What Fire Safety Documentation Must You Keep
Most fire safety enforcement notices we see are not issued for buildings with bad fire safety. They are issued for buildings with bad records of fire safety. The two are not the same thing in law, but the law treats them as if they were, and it has done so more strictly since October 2023 than at any point in the last twenty years.
Fire safety record-keeping is unloved and unglamorous, and it is also the single thing most likely to determine how a fire safety audit ends. A building with a working alarm but no test log, a building with a properly maintained set of fire doors but no inspection records, a building with a competent fire risk assessor but no name recorded against the assessment, will all be treated by an enforcing officer as buildings where the work probably has not been done. The presumption is unfavourable, and the burden of disproving it falls on the responsible person.
This is not a stylistic preference of the fire and rescue services. It is the position the law now takes, and it has hardened materially in recent years.
What changed in October 2023
On 1 October 2023, Section 156 of the Building Safety Act 2022 came into force in England and Wales, amending the Regulatory Reform (Fire Safety) Order 2005. The change was substantial. Three points matter most for documentation.
First, every responsible person must now record their fire risk assessment in full. Previously, only the significant findings had to be written down, and only in buildings with five or more employees or where licensing applied. That threshold is gone. A two-person office, a small HMO, a village hall, all must now hold a complete written assessment, regardless of size, sector or staffing.
Second, the responsible person must now record the name of the individual or organisation appointed to assist with the assessment. The competence of the assessor is no longer a private matter between client and consultant; it is a matter of record.
Third, the responsible person must now record the building's fire safety arrangements — the standing measures by which fire safety is actively managed: who tests what, on what cycle, against what standard, with what escalation when something fails. The arrangements are distinct from the assessment, and both must exist on paper.
Alongside these recording duties, Section 156 introduced an obligation to identify and cooperate with any other responsible persons sharing the building, exchanging contact details and recording who is responsible for what. And it raised the maximum fine under Article 32 of the Order, including for failure to produce records on request, from £1,000 to an unlimited amount. The change in tone is unmistakable. Documentation is no longer a soft expectation. It is a hard duty, and the consequences of failing it now scale with the seriousness of the failure.
What an enforcement officer actually asks for
The most useful way to think about fire safety documentation is to imagine the visit you are documenting against. A fire and rescue service inspector arrives, often unannounced, and works through a fairly predictable sequence. They will ask to see the fire risk assessment first. They will then ask to see the fire safety arrangements, which means the policies and procedures by which the building is run. They will ask for the most recent fire alarm and emergency lighting test records, expecting to see weekly entries for the alarm and monthly entries for the lighting. They will ask to see fire door inspection records. They will ask about staff training and evacuation drills. They will ask, increasingly often, to see evidence that the contractors who maintain the systems are themselves competent.
If any of these documents cannot be produced within a reasonable time, the inspector will record that they were not produced. They are not required to assume that the document exists somewhere and will be found later. The fire and rescue service's published statistics for England in the year to March 2025 show 51,020 audits carried out, with breaches of Article 9, the assessment article itself, among the most commonly cited. A significant proportion of those breaches are not failures to assess; they are failures to evidence the assessment when asked.
The documents themselves
The fire risk assessment
The assessment must be in writing, in full, and must include the name of the person or organisation who carried it out. Previous versions should be retained for the life of the building, because the history of how a building's fire safety has evolved is itself a defence: it shows that risks have been considered, addressed and reconsidered as the building has changed. An assessment dated 2017 with no subsequent review and no record of the reasons for not reviewing it is not an asset; it is a liability.
Action plans flowing from each assessment should be retained alongside it, with evidence of completion, sign-off and dates. An open action item from a five-year-old assessment is one of the easiest things for an enforcing officer to find and one of the hardest to explain.
The fire safety arrangements
This is the document most often missing from buildings we audit, because most responsible persons do not realise it is a separate requirement. The fire safety arrangements describe how fire safety is actually managed: roles and responsibilities, testing regimes, maintenance cycles, training programme, evacuation strategy, escalation routes when things go wrong. BS 9997 provides a useful framework for those who want one. A short, clear, building-specific document is more useful than a long generic one. What matters is that it exists, that it reflects how the building is run, and that it is reviewed when arrangements change.
