Fire Risk Assessments for Flats and Blocks of Flats: What's Required and Who's Responsible

A block of flats with any shared area needs a fire risk assessment of its common parts, and the person who controls the building — usually the freeholder or managing agent — is legally responsible for it. The assessment covers the communal spaces, the structure and external walls, and the flat entrance doors that open onto escape routes. It does not cover the inside of each privately occupied flat. How much else it covers depends almost entirely on how tall the building is.

This guide explains what is required, who carries the duty, and how the rules step up at 11 metres and again at 18 metres or seven storeys.

This article summarises UK fire safety law for educational purposes and is not legal advice. The responsible person carries the legal liability for fire safety in the building, even where the assessment is carried out by a competent assessor on their behalf. For specific compliance questions, consult a competent fire risk assessor or your local fire and rescue authority.

What a Block of Flats Needs

The Regulatory Reform (Fire Safety) Order 2005 — the Fire Safety Order — applies to the common parts of any residential building containing two or more sets of domestic premises. For a block of flats, that means the entrance hall, stairwells, corridors, lift lobbies, bin and bike stores, plant rooms, and any other shared space.

Article 9(1) of the Order sets the core duty: "the responsible person must make a suitable and sufficient assessment of the risks to which relevant persons are exposed." For a block, "relevant persons" are the residents and anyone else who might be in or around the building.

Since the Fire Safety Act 2021, the scope is wider than the communal corridors. Section 1 of that Act inserted into the Order that where a building contains two or more sets of domestic premises, the things to which the Order applies include:

"(a) the building's structure and external walls and any common parts; (b) all doors between the domestic premises and common parts ..."

with the reference to external walls including "doors or windows in those walls, and ... anything attached to the exterior of those walls (including balconies)." So a competent assessment of a block now reaches the external wall system and every flat entrance door, not just the hallway carpet and the extinguisher.

Who Is Responsible

The responsible person is whoever controls the building's common parts. Article 3 of the Order points to "the person who has control of the premises ... in connection with the carrying on by him of a trade, business or other undertaking," or the owner where no one else has that control. In practice, for a block of flats that is:

• The freeholder, where they manage the building directly;
• The managing agent, where one has been appointed to run the building;
• A residents' management company or right-to-manage company, where the leaseholders collectively control the building.

The duty to carry out the assessment can be delegated to a competent assessor. The legal responsibility cannot. If you sit on the board of a residents' management company, that responsibility is yours — which is exactly why most RMCs engage a competent assessor and keep the report current.

On the common question of who pays: the cost is normally recovered through the service charge under the terms of the lease, so leaseholders fund it collectively. But the duty to ensure the assessment happens does not depend on the payment mechanism.

How Height Changes Everything

This is where blocks of flats diverge from every other premises type. Two height thresholds matter.

Over 11 metres — fire door inspection duties

The Fire Safety (England) Regulations 2022 (SI 2022/547) added duties on responsible persons for multi-occupied residential buildings. For buildings over 11 metres containing two or more sets of domestic premises, the responsible person must arrange inspections of communal-area fire doors at least every three months and flat entrance doors at least every twelve months, checking the self-closing devices work. Our fire door inspection guide covers the method, and the fire door checklist tool gives you a structured on-site list.

18 metres or seven storeys — high-rise duties

Regulation 3 of SI 2022/547 defines a "high-rise residential building" as:

"a building containing two or more sets of domestic premises that— (a) is at least 18 metres above ground level; or (b) has at least seven storeys."

For those buildings, the 2022 Regulations add the secure information box, the external wall record, floor and building plans, monthly checks of firefighting lifts and equipment, and wayfinding signage. The same 18-metre / seven-storey building, where it contains at least two residential units, also meets the Building Safety Act 2022 definition of a higher-risk building for the in-occupation regime. The gov.uk criteria describe it as:

"a building in England that— (a) is at least 18 metres in height or has at least 7 storeys, and (b) contains at least 2 residential units."

That brings the building within the Building Safety Regulator's occupation regime — a separate set of duties (the safety case, the building assessment certificate) that sit alongside, not instead of, the fire risk assessment. Your assessment feeds the wider safety case; it does not replace it.

The practical headline: a four-storey converted block under 11 metres is a relatively contained piece of work. A purpose-built tower at 20 storeys is a different category of building entirely, and needs an assessor with the competence to match.

What the Assessment Works Through

For a typical block of flats, a competent assessment covers:

• Escape strategy — usually "stay put" for purpose-built blocks with good compartmentation, or simultaneous evacuation where compartmentation cannot be relied on. The strategy must match the building, and residents must be told which one applies.
• Compartmentation — whether each flat is an effective fire-resisting box, including fire stopping around service penetrations and in roof voids.
• Means of escape — protected stairwells, travel distances, and whether escape routes are kept clear of stored items.
• Flat entrance doors — fire rating, seals, and self-closers on the doors that protect the common escape route.
• External walls — the construction and any cladding; where there is a credible concern, the route is a specialist PAS 9980 external wall assessment, not a guess from the assessor.
• Detection, lighting, and signage in the common parts.
• Management — the resident information cycle, equipment checks, and the record of the assessment.

A competent assessor follows a recognised structured methodology and records findings, a risk evaluation, and an action plan with timescales. The output is a report the responsible person can act on and produce to an enforcing authority.

Practical Takeaways

• Confirm the building's height — it determines which duties apply. The 11-metre and 18-metre/seven-storey lines are the ones that matter.
• Identify the responsible person clearly, especially where a managing agent or RMC is involved.
• Make sure the assessment reaches the external walls and flat entrance doors, not just the communal corridors.
• Keep fire-door inspections on schedule for buildings over 11 metres.
• Record the assessment in full and set a review date.

Summary

Every block of flats with communal areas needs a fire risk assessment of those common parts, plus — since 2021 — the structure, external walls, and flat entrance doors. The responsible person is whoever controls the building, and the legal duty cannot be delegated away. Building height is the variable that drives everything: 11 metres for fire-door inspection duties, 18 metres or seven storeys for high-rise and higher-risk-building duties.

For managing agents and assessors handling several blocks, the ongoing challenge is keeping each building's assessment, door-inspection cadence, and review date on track. AssessKit gives you a site-by-site portfolio with action tracking and review reminders, built on a recognised structured methodology (PAS 79-1 for non-domestic premises, BS 9792:2025 for housing). Start free — the Free plan includes two assessments a month, no card required. See pricing for the full plans.

Sources

• Regulatory Reform (Fire Safety) Order 2005, Article 9 — Risk assessment (legislation.gov.uk)
• Fire Safety Act 2021, Section 1 — Premises to which the Fire Safety Order applies
• Fire Safety (England) Regulations 2022, Regulation 3 — Meaning of high-rise residential building
• Criteria for being a higher-risk building during the occupation phase (GOV.UK)
• Fire safety in purpose-built blocks of flats (GOV.UK)