Open consultation

Fire risk assessors profession

Published 26 March 2026

Applies to England

Scope of the consultation

This consultation seeks views on proposals relating to the fire risk assessor (FRA) profession. It covers the following areas:

• the future development of the FRA profession
• the powers needed to regulate the FRA profession, and
• implementation approaches for competency requirements in the FRA profession

Geographical scope

These proposals relate to England only.

Impact assessment

Not required. We will use feedback from the consultation to inform our assessment of the impact of the measures.

Basic Information

Body responsible for the consultation:

Ministry for Housing, Communities and Local Government

Duration

This consultation will last for 12 weeks from 26 March 2026 to 18 June 2026.

Enquiries

For any enquiries about the consultation please contact:

FireSafetyUnitconsultations@communities.gov.uk

How to respond

You may respond by completing the online survey.

Alternatively, you can email your response to the questions in this consultation to:

FireSafetyUnitconsultations@communities.gov.uk

If you are responding in writing, please make it clear which questions you are responding to.

Written responses should be sent to:

Fire Risk Assessor Consultation
Attn: National Resilience and Fire Safety Division,  
Fry Building,
2 Marsham Street, 
Westminster, 
London, 
SW1P 4DF

When you reply it would be very useful if you confirm whether you are replying as an individual or submitting an official response on behalf of an organisation and include:

• your name

• your position (if applicable)

• the name of organisation (if applicable)

• an address (including post-code)

• an email address

• a contact telephone number

Ministerial foreword

The events at Grenfell Tower, and the deaths of the 72 innocent people it caused, were a national tragedy which must never be repeated. Grenfell, together with earlier tragedies such as the 2009 Lakanal House fire, exposed longstanding weaknesses in a regulatory system that should have kept people safe in their homes. The Grenfell Tower Inquiry’s detailed examination laid bare the scale and seriousness of those systemic failings. For this reason, this government has accepted the principle of all the Grenfell Tower Inquiry (GTI) Phase 2 recommendations and is acting decisively to secure their implementation. Ensuring the safety of people in their homes and communities is, and will remain a top priority.

This consultation is an important step in delivering our commitments in relation to FRAs. Ministerial responsibilities for all fire-related functions, including policy relating to FRAs, transferred to the Ministry of Housing, Communities and Local Government in April 2025. I am pleased this work therefore forms part of a wider suite of departmental publications on a range of Grenfell Tower Inquiry recommendations to deliver professional, regulatory and institutional reform relating to fire safety and the built environment. These include the publication in December 2025 of the Single Construction Regulator Prospectus and an Authoritative Statement and Next Steps Statement on Fire Engineers. Further, a call for evidence on professions working on the safety of the built environment and a consultation on the development of a College of Fire will shortly be published. I would encourage everyone who reads this consultation to also consider those publications as they are issued.

FRAs perform a critical fire safety role, keeping people safe – not only in blocks of flats, but in almost every non-domestic building from workplaces to care homes to nightclubs. Their assessments help identify hazards, ensuring effective fire safety precautions are in place to protect those who live in, work in, or visit buildings across England. Despite this, the FRA role is not currently a regulated profession. There is no single professional body overseeing the industry, no consistent definition of the role, no clear consistent career pathway for those who wish to enter the profession and no mandatory training, qualifications or certification. This lack of consistency means that those occupying or responsible for fire safety in premises lack assurance that FRAs are always competently undertaking these vital fire risk assessments.

Everyone is entitled to feel safe in their home, and in the buildings they use. As the Secretary of State has made clear, this government is committed to ensuring every family can access a safe, decent and affordable home. We want an FRA profession which helps deliver our vision: with consistently high levels of competency, a strong and diverse pipeline of skilled practitioners, transparency, and rebuilt trust and confidence for those who rely on their expertise. These principles underpin the government’s ambitions for the wider built environment and for fire safety.  

I welcome the steps already taken by industry to improve competency standards, including the development of the British Standard BS8674 in 2025. Continued collaboration between government and industry is essential and I strongly encourage the fire safety sector to continue its important role in driving improvements. While many FRAs are highly competent, we must continue to raise standards across the board. The government is therefore acting on the Grenfell Tower Inquiry’s recommendation to establish consistent and mandatory competency requirements.

This government is determined to drive improvements in fire and building safety. The reforms we are taking forward - including those outlined in this consultation – are an important part of ensuring communities across England are protected. I urge all stakeholders to engage in this consultation and help shape a stronger, more competent and accountable FRA profession which consistently delivers its vital fire safety role.  

Minister Samantha Dixon MP

Executive summary

For non-domestic premises including the common parts of blocks of flats, Responsible Persons (RPs) (see Glossary for definitions) are under a duty to make a suitable and sufficient fire risk assessment to identify general fire precautions. RPs can currently undertake this assessment themselves, and they may appoint someone, known as an FRA, to assist them in doing so.

Fire risk assessments, and those who undertake them, play a key role in making sure those who live in, work in or visit buildings are safe. However, FRAs are not a regulated profession, lacking common definitions, structures and career pathways. Concerns about the conduct of fire risk assessments have been raised over the last two decades, including following major fires.

Following the events of 14th June 2017 at Grenfell Tower, a series of reports and consultations have further illustrated the need for action to ensure consistent competency in the FRA profession. Dame Judith Hackitt’s Independent Review of Building Regulations and Fire Safety, published in 2018, found that a new, coherent competence framework was required to allow those with duties under the FSOs to satisfy themselves of the competence of an FRA.^{[footnote 1]}

The Grenfell Tower Inquiry Phase 2 report recommended that government “establish a system of mandatory accreditation to certify the competence of fire risk assessors”. The government accepted this recommendation in full. The report also recommended that government establish a regulator undertaking a range of functions, including the “accreditation of fire risk assessors”. The government has accepted this recommendation and is making progress in implementing it.^{[footnote 2]}

Important work has been undertaken by the fire safety sector both prior to and following the Grenfell Tower tragedy to strengthen the profession, including the publication in 2025 of British Standard BS 8674 which sets out the skills, knowledge, experience and behaviours that industry considers FRAs should possess. 

The proposals presented in this consultation identify opportunities to go further in ensuring the best possible public safety outcomes. The vision proposed for the future of the FRA profession through this document is one where there are consistent standards of competency, excellent career opportunities, clear standards and effective regulation of the profession. These reforms will mean that those with duties under fire safety legislation, residents, leaseholders, building users and developers will have greater confidence in the quality and consistency of fire risk assessments, and therefore the safety of the buildings they use, live in and build.

To achieve this vision, this consultation sets out proposals relating to:

• defining the role of FRAs
• considering the RP’s ability to conduct their own assessments
• developing competency frameworks and standards
• establishing clear career pathways
• providing appropriate regulatory powers
• ensuring effective implementation of measures introduced

Informed by the findings of this consultation, we will seek to legislate when parliamentary time allows.

FRAs form part of a complex and fragmented fire safety, building safety, and construction landscape, however it will be vital for the various professions and regulations to form a coherent regulatory regime. To support greater coherence, the Single Construction Regulator Prospectus and consultation was published in December 2025. The Prospectus committed to a new framework to underpin the competence, skills and conduct of those working in the industry, which will be the subject of a call for evidence in 2026.

Also published in December 2025, the Fire Engineers Authoritative Statement and Next Steps Statement included commitments to consider the relationship between fire engineers and FRAs during the occupation phase of a building given the important links between these fire safety professions. Responses to this consultation will help us explore this relationship.

Introduction

Existing legislation

The Fire Safety Order

The Regulatory Reform (Fire Safety) Order 2005 (FSO) is the principal legislation covering fire safety in non-domestic premises in England and Wales. This includes the common parts of blocks of flats.^{[footnote 3]}

Article 9 of the FSO places a statutory duty on RPs^{[footnote 4]} to:

make a suitable and sufficient assessment of the risks to which relevant persons are exposed for the purpose of identifying the general fire precautions they need to take to comply with the requirements and prohibitions imposed on them by or under this Order.^{[footnote 5]}

The fire risk assessment is therefore vital to ensuring people’s safety, given these assessments are the foundation for the fire safety precautions in any relevant premises.

