What Is a Fire Risk Assessment and When Is One Required?

Summary

The Regulatory Reform (Fire Safety) Order 2005 replaced over 70 pieces of previous fire safety legislation and placed responsibility for fire safety firmly on the "responsible person" — typically the employer, building owner, or occupier. The Order applies to all non-domestic premises in England and Wales, including workplaces, commercial buildings, the common areas of HMOs (houses in multiple occupation), and the common parts of blocks of flats.

A fire risk assessment is not a single document or checklist — it is a structured process of identifying what could cause a fire, who might be at risk, what existing precautions are in place, and what further action is needed. The responsible person must either carry one out themselves (if competent to do so) or appoint a competent person to do it on their behalf.

The Building Safety Act 2022 and subsequent Fire Safety (England) Regulations 2022 introduced additional requirements for higher-risk residential buildings, creating a more demanding regime for buildings over 18 metres or 7 storeys. For most tradespeople working in smaller commercial or residential properties, the RRO framework remains the primary obligation.

Key Facts

• Legal basis — Regulatory Reform (Fire Safety) Order 2005 (RRO), Article 9
• Who must have one — All non-domestic premises in England and Wales; common areas of residential blocks and HMOs
• Responsible person — Employer, building owner, or person in control of premises
• Review triggers — After significant changes to the building, its use, occupants, or whenever the assessment may no longer be valid
• Minimum review frequency — No prescribed interval, but annually is widely recommended; more frequently for high-risk premises
• Documentation — Must be recorded in writing if you employ 5 or more staff; best practice to record regardless
• 5-step process — Identify hazards, identify people at risk, evaluate and act, record and plan, review
• Competency requirement — Assessor must have sufficient training, experience, knowledge, and skill for the specific premises
• HMO requirement — All licensed HMOs require an assessment; unlicensed HMOs in common areas still require one under RRO
• Blocks of flats — Common areas require assessment; individual flats were brought within scope by the Fire Safety Act 2021
• Fire Safety Act 2021 — Clarified that blocks of flats include the structure, external walls, and flat entrance doors within scope
• Higher-risk buildings — Buildings over 18m or 7 storeys face additional requirements under the Building Safety Act 2022
• Enforcement — Local fire and rescue authorities; powers to issue enforcement notices, prohibition notices, and prosecute
• Penalties — Unlimited fines; up to 2 years imprisonment for serious breaches (Article 32 RRO)
• Insurance implications — Insurers routinely require evidence of a current, adequate assessment

Quick Reference Table

Detailed Guidance

The Five-Step Process

The Home Office and National Fire Chiefs Council (NFCC) guidance sets out a recognised five-step process for carrying out a fire risk assessment:

Step 1 — Identify fire hazards Consider sources of ignition (heating appliances, electrical equipment, smoking materials, hot works), sources of fuel (combustible materials, waste, stored goods, furnishings), and sources of oxygen (natural ventilation, mechanical systems, oxidising chemicals).

Step 2 — Identify people at risk Consider employees, contractors, customers, visitors, and any particularly vulnerable people — including those who work alone, those with mobility or sensory impairments, those unfamiliar with the building, and sleeping occupants. Sleeping risk significantly increases the severity classification.

Step 3 — Evaluate, remove, reduce, and protect Evaluate the risk of a fire starting and the risk to people. Eliminate or reduce hazards where possible. Where hazards cannot be removed, ensure adequate protection: fire detection and warning systems, fire-fighting equipment, means of escape, emergency lighting, and signage.

Step 4 — Record, plan, instruct, inform, and train Record significant findings and actions taken. Prepare an emergency plan. Ensure staff are trained in fire procedures, including evacuation, use of extinguishers (where appropriate), and reporting.

Step 5 — Review and revise Review the assessment regularly. Triggers for immediate review include: structural alterations, changes in occupancy or use, a fire occurring, significant new hazards introduced, or changes in the number or nature of occupants.

Who Can Carry Out an Assessment

The RRO requires the assessor to be a "competent person" — defined as someone with sufficient training and experience, knowledge, and other qualities to enable them to properly assist in undertaking preventive and protective measures. There is no mandatory licensing or accreditation scheme, but the Third Party Certification (TPC) scheme operated by the BAFE (British Approvals for Fire Equipment) provides recognised accreditation for fire risk assessors.

For low-risk premises (e.g., a small office with limited occupancy), a responsible person with basic fire safety awareness may be competent to carry out the assessment themselves using published guidance. For complex, high-risk, or higher-risk residential buildings, an accredited assessor with demonstrable experience of that building type is strongly recommended — and for buildings over 18m, the Building Safety Act effectively demands it.

