Fire Risk Assessments in London: Why the Works Have to Actually Happen, Not Just Be Recorded

Fire risk assessor in a high-vis vest surveying London council estate buildings

A signed fire risk assessment in a folder has never put out a fire.

An FRA is important because it identifies hazards, assesses risk and sets out the actions needed to protect residents. However, the assessment is the start of the job. It is not the finished result.

If a report identifies defective fire doors, blocked escape routes, missing alarms or combustible external wall materials, those issues must be managed and resolved. A risk that is recorded but left in place remains a fire hazard.

For landlords, property owners, social housing providers and council housing teams across London, the message is clear: fire safety compliance must be demonstrated through completed works, evidence and ongoing management.

What Is a Fire Risk Assessment?

Under the Regulatory Reform (Fire Safety) Order 2005, the Responsible Person must carry out and regularly review a suitable and sufficient fire risk assessment.

In a multi-occupied residential building, the Responsible Person will usually be the building owner, landlord or manager responsible for the common parts and relevant structure. There may be more than one Responsible Person, and each must cooperate so that the building is managed as a whole.

The duty is not simply to commission a report. The Responsible Person must put in place and maintain reasonable fire precautions.

Since October 2023, changes introduced by Section 156 of the Building Safety Act 2022 require Responsible Persons to:

Record the fire risk assessment in full.
Identify the assessor and their organisation where applicable.
Record the building’s fire safety arrangements.
Share relevant fire safety information with residents.
Cooperate with other Responsible Persons and Accountable Persons where applicable.

Residents should be able to understand the significant risks identified in their building, the protective measures in place and what they should do in the event of fire.

Fire risk assessment paperwork being reviewed by a property professional

What Should the Assessment Cover?

The Fire Safety Act 2021 clarified that the assessment must consider more than internal communal areas. It includes the building’s structure, external walls, balconies, cladding and flat entrance doors opening onto common parts.

A suitable FRA may consider:

Means of escape and emergency routes.
Fire doors, self-closing devices, seals and door gaps.
Compartmentation between flats and common areas.
Fire detection, alarms and emergency lighting.
Signage and wayfinding.
Housekeeping, storage and ignition sources.
External wall systems, cladding and balcony materials.
Residents’ ability to evacuate safely.
The building’s evacuation strategy.
Procedures for reporting and completing remedial works.

For higher-risk residential buildings, generally those at least 18 metres high or with at least seven storeys, the Building Safety Regulator regime also applies. This includes expectations around the golden thread of building information, mandatory occurrence reporting and a safety case approach.

The Remediation Enforcement Unit became operational in March 2026 to support enforcement activity involving higher-risk buildings with serious safety defects. This makes accurate records and timely action even more important.

Height-Based Duties for Residential Buildings

The Fire Safety (England) Regulations 2022 introduced additional duties for multi-occupied residential buildings.

For buildings over 11 metres, the Responsible Person must arrange:

Quarterly checks of fire doors in common parts.
Annual checks of flat entrance doors, using best endeavours.
Fire safety information for residents.
Information for the local Fire and Rescue Authority where required.

For high-rise residential buildings, further duties include:

Keeping electronic floor plans available for the Fire and Rescue Service.
Maintaining a secure information box.
Providing external wall system information.
Checking firefighting and evacuation lifts monthly.
Checking other key firefighting equipment.
Reporting certain faults that cannot be repaired within 24 hours.
Providing wayfinding signage that remains visible in low-light or smoky conditions.

These duties are not paperwork exercises. They exist because firefighters need reliable information, and residents need working safety measures before an emergency occurs.

What Grenfell Teaches About Uncompleted Works

On the night of 14 June 2017, 72 people died at Grenfell Tower in North Kensington. The loss of life caused profound grief for families, survivors and the wider community.

The Grenfell Tower Inquiry’s Phase 1 report was severe in its findings about the “stay put” instruction, which continued to be communicated to residents after it could safely have applied. It also found that vulnerable and disabled residents were disproportionately affected.

The Phase 2 report identified a chain of failures over decades. These included unsafe cladding and materials, a regulatory system that did not function properly, and defects that were identified but not acted upon.

Residents had raised and documented concerns about fire safety for years. The lesson is not simply that a building lacked a risk assessment. The deeper lesson is that concerns can be recorded, reported and still left unresolved.

That is the failure mode this article addresses.

The Government’s February 2026 annual report on its response to the Phase 2 recommendations confirms that work remains ongoing. The fire safety regime has been substantially rewritten, but the government has not claimed that every recommendation has been fully implemented.

Why Outstanding Works Create a Fire Hazard

A fire risk assessment identifies a hazard. It does not remove it. Only effective work, followed by inspection and evidence, can reduce the risk.