RPs can currently undertake fire risk assessments themselves, and statutory guidance is available to assist them in the discharge of their duties under the FSO. All of this guidance advises that, if the RP is unable to apply the guidance, they should seek expert advice from a competent person, and that more complex premises will probably need to be assessed by a person who has comprehensive training or experience in fire risk assessment.

Article 5 (3) of the FSO may extend the Article 9 duty to every person who has, to any extent, control of the premises so far as the requirements relate to matters within their control. This might include a person who assists the RP with the fire risk assessment if they meet the requirements in Article 5.

Background and Supporting Legislation

For certain types of premises, particularly those where significant fires have occurred in the past, other legislation may place additional duties on those conducting a fire risk assessment. A non-comprehensive list is given below:

The Fire Safety and Safety of Places of Sport Act 1987

Introduced partly in response to the Bradford City Stadium fire of 1985, the Act requires the RP to apply for a safety certificate as a condition of their license to operate, which must not contravene the fire risk assessment duties under FSO Article 9.

The Dangerous Substances and Explosive Atmospheres Regulations 2002

Dangerous substances present unique risks from fire and explosions – the most notable UK example being the 1974 explosion at the Flixborough chemical plant that led to the deaths of 28 people. Premises where such substances are liable to be present have additional risk assessment duties under these regulations – the findings of which should be used to inform the more general assessment made under FSO Article 9.

The Licensing Act 2003

This Act builds on preceding legislation that was enacted in response to several significant fatal fires in these types of licensed premises (e.g., nightclubs, cinemas, theatres). The Act requires those applying for mandatory licenses to operate to submit evidence that they’ve met their fire safety objectives, of which the FSO Article 9 risk assessment is an essential component.

The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014

Care providers are required to assess the potential health and safety risks to their users (FSO Article 9 for fire safety). Failure to do so can lead to prosecution and the removal of provider’s ability to operate. This legislation was partly in response to the 2004 Rosepark Care Home fire, which resulted in the deaths of 14 residents.

The Fire Precautions (Sub-surface Railway Stations) England Regulations 2009

Those fire risk assessing sub-surface railway stations must ensure that their recommendations comply with additional duties under these regulations, which were originally introduced in response to the King’s Cross fire of 1987.

The Building Safety Act 2022

The Building Safety Act 2022 (BSA) sets out duties and responsibilities for those involved in the design, construction, maintenance and management of higher-risk buildings (the person with duties and accountable persons). For the purposes of the BSA, higher risk buildings are premises at least 18 metres or 7 storeys in height, containing two or more residential units^{[footnote 6]}.

Relevant persons with duties and accountable persons are identified and have duties to cooperate, including with the RP under the FSO, to coordinate with each other and be competent (have the skills, knowledge, experience and behaviours) for design and building work they undertake.

Fire Risks Assessors - the case for change

The tragedy at Grenfell Tower in 2017, which took 72 lives including 18 children, was preventable. The failings it exposed, including the impact upon the most vulnerable, demand fundamental change. It was preceded by a series of serious fires, including the fatal fire at Lakanal House in 2009.

In the wake of the events of 14th June 2017, the government invited Dame Judith Hackitt to carry out an Independent Review of Building Regulations and Fire Safety. In her final report, published in 2018^{[footnote 1]}, she made a series of recommendations for fundamental change that directly led to the government legislating through the BSA 2022. In relation to FRAs, she found that the approach to competence was incoherent, specifically in relation to competence levels and the experience and qualifications required. In particular, she said fire risk assessments ‘often consist of little more than a ‘tick box’ exercise undertaken by someone without demonstrable competence of fire safety’ and noted that the scope of the existing frameworks used within the industry did not extend to include requirements for the enhanced levels of competence needed to assess high rise residential buildings.

In 2020, the previous government ran a consultation on proposals to strengthen fire safety through reform of the FSO. Of those who responded, an overwhelming majority (96%) agreed that those assisting RPs should be subject to mandatory competency requirements. Most respondents also believed that competence can only be demonstrated through relevant qualifications and accreditation.

There is a significant lack of data about those who conduct fire risk assessments professionally, linked to the lack of agreed professional definitions, structures and pathways. A first step was made to address this when the Home Office (previously holding responsibility for fire safety policy) published the results of a 2023 survey of FRA competency and capacity in September 2024. Of those who responded, only 46% belong to a certification or registration scheme, and 50% undertook no formal refresher training.^{[footnote 7]} 

The Grenfell Tower Inquiry Phase 2 report, published in 2024, found that the FRA appointed by the Kensington and Chelsea Tenant Management Organisation (TMO) had misrepresented both his experience and qualifications (some of which he had invented), and was ill-qualified to assess buildings of the size and complexity of Grenfell Tower, let alone the entire TMO portfolio. The Inquiry identified serious shortcomings in the fire risk assessments produced, including failures to identify critical fire safety hazards and to verify that previously identified risks had been addressed. Despite London Fire Brigade raising concerns about the competence of the FRA, the Inquiry found that the TMO continued to rely uncritically on him, a situation which they concluded made the danger more acute in the absence of any arrangements for assessing the quality of his work.

The Grenfell Tower Inquiry Phase 2 report recommended that, to address these issues, the government should:

establish a system of mandatory accreditation to certify the competence of fire risk assessors by setting standards for qualification and continuing professional development and such other measures as may be considered necessary or desirable. We think it necessary for an accreditation system to be mandatory in order to ensure the competence of all those who offer their services as fire risk assessors.

The government accepted this recommendation in full, committing to legislate to make it a mandatory requirement for FRAs to have the competence to perform this critical role.

The Building Safety Regulator’s (BSR) Industry Competency Committee (ICC) is a statutory body tasked with overseeing and facilitating the improvement of competence across the built environment.  As part of its remit, the ICC has helped identify the fundamental challenges facing the sector; where professional bodies provide oversight and certification, these can vary widely in terms of legal status, governance and public interest functions, and there is no consistent definition or enforcement of competence or standards for public accountability. As a result, there is generally insufficient recognition and benefit for those who do the right thing and limited consequences for those who do not, with wider implications for skills, development, safety, and overall productivity.

Professional and Institutional Reform

Fire risk assessments, and those who undertake them, play a vital role in a wider fire safety, building safety and construction professional and regulatory landscape. However, the Inquiry exposed a fragmented regulatory system, with multiple gaps in standards and assurance across building regulations, products and professions.     

The final report of the Grenfell Tower Inquiry made a number of recommendations regarding the regulation of the construction industry and professions which have safety-critical roles in relation to buildings. Alongside the recommendation above on FRAs, in relation to fire safety professions and their regulation, these included:

• government drawing together under a single regulator identified functions relating to the construction industry
• that, for higher-risk buildings, a statutory fire safety strategy must be produced by a registered fire engineer and submitted with building control applications
• introducing new legal protections for the fire engineering profession, supported by an independent body responsible for regulation, registration and standards

The government wholly accepts the findings of the Inquiry and remains committed to delivering these recommendations. We recognise that these reforms need to be delivered as part of a cohesive strategic approach to fire safety and building professions.

To support greater coherence, the Single Construction Regulator Prospectus: Consultation Document was published in December 2025. The Prospectus set out proposals for a new long-term strategy for the building professions, including wider trades and occupations. The aim of this strategy is to provide long-term benefits for building safety, quality and productivity, as well as supporting greater capacity, skills and investment in the workforce. Government will publish a call for evidence in spring 2026 to seek views on proposals for reform. We then aim to publish an overarching strategy for the built environment professions in spring 2027. This will include detailed design of a new framework for regulation, oversight and enforcement, alongside consideration of other, non-regulatory levers, including options to support skills, sustainable business growth and consumer advice.

In response to the Inquiry recommendations on fire engineers, the Fire Engineers Advisory Panel (‘the Panel’) was established in April 2025 to provide advice to government on the fire engineering profession. The Panel has developed an Authoritative Statement of the knowledge and skills to be expected of a competent fire engineer and advice on the implementation of the Inquiry’s wider recommendations for fire engineers. This was published in December 2025 alongside government’s Next Steps Statement on fire engineering. The Next Steps Statement committed to further analysis of Panel proposals relating to production and the contents of the fire safety strategy, the periodic review of the fire safety strategy during occupation and the relationship with the role of the FRA.

