Guide
Fire door inspections and building safety duties
Your legal duties for fire door inspections and building safety under the Fire Safety Act 2021 and Fire Safety (England) Regulations 2022. Covers which buildings are affected, inspection frequencies, external wall assessments, and resident information requirements.
The Fire Safety Act 2021 was passed in response to the Grenfell Tower tragedy. It closes gaps in fire safety law by clarifying that fire risk assessments for multi-occupied residential buildings must cover external walls (including cladding) and flat entrance doors.
The Fire Safety (England) Regulations 2022 then introduced specific duties for fire door inspections, building information, and resident communication. If you own, manage, or control a multi-occupied residential building in England, these requirements apply to you.
This guide explains what changed, which buildings are covered, and exactly what you must do to comply.
What the Fire Safety Act 2021 changed
Before 2021, there was legal uncertainty about whether the Regulatory Reform (Fire Safety) Order 2005 covered external walls and flat entrance doors in residential buildings. Some building owners argued these were outside scope and did not need to be included in fire risk assessments.
The Grenfell Tower Inquiry Phase 1 report revealed the devastating consequences of this gap. The Fire Safety Act 2021 removes all ambiguity by explicitly confirming that the Fire Safety Order applies to:
- The structure of the building including walls, floors, and compartmentation
- External walls including cladding systems, balconies, windows, and anything attached to the exterior
- All flat entrance doors that open onto common parts (corridors, stairwells, lobbies)
This is not a new duty - it clarifies what was always intended. But many building owners are now reviewing and updating fire risk assessments that previously excluded these elements.
Which buildings are covered
The Fire Safety Act 2021 applies to all multi-occupied residential buildings in England and Wales, regardless of height. This includes:
- Purpose-built blocks of flats
- Converted houses with multiple flats
- Houses in Multiple Occupation (HMOs)
- Student accommodation blocks
- Sheltered housing schemes
- Mixed-use buildings with residential units above commercial premises
A building is "multi-occupied residential" if it contains two or more sets of domestic premises (flats, maisonettes, or similar). A single-family home converted into two flats is covered. A building with one penthouse flat above offices is covered.
Height does not matter for basic duties. Whether your building is 3 metres or 30 metres tall, you must include external walls and flat entrance doors in your fire risk assessment. The height thresholds (11m, 18m) only trigger additional requirements like fire door inspection frequencies.
Who is the responsible person?
Fire safety law places duties on the "responsible person" - whoever has control of the building. In multi-occupied residential buildings, this is typically:
- The freeholder or building owner (for structure and common parts)
- A management company (if they control the common parts)
- A managing agent (if given sufficient control by the freeholder)
- A Resident Management Company (RMC) (if they own the freehold or control the building)
- Housing associations and local authorities (for their housing stock)
In many buildings, there are multiple responsible persons. The freeholder might be responsible for the structure and external walls, while a management company is responsible for common parts and fire doors. Each responsible person must comply with the duties for the areas under their control, and they must cooperate with each other.
Fire door inspection requirements
The Fire Safety (England) Regulations 2022 introduced mandatory fire door inspection requirements for buildings 11 metres or higher (approximately 5 storeys). These came into force on 23 January 2023.
Communal fire doors - quarterly inspections
Fire doors in communal areas (corridors, stairwells, lobbies, refuse rooms) must be inspected at least every three months. This applies to all fire doors that residents or visitors might pass through in common parts of the building.
Flat entrance doors - annual inspections
Individual flat entrance doors (the front door of each flat that opens onto the communal corridor or stairwell) must be inspected at least once per year. The responsible person must make "best endeavours" to gain access - this means making reasonable attempts to arrange inspections with residents.
What counts as a fire door inspection?
Fire door inspections must check that doors are functioning correctly and maintaining compartmentation. Each inspection should verify:
- Closing mechanism - door closes fully and latches on its own
- Self-closing device - overhead closer or rising butt hinges working
- Intumescent strips and smoke seals - intact and not painted over
- Gaps around frame - no gaps exceeding 3mm when door is closed
- Hinges - secure, correct number (usually 3), correct specification
- Door leaf - no damage, holes, letterboxes (unless fire-rated), cat flaps, or modifications
- Glazing - if present, fire-rated glass with correct fire certification
You must keep records of all inspections and any remedial work carried out. Fire and Rescue Authorities can request these records during inspections.
Who can inspect fire doors? There is no legal requirement for inspections to be carried out by a third party. However, the person conducting inspections must be competent - they must understand what makes a fire door effective and be able to identify defects. Many managing agents use specialist fire door inspection companies or train their own staff.