When appointing an external assessor, check:

• Membership of a recognised professional body (e.g., IFE — Institution of Fire Engineers)
• Third-party certification (BAFE SP205 scheme)
• Specific experience with the building type
• Professional indemnity insurance

Common Findings

Inspections by fire and rescue services consistently identify the same recurring deficiencies:

• Inadequate fire detection — no automatic fire detection, or coverage not extending to all risk areas
• Blocked or obstructed escape routes — props on fire doors, stored goods in corridors, poor housekeeping
• Faulty or missing self-closers on fire doors — one of the most common enforcement notice triggers
• No or inadequate emergency lighting — particularly in areas without natural light
• Out-of-date or undertested fire-fighting equipment — extinguishers not annually serviced
• Missing or inadequate fire action notices
• No evidence of staff training — no records of induction fire training or drills
• Inadequate compartmentation — unsealed service penetrations, missing cavity barriers
• Assessment not reviewed — original assessment from building completion, never updated despite changes

Documentation Requirements

If you employ 5 or more people, the significant findings of the assessment must be recorded in writing. This includes:

• The hazards identified
• The people at risk
• The existing fire precautions
• The actions taken or planned
• The date of the assessment and the date of the next review

Even where recording is not strictly required by headcount, maintaining written records is strongly recommended for insurance purposes, due diligence in property transactions, and defence against enforcement action.

Frequently Asked Questions

Does every building need a separate fire risk assessment?

Yes, if the building is occupied by different employers or responsible persons controlling different parts, each part may require its own assessment. Where a building has a managing agent or freeholder responsible for common areas, that party must carry out an assessment for the common areas separately from any assessments carried out by individual tenants for their own occupancy.

How often should a fire risk assessment be reviewed?

There is no legally prescribed interval. The RRO requires the responsible person to review it regularly and revise it where necessary. In practice, annual review is widely adopted as the minimum standard. High-risk premises (care homes, hospitals, large places of assembly) should consider more frequent review. Immediate review is required following any fire, significant building alteration, change of use, or change in the nature or number of occupants.

Can I use a template or online tool?

For very simple, low-risk premises, the government's online fire risk assessment tools and template forms (available via gov.uk) are a starting point. However, templates are not substitutes for judgement — a properly conducted assessment must reflect the actual conditions of the specific premises. Using an unsuitable template or ticking boxes without genuine evaluation can leave the responsible person exposed to enforcement action and uninsured.

What happens if I don't have one?

Failure to carry out a suitable and sufficient fire risk assessment is a criminal offence under Article 32 of the RRO. Fire and rescue authorities have powers to issue enforcement notices requiring remedial action, prohibition notices preventing use of all or part of the building, and to prosecute. Penalties include unlimited fines and, for the most serious breaches (such as those that put people at serious risk of death), up to 2 years imprisonment. Insurers may also refuse to pay claims where the absence of an adequate assessment is found to be a contributing factor.

Does the assessment cover external walls and cladding?

Following the Fire Safety Act 2021, the responsible person for a multi-occupied residential building must assess the building's structure, external walls (including cladding and insulation), and flat entrance doors as part of the fire risk assessment. This brought high-rise residential buildings more firmly into the RRO regime and triggered the External Wall System (EWS1) process for mortgage lending purposes.

Regulations & Standards

• Regulatory Reform (Fire Safety) Order 2005 (SI 2005/1541) — Primary fire safety legislation for non-domestic premises in England and Wales; Article 9 requires fire risk assessment

• Fire Safety Act 2021 — Clarified scope of RRO to include external walls, structure, and flat entrance doors of multi-occupied residential buildings

• Building Safety Act 2022 — Introduced the higher-risk building regime for buildings over 18m/7 storeys; established the Building Safety Regulator

• Fire Safety (England) Regulations 2022 (SI 2022/547) — Additional duties for responsible persons in multi-occupied residential buildings; wayfinding signage, evacuation plans, fire door checks

• PAS 79-1:2020 — Specification for fire risk assessments of non-domestic premises

• PAS 79-2:2020 — Specification for fire risk assessments of housing

• BS 9999:2017 — Code of practice for fire safety in the design, management and use of buildings

• Fire safety in the workplace: making your premises safe — GOV.UK overview of responsible person duties

• Regulatory Reform (Fire Safety) Order 2005 — Full text of the Order

• Fire risk assessments: guidance for businesses — Home Office sector-specific guides

• NFCC Fire Risk Assessment Competency Council guidance — National Fire Chiefs Council competency framework

• BAFE SP205 scheme — Third-party certification for fire risk assessors

• compartmentation — How fire compartmentation works and how to maintain it

• fire door installation — Fire door standards and installation requirements

• passive fire protection — Overview of passive fire protection products and methods

• fire safety order — Detailed breakdown of the RRO's specific requirements