The evidence and feedback from this consultation will provide a key contribution as the government works with professions across the built environment to design a coherent framework of regulation for fire engineers and for FRAs.

Our vision for the profession

Government is committed to building a country where everyone has access to a safe, affordable and decent home. Fire safety professionals including FRAs have a vital role to play in delivering this outcome, ensuring that people are safe within their homes, and the places where they work and visit. Building on the reports, consultations and recommendations above, the proposals in this consultation provide a clear direction to build a formally recognised FRA profession which achieves the vision for the future set out below.     

Consistent competency

We want to see an FRA profession with consistently high and demonstrable standards of competency so that RPs are always capably supported when they employ an FRA. It is imperative that our communities can always have confidence in the competence and character of FRAs, given the crucial life safety role they hold.  

Clear standards

We intend to embed a system where there are clear competence frameworks, qualifications and standards of behaviour and practice. This will allow FRAs to demonstrate their skills, knowledge, experience and behaviour (SKEB) through a robust method of verifying competence.

We want to see a coherent approach to the certification of fire engineers and FRAs, within a wider framework of regulation for the building professions that ensures clarity and effective delineation of roles.

Excellent career opportunities

The government intends that this competence framework should provide an established and recognised career pathway with access to learning and progression that will attract new people, create a more diverse workforce and deliver career opportunities across the country. We consider this could include:

• the development of apprenticeships to provide a clear route into the FRA profession;
• a route for proficient existing workers, essential to ensuring that those who already work as FRAs (or in related professions) have a clear pathway to demonstrating their competence; and
• an effective, four nations approach which supports professionals to operate across the UK with minimal hindrance, and which looks to facilitate mutual recognition internationally.

Sector-wide coherence

As set out above (‘Professional and Institutional Reform’), fire risk assessment is just one component of a range of services provided by fire safety professionals. Regulating FRAs must sit coherently within the regulatory framework for wider professions and must recognise the ongoing relationship with other roles. This includes fire engineers and those who install protective fire safety measures as part of a broader regulated fire safety profession landscape. This consultation is a key step in understanding and managing those interactions and includes a number of questions that will help the government understand existing relationships and overlaps to inform future work.

Effective regulation

We recognise that effective oversight will need to be underpinned by a properly empowered regulator. Our intent is that regulation of FRAs should sit within the new integrated regulatory system for the built environment, as set out in the Single Construction Regulator Prospectus, supported by primary legislation when parliamentary time allows. More information on proposals for oversight of the regulation of professions can be found in that Prospectus which was consulted on earlier this year.

A sustainable workforce

We want to see sustainable capacity in the sector, so that there are always sufficient FRAs to undertake necessary assessments and a robust market for certified FRAs. To support this aim, this consultation asks questions about rollout approaches to support a smooth transition for the profession based on a clear understanding of present and future capacity requirements.

Future delivery

We will seek to legislate when parliamentary time allows, to deliver the vision set out in this consultation, subject to the responses we receive and within the wider context for the regulation of professions. Subject to parliamentary approval, we will work closely with the regulator to ensure that appropriate secondary legislation is put in place and will collaborate with all affected parties as we develop the detail of plans for the future of the FRA profession.

About you

To support our analysis of the questions in this consultation document, we are asking a brief series of questions about you and/or your organisation. The questions help us to identify the potential impacts of our proposals on individuals and organisations, including those with protected characteristics.

About you/your organisation

Question 1

What is your age? (Please select one)

• 18 to 34
• 35 to 49
• 50 to 64
• 65+
• prefer not to say

Question 2

Do you think of yourself as male or female? (We restrict the gender categories listed to prevent potential identification of individuals identifying in other ways)

• male
• female
• prefer not to say

Question 3

What is your ethnic group? (Please select the option which most closely applies to you)

• White
  • English or Welsh or Scottish or Northern Irish or British
  • Irish
  • Gypsy or Irish Traveller
  • any other white background
• Mixed / Multiple ethnic groups
  • White and Black Caribbean
  • White and Black African
  • White and Asian
  • any other mixed or multiple ethnic background
• Asian / Asian British
  • Indian
  • Pakistani
  • Bangladeshi
  • Chinese
  • any other Asian background
• Black / African / Caribbean / Black British
  • African
  • Caribbean
  • Any other Black or African or Caribbean background
• Other Ethnic Group
  • Arab
  • any other ethnic group
  • don’t know
  • prefer not to say

Question 4

[If you selected any ‘other’ ethnicity at the above question, please answer this question. If not, go to the next question] Please tell us your ethnic group.

• [Free Text Response]

Question 5

Are you responding as an individual, on behalf of a company, or on behalf of a trade organisation?

• individual
• company
• trade organisation
• other (please specify)

Question 6

[If you are responding on behalf of a company or trade organisation], what is the name of your organisation?

• [Free Text Response]

Question 7

[If you are responding on behalf of a company or trade organisation] Which of the following best reflects the role of your organisation? (Please select all that apply)

• Responsible Person (including property owners, managers and operators)
• Fire Risk Assessment
• Fire Engineering
• Other Fire Safety Professional
• Local Authority
• Insurance
• Fire and Rescue Service or Other Enforcing Body
• Qualification Provider
• Training Provider
• Certification Scheme Provider
• Residential Group
• Construction and Engineering (other than fire engineering)
• Other (please specify)

Question 8

[If you are responding as an individual] Which of the following best reflects your role? (Please select all that apply)

• Responsible Person (including property owners, managers and operators)
• FRA
• Fire Engineer
• Other Fire Safety Professional
• Local Authority Employee
• Insurance
• Fire and Rescue Service or Other Enforcing Body Employee
• Qualification Provider
• Training Provider
• Certification Scheme Provider
• Resident or Tenant
• Construction or Engineer (other than fire engineer)
• Other (please specify)

Question 9

[If you are a fire engineer, FRA, or other fire safety professional] Do you work primarily as an employee or under contract to Responsible Persons (or other contracting organisations)?

• employee
• contractor
• other (please specify)

About Fire Risk Assessments

Question 10

[If you are or your organisation is a Responsible Person] Do you/your organisation primarily conduct your own fire risk assessments or appoint an FRA under contract?

• I personally undertake the fire risk assessment myself
• I/my organisation employs a person directly who has responsibility for undertaking the fire risk assessment.
• I appoint an external FRA who charges a fee for undertaking the fire risk assessment.

Question 11

[If you or your organisation is a Responsible Person] How often do you/your organisation review your fire risk assessment?

• annually
• once every 2 years
• once every 3 years
• once every 4 years
• once every 5 years
• less than once every 5 years
• don’t know

Question 12

[If you or your organisation is Responsible Person] How many premises are you/your organisation responsible for?

• [Free Numeric Text Response]

Question 13

[If you undertake fire risk assessments] How many years’ experience in undertaking fire risk assessments do you have?

• less than 1 year
• 1 to 3 years
• 4 to 5 years
• 6 to 10 years
• 11 to 15 years
• 16 to 20 years
• more than 20 years

Question 14

Is your or your organisation’s work primarily in the public or private sector?

• public
• private
• mixed/other (please specify) [Free Text Response]

Question 15

In total, approximately how many people are employed in your organisation? (Please provide your best estimate).

• 1 (sole trader/consultant)
• 2 to 4
• 5 to 9
• 10 to 19
• 20 to 49
• 50 to 99
• 100+

Question 16

Which nations do you or your organisation operate in? (select all that apply)

• England
• Scotland
• Wales
• Northern Ireland
• other (please specify) [Free Text Response]

Question 17

[If you operate in England], which regions of England do you or your organisation operate in? (select all that apply)

• East of England
• East Midlands
• London
• North East
• North West
• South East
• South West
• West Midlands
• Yorkshire and the Humber
• other (please specify)

Creating a regulated profession

What is an FRA

There is no definition of an “FRA” in existing legislation. Though the role of FRA has been defined in various standards and guidance including BS 4422: 2024 Fire Vocabulary and BS 8674, we will need to legally define the role of the FRA and its protected assistance duties in order to regulate effectively.