External wall assessment duties
The Fire Safety Act 2021 confirms that your fire risk assessment must cover the external walls of the building. This includes:
- Cladding systems (all types, not just ACM)
- External wall insulation
- Balconies and their construction materials
- Windows and window surrounds
- Cavity barriers between floors
- Anything attached to or forming part of the external wall
EWS1 external wall surveys
For buildings with complex cladding systems, you may need an External Wall Survey (EWS1) conducted by a qualified professional. This is particularly relevant if:
- Your building is 18 metres or higher with any cladding
- Your building has ACM (aluminium composite material) cladding at any height
- Your building has combustible cladding and your fire risk assessment identifies significant risk
- Residents need EWS1 certificates for mortgage or sale purposes
An EWS1 form is completed by a qualified fire engineer and records their assessment of the external wall system. Options range from A1 (no combustible materials present) through to B2 (combustible materials present, remediation required).
Information for residents
The Fire Safety (England) Regulations 2022 require responsible persons to provide fire safety information to all residents. You must tell residents about:
- Fire safety measures in the building
- The evacuation strategy (stay put or simultaneous evacuation)
- What to do if they discover a fire or hear the alarm
- How fire doors work and why they must remain closed
- Who the responsible person is and how to contact them
- How to report fire safety concerns
Additional requirements for taller buildings
Buildings 18 metres or higher have extra information requirements:
- Fire and emergency file - comprehensive building information must be maintained and made available to Fire and Rescue Authority (Regulation 5)
- External wall information - residents can request information about external wall systems and cladding (Regulation 6)
- Secure information box - electronic or physical information box containing building plans and fire safety information for Fire Authority access (Regulation 7)
Penalties for non-compliance
Fire safety breaches under the Fire Safety Order 2005 (as amended) are criminal offences. Since the Grenfell Tower fire, enforcement has intensified significantly. Fire and Rescue Authorities are conducting more inspections and prosecuting more cases.
Who can be prosecuted
- The responsible person - whoever has control of the building or relevant part
- Directors and officers - personally liable if the offence was committed with their consent, connivance, or attributable to their neglect
- Employees - can be fined (but not imprisoned) for their own breaches
Prosecutions have increased since Grenfell. In 2023-24, Fire and Rescue Authorities secured convictions with fines ranging from £10,000 for smaller landlords to over £150,000 for larger building owners. Several directors have been personally fined for allowing serious fire safety failures.
How this links to the Building Safety Act 2022
If your building is 18 metres or higher (or 7+ storeys) and contains residential units, you must also comply with the Building Safety Act 2022. This creates additional duties on top of the Fire Safety Act requirements.
The key difference:
- Fire Safety Act 2021 - applies to all multi-occupied residential buildings; enforced by Fire and Rescue Authorities
- Building Safety Act 2022 - applies to higher-risk buildings (18m+/7+ storeys) only; enforced by the Building Safety Regulator (part of HSE)
For higher-risk buildings, you will have two regulators to satisfy: the Fire and Rescue Authority for fire safety duties, and the Building Safety Regulator for the higher-risk building regime. The requirements overlap but are not identical.
Action plan for compliance
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Confirm you are a responsible person
Check whether you have control over any multi-occupied residential building. If you're a freeholder, management company, managing agent, or RMC, you almost certainly have fire safety duties.
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Review and update your fire risk assessment
Ensure your fire risk assessment explicitly covers external walls (including cladding, balconies, windows) and flat entrance doors. If it predates May 2022, it likely needs updating.
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Determine your building's height
Measure the building height from ground level to the top of the top storey floor surface. This determines which additional requirements apply (11m for fire door inspections, 18m for information duties).
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Set up fire door inspection schedules
For buildings 11m+: implement quarterly inspections of communal fire doors and annual inspections of flat entrance doors. Create a schedule, assign responsibility, and set up record-keeping.
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Arrange resident communication
Prepare and distribute fire safety information to all residents. Include evacuation strategy, fire door importance, and your contact details. Keep a record of when information was provided.
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For 18m+ buildings: set up secure information box
Install an electronic or physical information box containing building plans and fire safety information that Fire and Rescue Authority can access. Maintain a fire and emergency file.
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Check if Building Safety Act also applies
If your building is 18m+ or 7+ storeys with residential units, you also have Building Safety Act duties including registration with the Building Safety Regulator.
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Consider external wall survey
For buildings with cladding, assess whether you need an EWS1 survey. This is essential if you have ACM cladding or if leaseholders are having difficulty selling or remortgaging.
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Document everything
Keep comprehensive records of all fire risk assessments, fire door inspections, remedial works, resident communications, and any external wall surveys. Inspectors will ask to see these.
Common compliance failures to avoid
- Assuming height exempts you - The Fire Safety Act 2021 applies at any height. Only fire door inspection frequencies have 11m threshold.
- Relying on old fire risk assessments - Pre-2022 assessments likely don't cover external walls and flat doors adequately.
- Not checking flat entrance doors - "Best endeavours" means actively trying to arrange inspections, not just sending one letter.
- Poor record keeping - If you can't prove you did the inspections, you may as well not have done them.
- Assuming the managing agent handles everything - Legal responsibility cannot be delegated. Check what your agent is actually doing.
- Ignoring resident concerns - Complaints about fire doors not closing or propped-open doors should trigger immediate investigation.
- Confusing the two Acts - Fire Safety Act 2021 and Building Safety Act 2022 have different thresholds, different enforcers, and different requirements.