When Is a Fire Risk Assessment Required in the UK?

Fire safety is a legal obligation, not an optional extra. If you’re a business owner, landlord, property manager, or the “responsible person,” you must know when a fire risk assessment is required, what it must cover, and how often to review it. This guide sets out the rules under the Regulatory Reform (Fire Safety) Order 2005 and the Fire Safety (England) Regulations 2022, with a practical checklist you can use today.

What Is a Fire Risk Assessment?

The Legal Framework

When Is a Fire Risk Assessment Required?

Who Is the Responsible Person?

How Often Must You Review an FRA?

Documentation & Record‑Keeping (Oct 2023 updates)

Extra Duties for High‑Rise & Multi‑Occupied Residential Buildings

What Your FRA Should Cover

Evidence Pack to Keep

Penalties for Non‑Compliance

FAQs – When Is a Fire Risk Assessment Required?

Book a Compliant Fire Risk Assessment

What Is a Fire Risk Assessment?

A fire risk assessment (FRA) is a structured, evidence‑based review of your premises to identify fire hazards, evaluate people at risk, and set proportionate measures to prevent fire and protect life if a fire occurs. It ends with a written action plan prioritising improvements, targets, and responsible owners.

The Legal Framework

Two core instruments apply in England & Wales:

Regulatory Reform (Fire Safety) Order 2005 (the “Fire Safety Order”) – requires a suitable and sufficient FRA for almost all non‑domestic premises, and for the common parts of residential buildings.

Fire Safety (England) Regulations 2022 – add specific duties for multi‑occupied residential buildings, with further measures for high‑rise buildings (18m+/7+ storeys), including plans, signage, and equipment checks.

Since 1 October 2023, amendments introduced via Section 156 of the Building Safety Act 2022 tightened duties on how you record and share fire safety information. (See “Documentation & Record‑Keeping”.)

When Is a Fire Risk Assessment Required?

1) All Non‑Domestic Premises

If staff, customers, contractors, visitors, or the public can access your premises, you must have an FRA. This includes:

Workplaces: offices, co‑working spaces, factories, warehouses, laboratories, data centres.

Retail and hospitality: shops, supermarkets, cafés, restaurants, pubs, hotels, venues.

Public and community buildings: schools, healthcare, libraries, leisure centres, places of worship.

Specialised and high‑risk activities: care homes, clinics, workshops with hot works or hazardous substances.

2) Common Parts of Residential Buildings

The Fire Safety Order applies to communal areas of blocks of flats and HMOs (e.g., lobbies, corridors, stairwells, plant rooms, bin stores). It does not apply inside individual flats used solely as private dwellings.

3) Construction, Fit‑Out, and Vacant Premises

Where non‑domestic premises are under construction, undergoing alterations, or standing vacant but accessible to people, you still need a current, suitable FRA that reflects the site risks, contractor activities, and temporary fire precautions.

4) Shared or Multi‑Occupancy Sites

Where multiple businesses share a building, each responsible person must ensure an FRA covers their undertaking and cooperate on shared fire precautions (alarms, routes, signage, evacuation strategy).

5) Trigger Events (You Must Review/Update Immediately)

Layout or use changes (e.g., open‑plan conversions, new mezzanine, storage increases).

Major works to fire safety systems (alarms, sprinklers, smoke control, fire doors).

Significant changes in occupancy, working patterns, or vulnerability (e.g., more night staff, new clinic).

New processes or hazardous materials; hot works; lithium‑ion storage/charging areas.

A fire, false alarm trends, or enforcement action.

Who Is the “Responsible Person”?

Depending on the premises, the responsible person is typically the employer (for workplace areas), the owner or landlord, or any other person with control (e.g., managing agent or facilities manager). In multi‑occupied buildings, there can be more than one responsible person, each with duties for their areas, plus a duty to cooperate and coordinate on shared risks.

How Often Must You Review an FRA?

The law requires FRAs to be kept current. While no fixed period is mandated, a pragmatic schedule is:

Annually: formal review for most premises.

Higher risk: review every 6–12 months (e.g., care, healthcare, sleeping risk, complex sites).

After any trigger event: update immediately.

For simpler, low‑risk premises with stable occupancy and no changes, the review may confirm the assessment remains valid; for complex or high‑risk sites, plan more frequent reviews and audits.

Documentation & Record‑Keeping (from 1 October 2023)

Section 156 of the Building Safety Act 2022 amended the Fire Safety Order so that all responsible persons must now:

Record the fire risk assessment in full (the old “5+ employees” threshold no longer applies).