FSO Article 9 applies to all premises within the scope of the FSO, and it requires that the RP make:

a suitable and sufficient assessment of the risks to which relevant persons are exposed for the purpose of identifying the general fire precautions they need to take to comply with the requirements and prohibitions imposed on them by or under this Order.^{[footnote 8]}

Whilst this duty should form the basis of a regulated FRA profession, there may be parallel and supplementary duties that also contain elements of fire risk assessment. We must ensure that competency of those performing these other duties is consistent with the regulation of fire risk assessment duties under FSO Article 9.

Fire engineering

FRAs play a vital role in fire safety, but they are unlikely to have the competency to undertake the most complex fire risk assessments (such as the assessment of the construction of external walls, inspections requiring intrusive surveys of a building’s structure, or an assessment of a complex higher-risk building) unless they possess fire engineering qualifications.

Following on from the GTI recommendations concerning fire engineers, the government is now progressing reforms to recognise the profession in law, including regulation of both title and function.

The Fire Engineers Advisory Panel’s authoritative statement and government’s plan for next steps were published in December 2025 and set out the direction of travel for reform. This includes commitment to a number of principles which should underpin reform, including that the development of a competent fire engineer should be a structured process combining formally accredited education and supervised professional experience, comparable to other engineering disciplines.

Fire safety strategies will be a central and defining function of the fire engineering role, and such strategies can play an important role throughout the lifecycle of a building. Further work is required to determine the scope of fire safety strategies, when they should be required and which buildings will require a fire safety strategy. This will form part of government’s work to take forward the GTI recommendations concerning reform to the fire engineering profession and the role of fire safety strategies in the higher-risk buildings regime. We will also need to consider the role of the FRA for all those premises where a fire safety strategy is in place.

To define the FRA and fire engineer roles and create a coherent landscape of fire safety professions, we must consider how the two roles currently interact, and this relationship may need to change going forward.

Other duties

For many FRAs and other fire safety professionals, fire risk assessments may be only one aspect of their work; a substantial sector exists to assist in the implementation and maintenance of the fire safety precautions identified by the fire risk assessment or fire safety strategy. We will need to consider how any mandatory competency requirements for FRAs and fire engineers will work in practice alongside the competency of those offering of these services and products.

We will also need to ensure that RPs understand what they need to do to comply with fire safety legislation, and that FRAs and other professionals clearly understand which services they are competent to offer. 

What is an FRA (All)

Question 18

In addition to FSO Article 9, to what extent do you agree or disagree that it’s necessary for a regulator of FRAs to have the power to introduce mandatory competency requirements for other fire safety duties within the scope of the FSO (including its secondary legislation)?

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 19

Are you able to elaborate on your response to the above?

• [Free Text Response]

Question 20

Are there fire safety duties outside the scope of the FSO (including its secondary legislation) over which it may be necessary for the regulator of FRAs to introduce mandatory competency requirements?

• [Free Text Response]

Question 21

[If you are a Responsible Person] Besides your risk assessment duties under FSO Article 9, do you seek assistance from outside your organisation to help you comply with any other fire safety duties? (e.g., fire door inspections)

• yes
• no
• not applicable
• [Free Text Response]

Question 22

[If you are a Responsible Person or others with duties] Do you have an existing document for your building that you identify as a fire safety strategy (prepared by a Fire Engineer and separate from the Fire Risk Assessment required under FSO Article 9):

• yes
• no
• don’t know
• not applicable

What is an FRA (FRAs, Fire Engineers and Other Fire Safety Professionals)

Question 23

Is assistance in fulfilling the FSO Article 9 risk assessment requirement your only fire safety duty/service?

• yes
• no
• not applicable

Question 24

If no, what are these other duties/services?

• [Free Text Response]
• not applicable

Question 25

Do you use existing building fire safety strategies (where available) to inform your fire risk assessments?

• yes
• no
• not applicable

Question 26

How, if at all, do you engage with fire engineering products and services in other ways when conducting a fire risk assessment?

• [Free Text Response]
• not applicable

Question 27

When would you recommend the services of a qualified fire engineer to the RP to assist in the fulfilment of their legal duties under Article 9 of the FSO? (e.g., fire risk assessments of external walls and intrusive surveys).

• [Free Text Response]
• not applicable

Question 28

If you’ve conducted fire risk assessments and/or you’re a qualified fire engineer, we would welcome any further thoughts on the reasons for your answers above.

• [Free Text Response]
• not applicable

The role of the Responsible Person

At present, Responsible Persons (RPs) can undertake their own fire risk assessments under Article 9 of the FSO, and government publishes statutory guidance to assist them in fulfilling this duty. Fire risk assessments, and those who undertake them, play a key role in making sure those who live in, work in or visit buildings are safe. In introducing mandatory competence requirements for FRAs, the government must also consider whether, and to what extent, RPs should continue to undertake fire risk assessments on their own premises if they are not registered competent professionals.

In exploring this question, we recognise the need to carefully consider factors including the safety of people, proportionality including cost, capacity in the FRA profession, and the clarity of any measures which are introduced. Defining fire risk is complex but any such definition would need to be readily understood so RPs and FRAs are clear on their legal duties.

In the Building Safety Act 2022 a definition of a higher-risk building (for residential premises) was introduced, covering buildings of at least 18 metres or 7 storeys in height. If the ability to conduct a fire risk assessment were to be restricted to registered professionals for certain premises types, we believe that, at a minimum, these premises should be included.

In considering further types of premises that may require assessment by a certified FRA, our initial position is that it may be appropriate to prioritise premises which present the greatest risks to life safety, through the likelihood of a fire occurring and/or the potential impacts on people when a fire does occur. As government takes forward the next steps on fire engineering profession reform, consideration of expanding the role of fire engineers throughout the lifecycle of higher-risk buildings and other premises, it will be necessary to consider similar factors to those mentioned above.

Consultation questions

Regulated Profession

Question 29

What factors do you believe are most important when considering whether a premises is of high potential risk to life safety?

• [Free Text Response]

Question 30

To what extent do you agree or disagree that fire risk assessments be restricted to regulated professionals for premises types considered of high potential risk to life safety?

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know
• [Free Text Response]

Question 31

To what extent do you agree or disagree that it should be mandatory to use regulated professionals to fire risk assess premises that meet the definition of a higher risk building as defined by the Building Safety Act 2022?^{[footnote 9]}

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 32

We would welcome any further thoughts on the reasons for this answer.

• [Free Text Response]

Competency frameworks and requirements

In order to verify an FRA’s competence, it is essential that there is a clear framework against which to assess their skills and knowledge.  A single, consistent competency framework would allow FRAs to understand and evidence that they are competent to perform their duties, regardless of where they received their training, qualifications and certification, and will allow those who employ their services to be assured that they are selecting people with the appropriate competency.

A competency framework should clearly set out the competency required for an organisation or individual to competently perform their duties. The fire safety industry has made progress here in developing a common standard for FRA competency in the new British Standard (BS 8674) for assessing FRA competency. This is one of a wider suite of standards being developed by the British Standards Institution to support competence in the built environment. The government welcomes this as an important step in setting out the skills, knowledge, experience and behaviours that industry considers FRAs should possess.

In responding to the recommendation in the Grenfell Tower Inquiry Phase 2 report, we now intend to build on that progress and ensure that FRAs, and those who employ their services clearly understand the Skills, Knowledge, Experience and Behaviours (SKEB) required. Formal qualifications (or equivalents) are an essential component of SKEB, but SKEB can only be fully assessed through certification, in which an independent body assesses whether an individual or organisation’s competency reaches the agreed standard and is appropriate for the work they wish to undertake. Assessment should be an ongoing process, with requirements for continuing professional development (CPD) and periodic recertification to ensure competence is maintained.

Buildings vary hugely in complexity and the risk and impacts of fire. As with BS 8674, it may be appropriate to provide for different tiers of professional competency to provide an entryway into the profession, and to provide RPs with a clear means to identify and secure the level of expertise that is proportionate to their premises, including fire engineering where necessary and/or appropriate.  The government proposes to work with the sector and with certification bodies, accreditation bodies and other relevant organisations to define frameworks for competence and qualifications that suitably addresses this level of complexity.

Consultation questions

Competency Requirements

Question 33

To what extent do you agree or disagree that all individual FRAs or the organisations who employ them should be certified to some extent in order to practice?

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 34

If no to the above, what other routes (e.g., qualifications without additional certification) do you think should be available to allow FRAs to practice?