Defective fire doors

A fire door that does not self-close, has been wedged open, has damaged smoke seals or has excessive gaps may fail to hold back fire, smoke and hot gases.

In a block of flats, that can allow smoke to enter a protected corridor or stairwell. An escape route can become dangerous or impassable before residents have time to leave.

Blocked escape routes

Items stored in stairwells, rubbish in corridors and mobility scooters placed in communal escape routes can obstruct movement. They may also add fuel to a fire.

An FRA recommendation to clear the route is not complete until the obstruction has been removed and the area is being monitored.

Missing or disconnected alarms

Detection systems provide valuable warning time. Missing detectors, isolated alarms or unresolved faults can mean residents receive no warning when a fire starts.

A recommendation to repair or replace an alarm should have a responsible owner, a deadline and completion evidence.

Compartmentation defects

Unsealed service penetrations, holes in walls and floors, damaged ceiling linings and poorly protected risers can allow fire and smoke to spread beyond the flat of origin.

This can undermine the building’s evacuation strategy. The National Fire Chiefs Council explains that “stay put” advice depends on effective compartmentation and suitably protected means of escape.

External wall and balcony defects

Combustible cladding, defective external wall systems and combustible balcony materials can allow fire to travel up the outside of a building.

Internal fire doors and alarms cannot compensate for every external wall defect. Where an FRA or specialist assessment identifies a serious external wall concern, the building owner must ensure that the appropriate technical investigation, interim measures and remediation process are progressed.

Inadequate evacuation planning

Residents need clear information about the building’s evacuation strategy. Residents who cannot evacuate without assistance may also need tailored support.

From 6 April 2026, the Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 apply to high-rise residential buildings and residential buildings over 11 metres with a simultaneous evacuation strategy.

Responsible Persons must take reasonable steps to identify relevant residents, offer a person-centred fire risk assessment where requested, consider reasonable and proportionate measures, and provide a written statement explaining what the resident should do in the event of fire.

Information about a resident can be shared with the Fire and Rescue Authority only with that resident’s explicit consent. Consent matters. The rules do not require personal information to be handed over without it.

A building-level evacuation plan must also be prepared, kept under review and shared with the local Fire and Rescue Authority. The secure information box must be capable of holding the required documents.

The explanatory memorandum estimates the total cost to the social housing sector at approximately £342.4 million over ten years. Government funding has been provided to support social housing providers with these changes.

A Practical FRA Action Plan

Action	What good management looks like
Immediate risk	Make the area safe promptly. Consider temporary controls while permanent works are arranged.
Short-term repair	Assign an owner and deadline. Obtain a competent contractor and retain the report.
Planned remediation	Record the scope, funding route, approvals and target completion date.
Completion	Keep photographs, certificates, contractor reports and inspection records.
Ongoing review	Reassess after works, refurbishment, conversion, incidents or material changes.

For landlords and housing providers, the process should include:

Commissioning a suitable and sufficient FRA from a competent, ideally accredited assessor.
Reading the action plan rather than filing it away.
Giving every recommendation a named owner and deadline.
Prioritising life-safety risks before lower-risk improvements.
Recording completed works with clear evidence.
Sharing understandable fire safety information with residents.
Reviewing evacuation arrangements and reasonable adjustments.
Managing personal information lawfully and obtaining consent where required.
Coordinating with freeholders, leaseholders, managing agents and other Responsible Persons.
Allowing for service charge and consultation procedures without using them to delay urgent safety work.

How a Managing Partner Can Help

RNS Homes holds properties on lease arrangements and manages them day to day. Through our property management service, we help coordinate inspections, maintenance, compliance monitoring and remedial works.

For councils and public sector organisations, our social housing solutions focus on providing properly managed, compliant accommodation. We also support landlords seeking guaranteed rent with full property management.

A managing partner can help keep the assessment cycle moving, arrange contractors, follow up outstanding actions and maintain evidence. However, a managing partner does not remove the landlord’s underlying obligations.

Structural remediation, building safety case work and defects involving an external wall system remain the responsibility of the owner or the relevant building dutyholder. No management company can make an unsafe building safe through administration alone.

Clear communal stairwell with a closed fire door and maintained escape route

Get a Compliance Review

Do you have a current FRA but an unclear action plan? Are repairs outstanding, records incomplete or responsibilities divided between several parties?

Contact RNS Homes to discuss a free initial compliance review of your property management arrangements. We are here to help you understand what is outstanding, who needs to act and how completed works should be evidenced.

This article provides general information about fire safety duties in England. It is not legal, fire engineering or building safety advice. Engage a competent fire risk assessor and appropriate specialist professionals for advice on your specific building.