Record fire safety arrangements in full (planning, organisation, control, monitoring, and review).

Cooperate and share fire safety information with other responsible persons and incoming/outgoing duty‑holders (e.g., when tenancies change).

Provide residents with relevant fire safety information in multi‑occupied residential buildings.

Practically, this means you should maintain a clear, version‑controlled FRA document, keep an up‑to‑date building fire strategy (where applicable), and retain evidence of maintenance, training, drills, and actions closed.

Extra Duties for High‑Rise & Multi‑Occupied Residential Buildings

The Fire Safety (England) Regulations 2022 introduce specific, additional requirements:

For High‑Rise Residential Buildings (18m+ or 7+ storeys)

Secure information box: install and maintain a box containing RP contact details and required documents.

External wall record: prepare and keep up‑to‑date a record of external wall design, materials, the assessed risk, and mitigations.

Plans: prepare floor plans and a single‑page building plan; place hard copies in the secure information box; keep them updated.

Monthly checks: check lifts for firefighters/evacuation lifts and essential fire‑fighting equipment; report faults lasting >24 hours to the local fire and rescue authority and record checks for residents to view.

Wayfinding signage: ensure clear, low‑light‑visible floor and unit identification in stair and lift lobbies.

Resident information: display fire safety instructions and provide them to residents on move‑in and at least annually.

For Multi‑Occupied Residential Buildings Above 11m

Fire doors: use best endeavours to check flat entrance doors at least every 12 months; check communal fire doors at least every 3 months; ensure self‑closing devices operate correctly.

Resident information: provide annual information about fire doors (keep shut, do not tamper with closers, report faults immediately).

What Your FRA Should Cover

Your FRA should be proportionate to the risk and the complexity of your building. As a minimum, include:

Hazard identification: ignition sources, fuel loads, processes, hot works, battery storage/charging, contractors.

People at risk: employees, residents, visitors, contractors, lone workers, sleeping risk, vulnerable persons.

Fire protection measures: compartmentation, fire doors, escape routes, travel distances, signage, emergency lighting, detection/alarm, sprinklers/suppression, smoke control, evacuation alert systems.

Management measures: fire policy, procedures (including PEEPs/ GEEPs), drills, training, permit to work, housekeeping, maintenance regimes, testing schedules, false alarm reduction.

Strategies: evacuation strategy (simultaneous, phased, stay put with contingencies), incident plans, coordination with the fire and rescue service.

Action plan: prioritised recommendations with owners, deadlines, and sign‑off.

Evidence Pack to Keep

Maintain a simple but complete compliance pack to demonstrate due diligence:

Current FRA and action tracker (with version control and closure evidence).

Building fire strategy (where applicable) and any external wall assessments/records.

Certificates and logs for alarms, sprinklers, emergency lighting, smoke control, firefighting lifts.

Fire door inspection records (communal and flat entrances as applicable).

Training records, drill reports, PEEPs/GEEPs, visitor/contractor procedures.

Copies of information provided to residents (where relevant) and to other responsible persons.

Penalties for Non‑Compliance

Failing to carry out and maintain a suitable and sufficient FRA can lead to enforcement notices, prohibition notices, unlimited fines, and in serious cases, criminal prosecution. Insurers may challenge claims if you cannot evidence compliance. Most critically, weak fire risk management endangers life.

FAQs – When Is a Fire Risk Assessment Required?

Do I need an FRA for a single shop unit?

Yes. All non‑domestic premises require a current, suitable and sufficient FRA.

Do residential landlords need a fire risk assessment?

Yes, for the common parts of blocks of flats and HMOs. Private flats themselves are usually outside scope, but doors opening onto common parts and resident information duties still apply.

How often should I review my FRA?

Keep it current. Review at least annually, and immediately after changes (layout, occupancy, systems) or a fire incident.

What changed on 1 October 2023?

All responsible persons must now record the FRA and fire safety arrangements in full and share fire safety information appropriately (Section 156, Building Safety Act 2022).

Do high‑rise residential buildings have extra requirements?

Yes. You must maintain a secure information box, external wall record, floor and building plans, conduct monthly checks of firefighting lifts/equipment, ensure wayfinding signage, and provide resident instructions.

We share a building with other tenants. Who is responsible?

Each party is responsible for its area and must cooperate and coordinate on shared risks and measures.

Can I complete the FRA myself?

Only if you are competent. Many duty‑holders appoint a qualified fire risk assessor to ensure thoroughness and compliance.

Does an empty building need an FRA?

Yes, if people may access it (e.g., security, contractors, viewers). The FRA should reflect vacant‑building risks and controls.

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 :