• [Free Text Response]

Question 35

To what extent do you agree or disagree that there should be a single consistent competency framework by which to assess the required skills, knowledge, education and behaviours for organisations and individuals offering FRA services?

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 36

To what extent do you agree or disagree that a single consistent competency framework will support the enforcement of compliance?

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 37

Do you consider that every individual FRA should be certified and/or that organisations employing FRAs should be certified?

• individual FRAs
• FRA organisations
• both
• don’t know

Question 38

We would welcome any further thoughts on the reasons for your answers above by providing a response in the text box below.

• [Free Text Response]

Tiering

We previously asked you to outline the factors most important to you when considering the potential risk to life safety of different types of premises, and the competency required to assess them.

Question 39

To what extent do you agree or disagree that a single consistent competency framework should define different tiers of required competency for individuals and/or organisations offering FRA services?

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 40

We would welcome any further thoughts on the reasons for your answers above by providing a response in the text box below.

• [Free Text Response]

Accredited Qualifications and Certification

The Grenfell Tower Inquiry Phase 2 report recommended that the government establish:

a system of mandatory accreditation to certify the competence of fire risk assessors.

What is accreditation, and why is it important?

Accreditation is a process by which an organisation may demonstrate that they are competent to perform a set of specific activities, such as certifying the competence of FRAs.

We believe accreditation is essential because it ensures that those responsible for verifying FRA competency are themselves suitably competent and impartial to perform this task. We would also expect qualification providers to only offer qualifications that have been accredited (regulated) through the Office of Qualifications and Examinations Regulation (Ofqual). 

The fire safety sector has made significant steps since Grenfell to verify the competence, knowledge and skills of FRAs. However, there is currently limited independent accreditation at present, with only 2 UKAS-accredited bodies certifying FRAs.

The government will also need to understand the impacts that regulation could have on those working for the certification bodies who review FRA applications and test the technical competency of professional codes of conduct of individuals and organisations (the certification body personnel).

We recognise the potential challenges of mandatory accreditation. This may include impacts on the resource needed to certify all FRAs, and the potential for additional costs and obligations for organisations to satisfy the criteria for accreditation. We will work with organisations currently offering and seeking to offer certification to help ensure a smooth transition to a regulatory regime.

Consultation questions

Accreditation

Question 41

To what extent do you agree or disagree that FRA certification bodies should be subject to accreditation by an independent body before they can be approved to verify competence of FRAs?

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 42

What are the potential impacts of requiring accredited certification of FRAs? If there are risks, how could these be mitigated?

• [Free Text Response]

Question 43

To what extent do you agree or disagree that those certification body personnel assessing applications should be certified to an equivalent or higher level than those they assess?

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Codes of Professional Conduct

We recognise that cultural change is required across professions working in the built environment to mitigate the complacency and lack of due regard for competence evidenced at Grenfell Tower.  

Competency frameworks, certification and qualifications will allow FRAs to demonstrate that they have the necessary skills, knowledge and experience to competently perform the technical aspects of the role, but being a competent FRA is not just about being able to perform the technical aspects of the role.

Those employing their services (and people affected by their work) have a right to expect professional behaviours, and they should be confident that the FRA is working in the interest of public safety. The wider role of fire safety professionals covers a range of duties, and we recognise for instance the potential for commercial conflicts of interest where an FRA or the organisation they work for stands to benefit financially from the recommendations made by their fire risk assessment.

While we trust that many FRAs already uphold high standards of ethical behaviour, we believe that FRAs should be subject to a mandatory professional code of conduct. Such a code would set standards for the professional ethics and integrity expected from those in the profession. A regulator will need to have the power to review and enforce a code, and to sanction those who fail to comply with the required standard.

Consultation questions

Conduct

Question 44

To what extent do you agree or disagree that FRAs should have a mandatory code for professional conduct?

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 45

To what extent do you agree or disagree that FRAs should be required to declare conflicts of interest to those who employ them?

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 46

What would you want to see included in a mandatory code for professional conduct?

• [Free Text Response]
• not applicable

Career pathways

Apprenticeships

There is no formal entry point or route into the FRA profession, and no recognised pathways for progression such as a formal training or qualifications framework. 

In 2023, the government surveyed FRAs - 87% of the respondents were male, 65% were 50 years or older, and only 8% were aged under 35. While the results of this survey are not necessarily representative of the sector, together with feedback from ongoing industry engagement, they indicate concern about the low number of younger professionals in the sector and a need to both attract a more diversified workforce and create a sustainable pipeline of qualified professionals.  An apprenticeship scheme is one option which could address this and supports the government’s public commitments on growth, housebuilding and to professionalise the built environment workforce.

An apprenticeship is a career development programme that combines on the job training with study and skill building and is open to everyone from school leavers and graduates to those changing or starting careers later.  Since 2020 over 1.6 million apprentices have started their apprenticeship in a wide range of industries.  An apprenticeship can also lead to higher level apprenticeships and permanent employment with the employer: 93% of learners say that they are still in employment following their apprenticeship^{[footnote 10]}.  Within the wider context of fire safety professions, an apprenticeship also offers an alternate entry point for individuals who either cannot or choose not to pursue traditional higher education qualifications including those transitioning from other related fields. Apprenticeships may therefore help attract a wider demographic to enter the profession.

Consultation questions

Apprenticeships

Question 47

To what extent do you agree or disagree that apprenticeships would be beneficial for raising competency levels in the sector:

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 48

To what extent do you agree or disagree that an apprenticeship programme would help expand and diversify the workforce?

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 49

Would you or your company be interested in employing people undertaking apprenticeships in fire risk assessment?

• yes
• no
• don’t know
• not applicable

Question 50

Are there any other approaches, beyond apprenticeships, that you believe should be considered to support diversifying and expanding the FRA workforce?

• [Free Text Response]

Question 51

We would welcome any further thoughts on the reasons for your answers above by providing a response in the text box below.

• [Free Text Response]

Entry routes for existing proficient workers

Alongside new entrants to the FRA profession, we recognise that there may be many individuals operating in the sector who currently lack formal qualifications but are technically proficient and play an important role in ensuring the safety of our communities. We want to ensure this group is supported in the transition to a regulated profession. Those who are currently operating in the sector would need to have a clear pathway to mapping out their existing skills, knowledge and behaviours against the standard required to achieve certification

Consultation questions

Entry routes for existing proficient workers

Question 52

To what extent do you agree or disagree that existing FRAs should be awarded the qualifications required for certification if they can already demonstrate appropriate skills, knowledge, experience and behaviours?

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 53

If you agree to the above, what criteria could be used for determining admission onto such a scheme? (tick all that apply)

• time spent working as an FRA
• number of fire risk assessments completed.
• complexity of the fire risk assessments completed
• professional memberships
• evidence of training or Continuing Professional Development (CPD)
• other, please give details [Free Text Response]
• not applicable

Question 54

If you currently carry out fire risk assessment work, to what extent do you agree or disagree you would benefit from the availability of an existing proficient worker route?

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 55

We would welcome any further thoughts on the reasons for your answers above by providing a response in the text box below.

• [Free Text Response]

A central register

A central register of competent FRAs is essential to provide regulatory oversight, and to enable those seeking to employ FRAs to easily verify their competence and that they have been certified to an appropriate standard.

To enable a central register to function effectively, we need to consider the types of data to collect. This could include the following information for each FRA:

• a unique registration number
• name, employer, business address
• level of competency and specific skills
• date of registration for specific competency levels, and the length of their validity
• those whose registration has expired
• awarding bodies for relevant certification and qualification
• previous professional breaches and sanctions

While we expect all the information above will need to be collected to support regulation of the profession, we will work with the regulator to address detailed questions, such as management and sharing of information. 

Consultation questions

Central register

Question 56

To what extent do you agree or disagree that the information outlined above should be recorded?

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 57

Is there any other data that might be beneficial to collect for a central register of competent FRAs and why?

• [Free Text Response]

Question 58

To what extent do you agree or disagree that records of an FRA’s previous professional breaches and sanctions should be accessible to the public?

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 59

We would welcome any further thoughts on the reasons for your answers above by providing a response in the text box below.

