When does your fire risk assessment need to be reviewed? What the law actually says.
The annual fire risk assessment review has become so embedded in industry practice that most managing agents treat it as the legal standard. It is not. The Regulatory Reform (Fire Safety) Order 2005 sets a more demanding and more immediate requirement — and understanding the difference matters for anyone managing a portfolio of residential buildings.
What the Fire Safety Order actually says
Article 9 of the FSO requires the Responsible Person to make a suitable and sufficient assessment of the risks to which relevant persons are exposed. Article 9(3) requires that assessment to be reviewed regularly and whenever there is reason to suspect it is no longer valid or there has been a significant change in the matters to which it relates.
That second limb is the important one. It is not tied to a calendar. It fires whenever the assessment is no longer valid — which can happen at any point, entirely independently of when the last review took place.
What triggers a review
A significant change to the building's layout or fabric — a refurbishment, a new partition wall, a change to the means of escape. A change in occupancy, including new tenants whose presence changes the risk profile. A change in how the building is used. A fire, near-miss or unwanted alarm signal that suggests the existing arrangements are not performing as expected. A change in the relevant legislation or guidance. A change in the contractors or maintenance arrangements that affect the systems the FRA relies on.
None of those require waiting for the annual date. The legal duty to review is triggered by the change, not by the calendar.
Why this matters in practice
A managed residential portfolio is not a static environment. Buildings change constantly — layouts are altered, flat conversions happen, new managing arrangements are put in place, building fabric is modified by contractors who may not understand the fire safety implications of what they are doing. An FRA that accurately described the building 18 months ago may not describe the building today.
In 2026, enforcement authorities and insurers are increasingly focused on whether the FRA reflects the building as it actually operates — not whether a review was carried out on schedule. An assessment that pre-dates a significant change is not a valid assessment for the purposes of the FSO, regardless of how recently it was written.
The "suitable and sufficient" test
The FRA must also be suitable and sufficient — a standard that applies not just to when it was produced but to the quality and depth of the assessment itself. An FRA that identifies hazards without setting out a clear programme for managing and reviewing them is increasingly scrutinised. The record of review, of actions taken, and of the current compliance position is as important as the assessment document itself.
What good practice looks like
Managing agents with well-run compliance programmes track not just when FRAs were last reviewed but what has changed in each building since the last review — and whether any of those changes would trigger a reassessment under the FSO standard. That tracking is not an onerous exercise if it is built into the compliance management process. It becomes onerous when it is done retrospectively, under pressure, after something has gone wrong.
If you have buildings that have changed since your last FRA and no review has been triggered, that is worth addressing. If you are not sure which of your buildings fall into that category, that is worth finding out.
Get in touch: s.coogan@omnifire.co.uk