Is an EWS1 Required for Buildings Under 18m?

When buying, selling, or remortgaging a flat in England or Wales, many leaseholders encounter the term EWS1 form. Originally introduced to address fire safety concerns following high-profile cladding failures, the form has become a key part of the mortgage process for certain buildings. One of the most common questions is: is an EWS1 required for buildings under 18m?

The answer is more nuanced than a simple “yes” or “no.” While the form was initially designed for taller, high-risk buildings, it can still be requested for properties under 18m in height in specific circumstances. This article explores when that might happen, what the regulations and professional guidance say, and how competence requirements affect who can complete the form.

1. Understanding the EWS1 Form

The External Wall System (EWS1) form is a standardised process developed by RICS (Royal Institution of Chartered Surveyors), UK Finance, and the Building Societies Association. It is used to confirm that the external wall system of a residential building has been assessed for fire safety risks.

The form does not declare a building “safe” or “unsafe.” Instead, it records whether a competent professional has inspected the external wall system and identified materials or design features that may require remedial work or ongoing management.

2. Height and the EWS1 Requirement

The original focus of the EWS1 process was residential buildings above 18 metres in height. This threshold was chosen because fire risk is generally higher in taller buildings due to evacuation challenges, firefighting complexity, and potential for rapid vertical fire spread.

However, height alone is not the only factor influencing whether an EWS1 is requested. Even for buildings under 18m, some lenders and managing agents may still seek an EWS1 where there are concerns about combustible cladding, balconies with combustible materials, or other risk factors.

3. Risk-Based Approach for Buildings Under 18m

The decision to request an EWS1 for a building under 18m is often risk-driven. Factors that might trigger an assessment include:

Combustible cladding materials such as certain ACM (Aluminium Composite Material), HPL (High Pressure Laminate), or timber-based panels.

Extensive external balconies constructed with combustible decking or handrails, particularly where they run continuously across the façade.

Complex façade design that might allow concealed fire spread within cavities.

Mixed-use buildings with residential units above commercial premises where fire load may be higher.

Past fire incidents or evidence of poor construction detailing in similar buildings.

Under PAS 9980:2022, the fire risk appraisal of external wall construction is based on a holistic evaluation. This standard guides competent assessors to consider the full range of potential hazards rather than relying solely on height.

4. Professional Competence for Under 18m EWS1 Assessments

The RICS EWS Assessment Training Programme sets out who is competent to complete an EWS1, and the competence level depends on building height and complexity.

According to the RICS guidance:

Successful course completers should be capable of completing Option A or Option B of the EWS1 form below 18m, but should self-assess their own competence. If the building is very complex or high risk, they should consult an Incorporated Engineer (IEng) or Chartered Engineer (CEng) fire engineer for advice on Option B if in any doubt.

For high-risk residential buildings above 18m, an IEng or CEng registered with the Engineering Council is generally expected to undertake the assessment.

This means that for a building under 18m:

Option A (no combustible materials) may be signed off by an appropriately trained RICS, IFE (Institution of Fire Engineers), or CABE (Chartered Association of Building Engineers) member who has completed the EWS training.

Option B (combustible materials present, further assessment required) may still require fire engineering input if the building is complex.

5. When Lenders May Still Ask for an EWS1 Under 18m

Even if the law does not mandate it, lenders sometimes impose their own conditions before approving a mortgage. This can be due to:

Valuer caution: If a valuer spots cladding or other fire-risk features, they may recommend an EWS1 before confirming the property’s market value.

Portfolio risk policies: Some lenders apply internal rules across all buildings with certain cladding types, regardless of height.

Buy-to-let mortgages: Lenders in the private rental sector may be more conservative, seeking an EWS1 to mitigate long-term liability risk.

As a leaseholder, it is worth confirming your lender’s exact requirements early in the sale or remortgage process to avoid delays.

6. PAS 9980 and the EWS1 Interface

The PAS 9980 methodology is now the recognised approach for assessing external wall systems. While an EWS1 is a lender-facing form, PAS 9980 is a technical assessment standard used by the assessor.

