice.

If you need more advice in respect of your obligations as a building owner, developer or manager, please contact us. For more information on all aspects of this service see the collection of articles in our blog.

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To commission a Fire Risk Assessment (FRA) or a Fire Risk Appraisal of External Walls survey (FRAEW) please call 020 4534 3130.

For further information on Fire Risk Assessments or advice in respect of your obligations as a building owner, developer or manager, please contact :