• [Free Text Response]

Regulatory powers

In accepting the Grenfell Tower Inquiry Phase 2 report recommendation in full, we have committed to regulating FRAs. We will seek to legislate when parliamentary time allows. Our intention is that the role of the FRA will then fall into the scope of a formal regulated profession as defined in the Professional Qualifications Act (PQA) 2022.

The Inquiry also recommended that a single regulator be created for the construction industry to bring together fire safety functions including the “accreditation of fire risk assessors”. Our intent is that regulation of FRAs should sit within the new integrated regulatory system for the built environment, as set out in the Single Construction Regulator Prospectus: Consultation Document. More information on the wider thinking around oversight of the regulation of professions can be found in that document.

Standard setting

We recognise that moving to a sustainable professional framework will require working with professionals and others across the fire safety sector. It may also require developing the detailed requirements over time, both to set and manage the key standards and to identify and resolve areas of confusion or overlap.

It is therefore our intention that legislation should provide the delegated powers to define key areas such as the requirements for demonstrating competence and standards of professional behaviour, the arrangements for registration, and the role of the sector in working with the regulator. This will allow the regulator and government to work with the sector to develop and maintain requirements as needed.

Fees and charging

To facilitate the proposals set out in this consultation the regulator will need to be suitably funded to carry out its work effectively. Legislation will therefore need to provide for matters related to fees and charging.

As part of a sustainable funding model, we consider that the regulator will likely need to charge fees for some of the services it provides. This may, for example, include fees associated with the registration of FRAs and maintenance of a central register, activities to support compliance, and related administrative costs.

Consultation questions

Fees and charging

Question 60

In principle, to what extent do you agree or disagree with the introduction of proportionate fees or charges for the activities outlined in this section?

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 61

Do you wish to share any feedback on the current and/or potential impact of such fees on your organisation?

• [Free Text Response]

Enforcement and sanctions

To deliver a competent FRA profession, enforcement is needed both to provide assurance that those in the profession are complying with their legal duties and to identify those who breach those duties and deliver appropriate sanctions.

It will be crucial to ensure that we support positive interaction between the public, RPs, FRAs and other enforcing authorities. We intend that there should be a simple mechanism for reporting concerns, and the regulator should be able to work with all interested parties to resolve conflict and identify and disseminate good practice, to promote better fire safety outcomes.

Under the FSO at present, all relevant persons have a duty to ensure that a fire risk assessment has been produced to a “suitable and sufficient” standard. Enforcing bodies, such as local fire and rescue authorities, have inspection regimes for FSO premises, and they may also review the fire risk assessment when a fire has occurred, or when a complaint has been raised. Individuals offering their services as FRAs have been successfully prosecuted under this legislation, which has resulted in sanctions ranging from fines to custodial sentences. We believe that these sanctions and offences remain appropriate for FRAs under a regulated profession for actions which could endanger the lives of relevant people on the premises they assess.

To effectively regulate and protect the integrity of the FRA profession, we need to ensure that the regulator has the additional powers to sanction FRAs for breaches of professional competency and codes of conduct. The government expects that this will include for instance those who use false credentials and those who practice at a level not appropriate to their certification and qualifications.

We will work with fire sector professionals, enforcing authorities and other interested parties as we develop a detailed approach to enforcement, sanctions and appeals, considering options for application of both criminal and civil penalties.

As set out in the Single Construction Regulator Prospectus, local authorities and fire and rescue authorities will need to continue to work closely with the BSR and the future regulator when established, including to enforce the Regulatory Reform (Fire Safety) Order 2005 and Housing Act 2004. We will work closely with relevant partners as we consider the future operation of a regulator.

Consultation questions

Existing offences and sanctions under the FSO

Question 62

To what extent do you agree or disagree that existing offences under the FSO (i.e., failure to undertake a “suitable and sufficient” fire risk assessment under Article 9) remain appropriate for the prosecution of regulated FRAs?

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 63

To what extent do you agree or disagree that existing FSO enforcing authorities (e.g., local fire & rescue authorities) should retain responsibility for FSO Article 9, including the sanctioning of regulated FRAs for alleged breaches of that duty?

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 64

We would welcome any further thoughts on the reasons for your answers above by providing a response in the text box below.

• [Free Text Response]

New offences and sanctions for the regulation of FRAs

Question 65

To what extent do you agree or disagree that a regulator should have the power to request information and documentation from FRAs to assist in the fulfilment of its duties?

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 66

To what extent do you agree or disagree that a regulator should have the power to suspend registration on an interim basis where serious breaches are under investigation?

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 67

To what extent do you agree or disagree that the following should be considered an offence under a regulated FRA profession: ‘Failure to meet required competency requirements, including offering services at a level not appropriate to certification level’.

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 68

To what extent do you agree or disagree that the following should be considered an offence under a regulated FRA profession: ‘Impersonating an appropriately certified FRA’.

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 69

To what extent do you agree or disagree that the following should be considered an offence under a regulated FRA profession: ‘Breaches of professional codes of conduct (including failures to declare conflicts of interest)’.

• strongly agree
• tend to agree
• neither agree nor disagree
• tend to disagree
• strongly disagree
• don’t know

Question 70

Should other offences be considered, and why?

• yes – [Free Text Response]
• no – [Free Text Response]

Question 71

We would welcome any further thoughts on the reasons for your answers above on new offences by providing a response in the text box below.

• [Free Text Response]

Question 72

To what extent do you agree or disagree that appropriate sanctions for offences under a regulated profession should include (tick all that apply):

• a summary fine
• variation of registration details
• suspension from the register of competent persons
• removal from the register of competent persons
• other, please give details [Free Text Response]

Question 73

We would welcome any further thoughts on the reasons for your answers above on new sanctions by providing a response in the text box below.

• [Free Text Response]

Implementation

In this consultation we have shared our vision for a regulated FRA profession, and the powers that a regulator will need to effectively regulate that profession. However, we must also ensure that this regulation is implemented in a way that facilitates improved FRA competency while also ensuring the creation of a sustainable workforce. We do not underestimate the potential challenges in expanding the existing workforce to meet future regulatory requirements. Ensuring there is a sufficient, capable and competent workforce is essential to enable the development of flats and non-residential buildings. We recognise that failing to do so could have significant impacts on people’s ability to live in blocks of flats, run businesses, and build new homes.

We therefore seek views in this section to help us to understand the existing capacity and capability requirements of the sector, and we will use that evidence to work with stakeholders to develop a sustainable plan for implementation.

Understanding sector capacity

To develop a robust approach to delivering a regulated profession we need to build a better understanding of the current size of the sector and how it operates.

The Home Office previously held responsibility for fire safety policy and published the results of a 2023 survey of 1,272 FRAs working in England FRAs in September 2024. This survey aimed to understand competency, capacity and experiences of the sector and the key findings in relation to capacity indicated the following:

• 53% conducted fire risk assessments on fewer than 50 buildings per year
• 22% undertook fire risk assessments on no more than 10 buildings per year
• 31% assessed more than 100 buildings per year
• 48% spent between 8 and 30 hours a week conducting assessments
• FRAs assess most building types, but as the complexity of the building increases, the proportion of FRAs who assess them decreases
• most FRAs (88%) assess buildings that are 11 metres in height and under, with only 34% conducting assessments on buildings that are above 18 metres

The findings of the survey represent the first piece of published research conducted on the FRA sector and as such is informative, but not sufficient to draw representative conclusions on the size of the sector and how it operates. We are now seeking information to further support the development of specific measures to roll out competency requirements in the FRA profession.

Consultation questions

FRAs and other fire safety professionals conducting fire risk assessments

Question 74

Are you in full time or part time employment?

• full time
• part time

Question 75

If you work part time, how many hours per week (on average) do you work?

• [Free Text Response]

Question 76

How many assessments do you personally conduct on average in a year? (please select one)

• 1 to 5 per year
• 6 to 10 per year
• 11 to 25 per year
• 26 to 50 per year
• 51 to 100 per year
• 101 to 250 per year
• more than 250 per year

Question 77

How many hours does it typically take to complete one fire risk assessment including associated administration (and average travel time)? Please specify the building types you are referring to.

• [Free Text Response]

Question 78

How many hours do you spend (on average) per week specifically on fire risk assessments and associated administration?

