The Fire Safety Act 2021 clarified that the Regulatory Reform (Fire Safety) Order 2005 applies to the structure and external walls of multi-occupied residential buildings, including flat entrance doors. The intent was clear: close the gap exposed by Grenfell. The reality on the ground has been messier.
Failing #1 — Mistaking PAS 9980 for an external wall survey
PAS 9980 is a fire risk appraisal of external wall construction (FRAEW) — not a survey. We continue to see Type 1 FRAs being treated as Act-compliant when they specifically exclude external walls. If your FRA pre-dates the Act and hasn't been re-scoped, it almost certainly fails.
Failing #2 — Flat entrance door inspections recorded but not actioned
The Fire Safety (England) Regulations 2022 require annual flat entrance door inspections. Plenty of blocks now have the inspections — far fewer have a documented remediation pathway when defects are found. Inspections without action are evidence of negligence.
Failing #3 — Compartmentation assumptions in older blocks
Compartmentation is presumed by most FRAs but tested by very few. In converted Victorian and Edwardian buildings particularly, it is rarely as intact as the drawings suggest. A targeted intrusive sample is now the only defensible position.
What good looks like in 2026
- Type 3 or Type 4 FRA where the building risk warrants it.
- FRAEW (PAS 9980) where external wall construction is unverified.
- Quarterly common-parts and annual flat-entrance door inspections under FSER 2022.
- A 36-month remediation programme linking findings to capital plans.