Short answer: the Fire Safety Act 2021 confirms that, in any building with two or more domestic premises, the Regulatory Reform (Fire Safety) Order 2005 covers the structure, external walls (including balconies and windows) and flat entrance doors. The Responsible Person must make sure the fire risk assessment covers them. If yours predates the Act or ignores the walls and doors, have it reviewed.

Since the full implementation of the Fire Safety Act 2021, the legal landscape for "Responsible Persons" in the UK has shifted significantly. If you manage a multi-occupied residential building, the previous "grey areas" regarding who is responsible for external walls and flat entrance doors have officially vanished.

Failing to update your Fire Risk Assessment (FRA) to reflect these changes isn't just a minor safety oversight—it is a direct breach of statutory duty. With local Fire Authorities ramping up inspections, operating with a legacy assessment is a massive legal risk.

The Cost of Non-Compliance If an inspector finds that your Fire Risk Assessment does not account for the new elements introduced by the Fire Safety Act 2021, you can be issued an Enforcement Notice immediately. Failure to comply can lead to unlimited fines or criminal prosecution.

Key Takeaways for Landlords & Block Managers

  • Scope Expansion: The Fire Safety Order now explicitly includes the building’s structure, external walls (including cladding and balconies), and all flat entrance doors.
  • Mandatory Updates: Existing FRAs that do not specifically assess these new elements are likely considered "not suitable and sufficient."
  • The "Responsible Person": Absolute legal liability rests with the owner, freeholder, or block manager to ensure these areas are professionally inspected.

🔥 Are you exposed? Use our Free Fire Safety Scorecard to identify vulnerabilities in your building before an official auditor arrives.

What Has Actually Changed?

Before 2021, there was often a legal "tug-of-war" between leaseholders and freeholders regarding who was responsible for the fire integrity of a front door or the cladding on a balcony. Assessors often excluded these areas, leading to critical safety gaps.

The Fire Safety Act 2021 definitively clarified the Regulatory Reform (Fire Safety) Order 2005. It states that for any building containing two or more sets of domestic premises, the Fire Safety Order applies strictly to:

  • The Building’s Structure & External Walls: This includes anything attached to the exterior, such as cladding, insulation, and even balcony fixings.
  • Flat Entrance Doors: The doors that lead from individual flats into common parts (corridors and stairwells) are now officially part of the "common parts" for the purpose of a Fire Risk Assessment.

The Risk of "Legacy" Assessments

If your last professional Fire Risk Assessment was conducted prior to these legislative updates, it highly likely focused only on the communal hallways, stairwells, and plant rooms.

Under the new regime, an inspector from the local Fire and Rescue Service will look specifically for your External Wall Assessment and evidence that Flat Entrance Doors have been checked for self-closing integrity and fire-strips. If these are missing, your compliance folder is incomplete, and your building is technically non-compliant.

Expert tip "Don't wait for your next scheduled review. If your current FRA doesn't explicitly mention 'External Wall Construction' or 'Entrance Door Sampling,' you should commission a compliance review immediately to protect your legal position and your tenants."

For more detailed guidance on the exact legal text, you can view the official government update on the Fire Safety Act 2021 here.

3 Steps to Stay Compliant in 2026

1

Review Your Current FRA

Check the "Scope" section of your current document. Does it actively mention the external envelope of the building and the flat entrance doors? If not, it is outdated.

2

Conduct a Door Audit

Ensure all flat entrance doors are appropriately fire-rated and, crucially, that the self-closing mechanisms are fully operational and not tampered with by tenants.

3

Consult a Professional

Fire safety in multi-occupied buildings is now far too complex for "DIY" checklists. Appoint a competent assessor who understands the Fire Safety Act 2021 scope and, for housing FRAs, current BS 9792:2025 practice.

Need a Legally Compliant Review?

Next step: Get a quote for a fire risk assessment through Safety Certificates UK’s matching network.

Guidance only — not legal advice. Requirements depend on the premises and enforcing authority. Arrange a formal on-site assessment where needed.

How the Fire Safety (England) Regulations 2022 sit alongside the Act

For multi-occupied residential buildings in England, the Fire Safety (England) Regulations 2022 add operational duties that scale with height: fire safety instructions and fire door information for residents in all such buildings, quarterly checks of communal fire doors and best-endeavours annual checks of flat entrance doors above 11 metres, and further duties (such as a secure information box and wayfinding signage) above 18 metres or seven storeys. These sit on top of the Fire Safety Act 2021 clarifications. Your fire risk assessment should record which duties apply and who performs them.

GOV.UK’s fire safety law collection and workplace fire safety guidance remain the practical starting points for Responsible Persons.

Evidence fire authorities expect to see

  • A suitable and sufficient fire risk assessment covering structure, external walls and flat entrance doors where the Act applies.
  • Records of self-closer and seal checks on flat entrance doors opening onto common parts.
  • Clear Responsible Person details for freeholder, RMC and managing agent interfaces.
  • An action plan with timescales — hiring an assessor does not transfer legal liability.

Fire risk assessment service · Get a quote. Typical small-premises bands £180–£350; medium or sleeping-risk buildings often £350–£750.

Primary sources

Related guides: BS 9792:2025 Housing Fire Risk Assessment — What Landlords Need · How Often Should a Fire Risk Assessment Be Reviewed? (UK Law) · Fire Risk Assessment HMO Guide.