The Review Obligation

Why Your Fire Risk Assessment Needs Reviewing — Even If Nothing Has Changed

One of the most dangerous assumption in fire safety is that last year's assessment is still valid. For property managers, the review obligation is a legal requirement with real teeth.

By Fletcher Risk | Chester · Liverpool · Manchester · Warrington · North Wales | 12 March 2026

There is a particular kind of false confidence that comes from having done something once. A fire risk assessment is commissioned, a competent-looking document arrives, a review date is noted somewhere in the system, and the matter is filed. The building continues to be managed. The years pass. The document sits. This is is the dominant pattern of fire risk assessment management in the UK. It is also one of the most significant sources of compliance risk that professional property managers face, as a fire risk assessment is not a one-time certification. It is a live document, a snapshot of a building's fire safety status at a specific point in time, that becomes progressively less accurate as time passes and conditions change. The obligation to review it is not a recommendation, but a legal requirement, and the failure to comply with it carries the same consequences as the failure to have an assessment in the first place.

What the Law Actually Requires

The Regulatory Reform (Fire Safety) Order 2005 requires, in Article 9, that the responsible person review their fire risk assessment regularly and where there is reason to suspect that it is no longer valid, or where there has been a significant change in the matters to which it relates. The Order does not specify a fixed review interval, instead it requires review where there is reason to suspect the assessment is no longer valid, and it leaves the definition of 'regularly' to be determined by reference to the risk profile of the premises.

In practice, the industry standard, codified in PAS 79:2020 (non-domestic premises) and BS 9792:2025 (Residential premises), the British Standards for fire risk assessments, is that assessments should be reviewed at least annually for higher-risk premises and at least every five years for lower-risk premises. A competent assessor will specify the appropriate review interval in the assessment itself, based on the specific risk profile of the building and the nature of any ongoing changes.

The Building Safety Act 2022 has added a further layer for higher-risk residential buildings, those of 18 metres or more, or seven or more storeys, where the building safety case must be kept continuously up to date and where the Building Safety Regulator has powers to inspect and require remediation. For managing agents with buildings in this category, the concept of a periodic review is insufficient. Safety management must be continuous.

Triggers for an Immediate Review

Beyond the calendar-based review obligation, the Fire Safety Order requires an immediate review, irrespective of when the last review was conducted, whenever certain conditions are met:

Any material alteration to the building's structure, layout or fabric.
Changes to the use of the building or any part of it.
Changes in the number, type or vulnerability of occupants.
Introduction, removal or significant modification of fire safety systems.
A fire or fire-related incident in the building, however minor.
Identification of a significant deficiency during a fire safety inspection.
Receipt of an enforcement notice or notification from a fire authority.
Changes to relevant legislation or guidance that affect the building's compliance.
A significant change in the building's maintenance or management arrangements.

The Problem with Outdated Assessments

An outdated fire risk assessment does not merely fail to protect its holder legally, it actively misleads them. A managing agent who believes their building is compliant on the basis of a three-year-old assessment, conducted before a new kitchen was installed on the third floor, before the ground-floor retail unit changed from a bookshop to a restaurant, and before a refurbishment removed the fire-resisting lining from a stairwell wall, is not in a position of safety. They are in a position of uninformed risk.

The practical consequences of this are visible in enforcement action. Fire authorities conducting inspections of commercial and residential premises regularly encounter responsible persons who are genuinely surprised to receive enforcement notices, not because they have been negligent in any conscious sense, but because their assessment did not reflect the building they were actually managing. The fire safety landscape had changed; the document had not.

The position is made worse, by the existence of an outdated assessment. A responsible person who has no fire risk assessment at all is clearly in breach of the Order. A responsible person who has one that is manifestly out of date is in a similar position, but may have had reasonable grounds to commission a review earlier and failed to act on them. In enforcement terms, the latter situation can be treated as an aggravating factor.

What Review Actually Means

A review of a fire risk assessment is not the same as a new assessment, though in some cases, where the building has changed significantly, or where the original assessment was of poor quality, a full reassessment is the only sensible course. A review involves the assessor returning to the building, comparing current conditions against the findings of the previous assessment, and updating the document to reflect any changes.

A desk-based review, where the assessor reads the existing document and updates it without visiting the building, is generally insufficient unless the changes since the last assessment are genuinely trivial and the assessor can satisfy themselves of this without a physical inspection. Property managers who are offered a review conducted remotely, or at a price that implies no site visit, should approach such an offer with scepticism.

The reviewed assessment should carry a new date, a new review schedule, and, where the findings have changed, updated action points. Any actions from the previous assessment that remain outstanding should be noted, with their priority reconsidered in light of current conditions. An assessment that has been 'reviewed' but that carries the same action list as its predecessor, with no acknowledgement of whether previous recommendations have been implemented, is not a reliable document.

Building a Review Into Your Management System

The most effective way to meet the review obligation consistently is to build it into the standard management cycle for every property in the portfolio, rather than relying on individual recollection or ad hoc prompting. Every fire risk assessment should carry a clear review date, that date should be entered into the management system as a hard deadline, and the system should generate a reminder, ideally at 90 days and again at 30 days, before the review falls due.

Equally important is a mechanism for capturing the change-triggers identified above. When a refurbishment is planned, when a tenancy changes, when a fire safety system is modified, these events should automatically prompt a review of the fire risk assessment, irrespective of where the calendar review date falls. Managing agents who treat fire safety documentation as a parallel track to property management, rather than an integral part of it, will inevitably find that the two fall out of alignment.

For property managers overseeing larger portfolios, it is also worth considering whether a single provider, one who knows the buildings, understands the local regulatory landscape and can offer consistent quality across the portfolio, is preferable to a fragmented approach using multiple assessors. Consistency of methodology makes comparison between assessments more meaningful, makes gaps easier to identify, and makes it easier to demonstrate a coherent compliance framework to any enforcement authority that comes calling.

The Cost of Delay

There is a natural human tendency to defer compliance activity that is not immediately pressing, to wait until the review date arrives, or until a change of tenancy prompts a review, rather than acting proactively. In fire safety, this tendency has a cost that is not always visible until it becomes acute.

The cost of a timely, competent fire risk assessment review is modest relative to the cost of the alternatives: an enforcement notice requiring immediate works, a prosecution following an incident, a civil claim from an injured occupant, or, most gravely, a fire in a building whose safety status had been allowed to drift from the document that was supposed to describe it. Professional property managers who take their obligations seriously do not wait to be compelled. They review, they update, and they act.

Book Your Fire Risk Assessment Review

If your current fire risk assessment is more than 12 months old, or if your building has changed since it was last assessed, now is the time to act. Fletcher Risk provides timely, thorough fire risk assessment reviews for property managers across the North West and North Wales. Please contact us today.

Disclaimer

The information contained in this article is intended for general guidance only and does not constitute legal, regulatory or professional advice. Whilst Fletcher Risk has taken reasonable care to ensure the accuracy of the information provided, the legal obligations governing fire risk assessment reviews are subject to interpretation and may vary depending on the specific circumstances of individual premises, their risk profile and applicable legislation. The review intervals and triggers referenced in this article reflect general industry practice and guidance current at the time of publication. They should not be treated as a substitute for the advice of a qualified and competent fire risk assessor, who will determine the appropriate review frequency for your specific premises. Fletcher Risk accepts no liability for any loss, damage or regulatory sanction arising from reliance on the contents of this article. Responsible persons should always seek advice specific to their premises and circumstances. References to legislation, British Standards and regulatory guidance should be verified against current editions before being acted upon.

Tim Fletcher12 March 2026