• Less than 4 hours
• 4-8 hours
• 8-15 hours
• 16-30 hours
• 31 hours or more

Question 79

Do you personally provide additional fire safety services – Approximately what proportion of your work hours do you spend on each (tick all that apply)

• Fire engineering – [Free Text Response]
• Fire safety training – [Free Text Response]
• Passive fire safety installation and/or maintenance – [Free Text Response]
• Active fire safety installation and/or maintenance – [Free Text Response]
• Fire door inspections – [Free Text Response]
• Personal emergency evacuation plans – [Free Text Response]
• Other – [Free Text Response]
• No other additional fire safety services – [Free Text Response]

Responsible Persons, Leaseholders, Developers

Question 80

If you were unable to employ a professional FRA due to a lack of availability, how might that impact you as an RP, a leaseholder, a developer or another interested party?

• [Free Text Response]

Question 81

If you were unable to seek the services of a professional FRA due to a lack of availability, and if the option were available, would you conduct the fire risk assessment yourself?

• yes (using government guidance)
• no
• don’t know

Implementation scenarios

As set out above, the current capacity and future requirements of the FRA sector are key variables where we are seeking to gather further evidence.

Informed by the findings of this consultation, we will need to assess whether it is preferable to introduce mandatory competency requirements at once (after sector capacity has been developed), or whether phased implementation, such as introducing competency requirements for higher priority premises earlier, is preferable. In considering this issue, we have identified several illustrative scenarios to help demonstrate (subject to the findings of this consultation) what potential approaches could look like. These scenarios could apply if RPs were still able to conduct their own fire risk assessments, and if assessments for some/all premises were restricted to certified FRAs.

Scenario 1:  Implementation of mandatory competency requirements for all FRAs conducting a fire risk assessment (no phasing).

This approach would minimise confusion for an RP about whether their building falls in scope of a specific phase and therefore the risk that FRAs are unaware of at which point their new legal duties must apply.  This approach would also ensure improved fire safety for everyone at once rather than a phased approach, where some people would have to wait longer than others for improved fire safety outcomes. However, ahead of regulation coming into force for this scenario, all FRAs would need to meet the criteria for future regulation, including holding the appropriate qualifications, certification and registration, which would require a longer period of transition to avoid placing pressure on capacity and capability in the workforce.

Scenario 2: Phased introduction of competency requirements based on competence level of the FRA.

Competency could be defined in terms such as foundation, intermediate and advanced (as with BS 8674), which match the general levels of complexity that buildings present; low, medium and high. Implementation could be based on the competence level of the FRA - beginning with requiring the registration of FRAs with an advanced level of competence and therefore most likely to be assessing buildings attracting the highest level of complexity. This would then be followed by the intermediate and foundation levels of competence.

Scenario 3: Phased introduction of competency requirements based on the level of complexity associated with the building.

Best estimates suggest that there are around 3 million buildings which fall in scope of the FSO and therefore subject to the requirement in FSO Article 9 for the RP to provide a suitable and sufficient fire risk assessment. As an alternative to option 2 above, the statutory requirements could be phased using an approach where buildings are categorised according to the level of potential risk that they present to the life safety of those using the premises.  This could then mean that FRAs working on the highest risk premises are required to register first and demonstrate that they have the competence to work on such premises, followed by phased registration of those working on premises with decreased levels of potential risk. This option could be implemented in multiple phases to reflect varying levels of risk.

The final decision of whether a phased or ‘all at once’ implementation is more appropriate, will also clearly be influenced by and need to take account of the relationship with wider work on fire safety professions including the regulation of fire engineers and the delivery of all recommendations from the final report of the Grenfell Tower Inquiry.

Consultation questions

Implementation scenarios

Question 82

If a phased approach to introducing competency requirements were undertaken, which of the following, if any, of the indicative scenarios above do you think would work best?

• 1- Implementation of mandatory competency requirements for all FRAs
• 2- Phased introduction based on competence level
• 3- Phased introduction based on premises risk
• other – free text response
• don’t know

Question 83

Besides current and future expected capacity in the sector and the number of buildings in scope of fire risk assessments, are there other factors that you think should be considered in developing the implementation plan?

• [Free Text Response]

Final Questions

Question 84

Do you have any further information you wish to provide in relation to any of the proposals contained in this consultation, including their implications on individuals with protected characteristics or in relation to the Environmental principles policy statement?

• [Free Text Response]

Question 85

Are you content to be contacted further by the Ministry of Housing, Communities and Local Government?

• yes, either to clarify answers to the consultation, to be updated on progress regarding this consultation, OR be invited to participate in further research.
• yes, but only to clarify answers provided to this consultation
• no, I prefer not to be re-contacted following this consultation.

Question 86

If you have given permission to be contacted further, please provide your email address. We will only use it for the purposes for which you have given permission).

• [Free Text Response]

Glossary

Term	Definition
Accreditation	Accreditation means the assessment of the competence and impartiality of an organisation and the compliance of their work to nationally and internationally recognised standards or schemes.[footnote 11] In this consultation, it means the assessment of an organisation to allow it to certify the competence of FRAs or organisations.
Accountable Person	An “accountable person” for a higher-risk building is defined in Part 4, Section 72 of the Building Safety Act 2022 as: (a)a person who holds a legal estate in possession in any part of the common parts (subject to subsection (2)), or (b)a person who does not hold a legal estate in any part of the building but who is under a relevant repairing obligation in relation to any part of the common parts.
Article 5(3) and (4) Fire Safety Order	Article 5(3) and (4) Fire Safety Order provide that: 3) Any duty imposed by articles 8 to 22 or by regulations made under article 24 on the responsible person in respect of premises shall also be imposed on every person, other than the responsible person referred to in paragraphs (1) and (2), who has, to any extent, control of those premises so far as the requirements relate to matters within his control. (4) Where a person has, by virtue of any contract or tenancy, an obligation of any extent in relation to— (a)the maintenance or repair of any premises, including anything in or on premises; or (b)the safety of any premises, that person is to be treated, for the purposes of paragraph (3), as being a person who has control of the premises to the extent that his obligation so extends
Article 9 Fire Safety Order	Article 9 (1) provides that the RP must make a suitable and sufficient assessment of the risks (i.e. a fire risk assessment) to which relevant persons are exposed for the purpose of identifying the general fire precautions he needs to take to comply with the requirements and prohibitions imposed on him by or under this Order.
British Standard BS 8674	BS 8674 is a British Standard published by the British Standards Institution that sets out a framework for assessing and assuring the competence of individual FRAs operating in the built environment.
Certification	Certification is the third-party confirmation via audit of an organisation or individual’s systems or products.[2] In this consultation, it means FRAs or organisations demonstrating their conformity with a set of criteria to be certified.
Competence	The combination of skills, knowledge experience and behaviours that a person/organisation has and their ability to apply them to perform a task safely.
Enforcing Authorities	Fire and rescue authorities and other enforcing bodies listed in Article 25 of the FSO, who have powers to audit compliance with fire safety duties and a range of enforcement tools in case of a breach.
Fire Engineer	While there is currently no legal definition of a fire engineer, the Fire Engineers Advisory Panel’s Authoritative Statement sets out that fire engineers are professionals who develop and deliver engineering solutions that protect people and mitigate harm to the built and natural environment in the event of fire. The Grenfell Tower Inquiry made a number of recommendations concerning reform of the fire engineering profession. Further information on this and the work of the Fire Engineers Advisory Panel is available.
Fire Risk Assessor (FRA)	There is no definition of an “FRA” in existing legislation. Though the role of FRA has been defined in various standards and guidance including BS4422: 2024 Fire Vocabulary and BS8674 (Framework for competence of individual fire risk assessors). An FRA can refer to anyone who assists in the fulfilment of the RP’s duties under Article 9 of the Fire Safety Order.
Fire Safety Strategy	There is no definition of a fire safety strategy in existing legislation of guidance. There are also not requirements for a building to have a fire safety strategy. There are different definitions of a fire safety strategy used in industry. The Grenfell Tower Inquiry report set out that a fire safety strategy for a building should describe its structure and the various fire protection systems it contains and set out how they work together to ensure the safety of the occupants in the event of a fire.[footnote 12] The Fire Engineers Advisory Panel’s Authoritative Statement provides a view on what fire safety strategies should include.
Qualifications	The process of passing examinations, or the official completion of a course, to demonstrate that one has a specified level of knowledge and/or skills in a particular profession or activity. Those qualifications regulated by Ofqual (in England) to ensure   a consistent high-quality standard are known as “regulated qualifications.”
Regulatory Reform (Fire Safety) Order 2005 or Fire Safety Order	The Regulatory Reform (Fire Safety) Order 2005 (FSO) is the principal legislation covering fire safety in non-domestic premises in England and Wales.
Responsible Person	Article 3 of the Fire Safety Order defines the Responsible Person as: (a) in relation to a workplace, the employer, if the workplace is to any extent under his control; (b) in relation to any premises not falling within paragraph (a)— (i) the person who has control of the premises (as occupier or otherwise) in connection with the carrying on by him of a trade, business or other undertaking (for profit or not); or (ii) the owner, where the person in control of the premises does not have control in connection with the carrying on by that person of a trade, business or other undertaking.
SKEB	SKEB refers to skills, knowledge, experience and behaviour.
United Kingdom Accreditation Service (UKAS)	UKAS is the National Accreditation Body for the United Kingdom. UKAS are appointed by government, to assess and accredit organisations that provide services including certification, testing, inspection, calibration, validation and verification.

