High-Rise Residential and HMO Fire Safety

Start with what the Fire Safety (England) Regulations 2022 actually require because the bands are frequently misread. Every building containing two or more sets of domestic premises, at any height, must give residents fire safety instructions appropriate to the evacuation strategy, covering how to report a fire and what to do if one occurs, plus information on the importance of fire doors. Above 11 metres the responsible person must check all fire doors in the common parts at least every three months and must use best endeavours to check every flat entrance door at least annually, including the self-closing devices, keeping records including of refused access. At 18 metres or seven storeys the duties step up again. You must provide the fire and rescue service with electronic building floor plans and a single-page block plan, install and maintain a secure information box holding hard copies and responsible person contact details, provide information on the design and materials of the external wall system including risk levels and mitigations and notify the service of material changes, carry out monthly checks of firefighting lifts, evacuation lifts and other key firefighting equipment with any fault that cannot be fixed in 24 hours reported to the fire and rescue service, record the results and make them available to residents and install wayfinding signage visible in low light or smoke identifying flat and floor numbers in stairwells. Our fire door surveys are structured around the three month and twelve month intervals so the record set matches the duty rather than approximating it.

Part 4 of the Building Safety Act 2022 applies to buildings of at least 18 metres or seven storeys with at least two residential units. The duties are registration with the Building Safety Regulator before occupation, identification of the accountable persons and the principal accountable person, assessment and management of the building safety risks of fire spread and structural failure, preparation of a safety case and submission of a safety case report, application for and compliance with a building assessment certificate when directed, mandatory occurrence reporting, maintenance of the golden thread of building information and a residents' engagement strategy with a complaints procedure. Residents carry their own duties under sections 95 and 96. One point causes constant confusion. Care homes and hospitals fall within Part 3 for design and construction but are excluded from the Part 4 in-occupation regime. The higher-risk building definition was reviewed and left unchanged, confirmed on 17 December 2025.

Stay put is not a policy you choose. It is a conclusion you draw. It holds only where each flat is a fire resisting compartment and fire will not spread beyond the flat of origin within the design period. Where compartmentation, the external wall system, fire doors or the smoke control system are known to be defective, the fire risk assessment must move the building to simultaneous evacuation. That change is not a line in a report. It requires a means of raising the alarm throughout the building, which means a common fire alarm system or, as a short-term interim measure only, a waking watch. Our waking watch and interim measures work is built around replacing that cost with a permanent alarm as quickly as the funding and the programme allow.

Changing to simultaneous evacuation above 11 metres now also triggers the Fire Safety (Residential Evacuation Plans) (England) Regulations 2025, SI 2025/797, in force since 6 April 2026. They apply to all high-rise residential buildings at 18 metres or seven storeys with two or more domestic units and to multi-residential buildings over 11 metres operating a simultaneous evacuation strategy. The responsible person must use reasonable efforts to identify relevant residents, meaning those for whom the building is their only or principal residence and who need assistance to evacuate because of a physical or cognitive impairment. You must offer each of them a person-centred fire risk assessment, record the agreed approach in a written residential emergency evacuation statement and give the resident a copy, share prescribed information with the fire and rescue authority only with the resident's explicit consent, install and maintain a secure information box if the authority asks for hard-copy sharing and prepare a building emergency evacuation plan reviewed annually or on change. The statements and the person-centred assessments are reviewed annually too. Note the statutory term is emergency evacuation statement. Residential PEEP is sector shorthand, not the language of the regulations. In practice this is a data, consent and resident engagement exercise as much as a fire safety one.

For shared housing and HMOs the benchmark used by councils and fire and rescue services remains the LACORS housing fire safety guidance of 2008, now maintained by the National Fire Chiefs Council. It is non-statutory. It gives risk-proportionate specifications for detection grade and category to BS 5839-6, fire doors, protected routes and escape windows and it bridges Housing Act enforcement inside the dwelling and Fire Safety Order enforcement in the common parts. Be honest about its age. LACORS predates the Fire Safety Act 2021, the Fire Safety (England) Regulations 2022, section 156 and the 2026 rating system and no replacement has been announced. We use it as the starting benchmark and say where a later duty overtakes it. Alongside it, the new Housing Health and Safety Rating System comes into force on 23 June 2026 under SI 2026/571, cutting 29 hazards to 21 with revised scoring, new baseline indicators and new statutory operating and enforcement guidance. Fire remains a hazard in its own right, a category 1 hazard creates a duty to act rather than a power and from 22 June 2026 councils can issue a £7,000 civil penalty for failing to fix serious hazards.

Lithium-ion charging deserves a paragraph of its own. Department for Transport guidance published on 1 February 2024, covering England, Scotland and Wales, sets the practical controls: locate charging and storage so a fire cannot block escape routes, provide automatic ventilation linked to fire detection, keep 45 centimetres of separation between charging battery packs, provide secure battery lockers to discourage charging inside flats, prohibit visibly damaged batteries and in workplaces consider prohibiting on-site charging altogether. It points to London Fire Brigade guidance note GN103 for detail. It is also explicit that introducing a new fire hazard requires the fire risk assessment to be reviewed by a competent person, not signed off by the premises manager alone.

One honest limitation. Article 9A of the Fire Safety Order, inserted by section 156(4) of the Building Safety Act 2022 to govern the competence of anyone appointed to assist with a fire risk assessment, has not been commenced. Competence remains a practical expectation backed by BS 8674:2025 and by third-party schemes rather than a commenced statutory test. We also do not publish figures for HMO civil penalties or rent repayment orders because the commonly quoted numbers predate amendments made by the Renters' Rights Act and we have not been able to verify current values against a primary source.