The Fire Safety Act 2021: what changed for multi-occupied buildings

What the Act brings into scope

For any building containing two or more sets of domestic premises, the Fire Safety Order now expressly applies to:

• The building's structure and external walls, including cladding, insulation, render and any attachments such as balconies and solar panels
• Doors between domestic premises and the common parts — flat entrance doors

What this means for your fire risk assessment

A fire risk assessment for a block of flats that says nothing about the external wall construction or the condition of flat entrance doors is no longer defensible. The assessor must consider them, and where they cannot be assessed from the ground or from existing records, the assessment should say so and recommend further intrusive investigation.

This is what created the market for the FRAEW (fire risk appraisal of external walls) carried out to PAS 9980. Not every block needs one. The judgement is risk-based: height, the presence of combustible materials, balcony construction and known defects all feed into whether an appraisal is proportionate.

Flat entrance doors in practice

Flat entrance doors are the weakest point in the compartmentation of most residential blocks. They are fire doors that residents treat as front doors — propped, drilled for cat flaps, fitted with letterboxes that are not fire-rated, and left with self-closers removed or disconnected.

The Fire Safety (England) Regulations 2022 built on the Act by requiring, in buildings above 11 metres, annual checks of flat entrance doors on a best-endeavours basis and quarterly checks of communal fire doors. Below 11 metres, residents must be given information about the importance of keeping their doors in good working order and not altering them.

Enforcement expectations

Fire and rescue authorities can and do serve enforcement notices where an assessment ignores external walls or entrance doors. Because the Act only clarified existing duties, there is no grace period to point to — the duty is treated as having always been there.

For landlords and managing agents, the practical response is a documented programme: a compliant fire risk assessment that addresses the external envelope, an entrance-door inspection cycle with a record for every flat including access attempts that failed, and a remediation plan with dates.