About this consultation

This consultation document and consultation process have been planned to adhere to the Consultation Principles issued by the Cabinet Office.

Representative groups are asked to give a summary of the people and organisations they represent, and where relevant who else they have consulted in reaching their conclusions when they respond.

Information provided in response to this consultation may be published or disclosed in accordance with the access to information regimes (these are primarily the Freedom of Information Act 2000 (FOIA), the Environmental Information Regulations 2004 and UK data protection legislation.  In certain circumstances this may therefore include personal data when required by law.

If you want the information that you provide to be treated as confidential, please be aware that, as a public authority, the department is bound by the information access regimes and may therefore be obliged to disclose all or some of the information you provide. In view of this it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the department.

The Ministry of Housing, Communities and Local Government will at all times process your personal data in accordance with UK data protection legislation and in the majority of circumstances this will mean that your personal data will not be disclosed to third parties. A full privacy notice is included below.

Individual responses will not be acknowledged unless specifically requested.

Your opinions are valuable to us. Thank you for taking the time to read this document and respond.

Are you satisfied that this consultation has followed the Consultation Principles?  If not or you have any other observations about how we can improve the process please contact us via the complaints procedure.

Personal data

The following is to explain your rights and give you the information you are entitled to under UK data protection legislation.

Note that this section only refers to personal data. Personal data may include your name, contact details, ethnicity, gender, and age and any other information that relates to you or another identified or identifiable individual. It does not apply to the views expressed in your consultation response, unless those views contain identifiable personal data.

1. The identity of the data controller and contact details of our Data Protection Officer    

The Ministry of Housing, Communities and Local Government (MHCLG) is the data controller. The Data Protection Officer can be contacted at dataprotection@communities.gov.uk or by writing to the following address:

Data Protection Officer,
Ministry of Housing, Communities and Local Government,
Fry Building,
2 Marsham Street,
London
SW1P 4DF

2. Why we are collecting your personal data  

Your personal data, such as your email address, ethnicity, gender and age, is being collected as an essential part of the consultation process, so that we can contact you regarding your response and for statistical purposes. We may also use it to contact you about related matters.

We will collect your IP address if you complete a consultation online. We may use this to ensure that each person only completes a survey once. We will not use this data for any other purpose.

Sensitive types of personal data

Please do not share special category personal data or criminal offence data  if we have not asked for this unless absolutely necessary for the purposes of your consultation response. By ‘special category personal data’, we mean information about a living individual’s:

• race
• ethnic origin
• political opinions
• religious or philosophical beliefs
• trade union membership
• genetics
• biometrics 
• health (including disability-related information)
• sex life
• sexual orientation

By ‘criminal offence data’, we mean information relating to a living individual’s criminal convictions or offences or related security measures.

3. Our lawful basis for processing your personal data

The collection of your personal data is lawful under article 6(1)(e) of the UK General Data Protection Regulation as it is necessary for the performance by MHCLG of a task in the public interest/in the exercise of official authority vested in the data controller. Section 8(d) of the Data Protection Act 2018 states that this will include processing of personal data that is necessary for the exercise of a function of the Crown, a Minister of the Crown or a government department i.e. in this case a consultation.

Where necessary for the purposes of this consultation, our lawful basis for the processing of any special category personal data or ‘criminal offence’ data (terms explained under ‘Sensitive Types of Data’) which you submit in response to this consultation is as follows. The relevant lawful basis for the processing of special category personal data is Article 9(2)(g) UK GDPR (‘substantial public interest’), and Schedule 1 paragraph 6 of the Data Protection Act 2018 (‘statutory etc and government purposes’). The relevant lawful basis in relation to personal data relating to criminal convictions and offences data is likewise provided by Schedule 1 paragraph 6 of the Data Protection Act 2018. Such special category personal data will be used for statistical and analytical purposes only, and not to identify individual respondents.

4. With whom we will be sharing your personal data

MHCLG will appoint the Department for Science, Innovation and Technology as a ‘data processor’, acting on behalf of the department and under our instruction, to help analyse the responses to this consultation.  Where we do we will ensure that the processing of your personal data remains in strict accordance with the requirements of the data protection legislation.

MHCLG will take reasonable and proportionate steps to remove personal data from the consultation responses before using an Artificial Intelligence (AI) tool called Consult AI. The AI tool processes data securely and does not copy or share data. The data will only be accessed and used by those authorised to do so

The AI tool identifies themes present in the responses. The draft themes are reviewed and agreed by a policy team before the tool then maps responses to the themes to be used by policy teams to analyse the consultation. MHCLG will take steps to check for accuracy and identify and reduce bias. Your data will not be used to train the AI models.

5. For how long we will keep your personal data, or criteria used to determine the retention period.

Your personal data will be held for three years from the closure of the consultation, unless we identify that its continued retention is unnecessary before that point.

6. Your rights, e.g. access, rectification, restriction, objection

The data we are collecting is your personal data, and you have considerable say over what happens to it. You have the right:

a. to see what data we have about you

b. to ask us to stop using your data, but keep it on record

c. to ask to have your data corrected if it is incorrect or incomplete

d. to object to our use of your personal data in certain circumstances

e. to lodge a complaint with the independent Information Commissioner (ICO) if you think we are not handling your data fairly or in accordance with the law.  You can contact the ICO at https://ico.org.uk/, or telephone 0303 123 1113.

Please contact us at the following address if you wish to exercise the rights listed above, except the right to lodge a complaint with the ICO: dataprotection@communities.gov.uk or

Knowledge and Information Access Team,
Ministry of Housing, Communities and Local Government,
Fry Building,
2 Marsham Street,
London
SW1P 4DF

7. Your personal data will not be sent overseas.

8. Your personal data will not be used for any automated decision making.

9. Your personal data will be stored in a secure government IT system.

We use a third-party system, Citizen Space, to collect consultation responses. In the first instance your personal data will be stored on their secure UK-based server. Your personal data will be transferred to our secure government IT system as soon as possible, and it will be stored there for three years before it is deleted.

1. Independent Review of Building Regulations and Fire Safety: final report - GOV.UK. ↩ ↩²

2. Single construction regulator prospectus - GOV.UK. ↩

3. The Regulatory Reform (Fire Safety) Order 2005, article 6 ↩

4. The Regulatory Reform (Fire Safety) Order 2005, article 3 ↩

5. The Regulatory Reform (Fire Safety) Order 2005 ↩

6. Excluding hospitals, care homes, secure residential institutions (prisons), hotels and military barracks. ↩

7. Fire risk assessors in England: competency and capacity - GOV.UK. ↩

8. https://www.legislation.gov.uk/uksi/2005/1541/article/9 ↩

9. A building at least 18 metres in height or has at least 7 storeys and contains at least 2 residential units. Excluding buildings that comprise entirely of: a residential care home, a hospital, a secure residential institution, a hotel, a military barracks. ↩

10. What are apprenticeships? Everything you need to know and how you can apply – The Education Hub. ↩

11. Accreditation vs Certification: What’s the difference? UKAS ↩

12. Grenfell Tower Inquiry, Phase II, September 2024. ↩