In practice:

The assessor conducts a Fire Risk Appraisal of External Walls in line with PAS 9980.

The outcome informs the completion of the EWS1 form.

The EWS1 is then provided to the lender or valuer.

For buildings under 18m, the PAS 9980 process ensures a proportionate evaluation—potentially confirming that no remediation is required, which can speed up lending decisions.

7. Costs and Timescales for Under 18m EWS1 Assessments

While full-scale cladding investigations on tall buildings can be costly, assessments for buildings under 18m are often more straightforward—though still detailed. Costs vary depending on:

Access requirements (e.g., MEWPs, scaffolding).

Complexity of façade design.

Whether intrusive investigations are needed.

Typical timescales range from 2–4 weeks, but can extend if there are any access issues or if laboratory testing of materials is required.

8. Key Steps for Leaseholders in Buildings Under 18m

If you believe your building may need an EWS1, follow these steps:

Check with your lender early in the process.

Review your building’s fire risk assessment for any mention of external wall risks.

Engage with your managing agent or freeholder—only the building owner can commission an EWS1.

Confirm assessor competence—ensure they are on the RICS EWS Assessment completers list or have equivalent qualifications.

Request a PAS 9980-based approach to ensure the assessment is proportionate.

FAQs – Is an EWS1 Required for Buildings Under 18m?

Q1: Is an EWS1 a legal requirement for buildings under 18m?
No. There is no legal requirement solely based on height. However, lenders or building owners may request it if there are fire risk concerns.

Q2: Can any surveyor complete an EWS1 for a building under 18m?
No. Only competent professionals—such as RICS, IFE, or CABE members who have completed the EWS training—should sign an EWS1. For complex or high-risk buildings, an IEng or CEng fire engineer may still be required.

Q3: What happens if my lender asks for an EWS1 but my building is under 18m?
You will still need to arrange for the building owner to commission one. The height does not exempt you if the lender insists.

Q4: Does PAS 9980 replace the EWS1 form?
No. PAS 9980 is the technical assessment standard; the EWS1 is a summary form for lenders.

Q5: How long does an under-18m EWS1 take?
Typically 2–8 weeks, depending on complexity and whether intrusive investigations are required.

Q6: Can an EWS1 confirm that no remedial works are needed?
Yes. An Option A1 outcome indicates that the external wall system contains no significant fire risk materials.

Conclusion - Is an EWS1 Required for Buildings Under 18m?

While the EWS1 process was born from concerns about high-rise safety, it is not solely limited to buildings above 18m. For leaseholders in lower-rise blocks, the need for an EWS1 is driven by a risk-based approach. Combustible cladding, extensive timber balconies, or complex façades can trigger the requirement even for smaller buildings.

Understanding competence requirements, engaging early with your lender, and ensuring a PAS 9980-compliant assessment are the keys to navigating the process smoothly. By approaching the issue proactively, leaseholders can minimise delays and uncertainty in property transactions.

Need Help with an EWS1 Form or Fire Risk Assessment?

We deliver EWS1 assessments across the UK with speed, precision, and professionalism. Our team is:

Registered with Royal Institution of Chartered Surveyors, Institution of Fire Engineers, BAFE Fire Safety Register, Fire Industry Association and the Chartered Association of Building Engineers

Fully qualified to complete both Category A and B assessments

Focused on delivering lender-acceptable, clear, and timely reports

Whether your building is six storeys or twenty, our experts offer comprehensive reports, risk classification, and actionable recommendations.

Contact us today to book a survey or get advice on whether your building qualifies.

With offices in London, Birmingham , Manchester, Bristol, Brighton, Norwich & Plymouth we provide EWS1 certificates and undertake Fire Risk Assessments all around the UK.

For more information 'Is an EWS1 Required for Buildings Under 18m' or any other aspect of this service see the collection of articles in our blog.

To commission an EWS1 Survey or a Fire Risk Assessment please call our Enquiry line on 020 4534 3130.

To book a call back from a member of the Fire team, please fill in our Contact Us form.

For further help or advice please contact :