Testing and maintenance records
The expected cadence is set by the relevant British Standards. Fire alarms under BS 5839 require weekly user tests and at least six-monthly servicing by a competent contractor. Emergency lighting under BS 5266 requires monthly short function tests and an annual full-duration test. Fire doors in higher-risk multi-occupied residential buildings have specific quarterly inspection requirements under the Fire Safety (England) Regulations 2022; in other buildings, six-monthly inspection is the established norm under BS 8214.
Each of these tests should generate a dated, signed entry in a logbook or its digital equivalent. The fire industry standard is the FIA fire safety logbook, which provides a structured format covering all of the above. Many responsible persons now use a digital alternative, which is fine provided the data is real, dated, attributable and retrievable. The format matters less than the integrity of the record.
Other systems
Service and maintenance records should be retained for every fire-related system in the building: sprinklers, dry and wet risers, smoke control and automatic opening vents, fire shutters, gas suppression, portable extinguishers where provided. Certificates of commissioning should be kept for the life of the system. Annual service certificates should be kept for at least the period during which the system remains in use, and ideally for the building's lifetime, because a system's history can become relevant after a fire in ways that are not foreseeable at the time of the service.
Training and drills
Training records should show what training was given, to whom, by whom, and when. Refresher cycles should be logged. Evacuation drills should be recorded with date, attendance, observations and any actions arising. In residential blocks with on-site staff, the same applies. Fire safety training records that exist only as an attendance sheet from a session two years ago do not satisfy a regime that expects ongoing competence.
Records of changes to the building
Any alteration that could affect fire safety should be documented and the assessment reviewed accordingly. Refurbishments, layout changes, new partitions, electrical works, changes to fire doors or compartmentation, the addition of new alarm zones, all should generate a paper trail consisting of drawings, certificates, contractor reports and a corresponding update to the fire risk assessment. The single most common cause of compartmentation failure we find on inspection is unrecorded historic works.
Enforcement correspondence
If the fire and rescue service has visited the building, every piece of correspondence should be retained indefinitely. Audit reports, advisory letters, enforcement and prohibition notices, and the evidence of how each required action was completed. These documents become part of the building's permanent fire safety history and are the first thing a future inspector will look for.
Contractor competence
Section 156 made the responsible person's duty to appoint competent assistance more explicit. In practice this means keeping evidence of the competence of every contractor doing fire safety work in the building: third-party certification (BAFE SP203 for alarm work, SP205 for fire risk assessment, SP101 for extinguishers, FIRAS for passive fire protection), professional registrations, insurance details, qualifications. Where possible, evidence should be refreshed annually rather than relied upon from the date of first appointment.
Information sharing in multi-occupied buildings
Where a building has more than one responsible person — a managing agent for the common parts, an employer in a leased office, a freeholder with retained obligations — Section 156 requires each of them to take reasonable steps to identify the others, share contact details, agree the boundaries of their respective duties, and record the arrangement in writing. When a responsible person changes, the outgoing person must hand over the relevant information to the incoming one. This applies to managing agent transitions, lease assignments and changes of building ownership. The records that prove this happened are themselves part of the documentation set.
The thing that goes wrong
Almost no one fails an audit because the documentation does not exist. People fail audits because the documentation cannot be found. A fire alarm log filed in a contractor's office in another county, an FRA on the previous building manager's laptop now wiped, a set of training records held only in a personal email account by an employee who left in 2023, are all examples we see regularly. The legal position is unforgiving: the responsible person cannot rely on documents they cannot produce. From the inspector's perspective, an unproducible document is an unproven document.
The practical answer is simple in principle and consistently neglected in practice. A single, central, up-to-date fire safety folder, accessible to whoever is on site when an inspector arrives, with an index, is the difference between a smooth audit and a difficult one. Whether the folder is digital or physical matters less than whether it is current and accessible. A digital folder is generally easier to keep current and easier to back up; a physical folder is easier to hand to an inspector. Many well-run buildings have both, with the digital version as the master copy.
How long to keep it
Fire risk assessments and their action plans should be kept for the life of the building. Testing logs and maintenance records should be retained for a minimum of three years, but in practice longer is better, because the value of the records compounds over time as patterns of recurring faults become visible. Enforcement correspondence should be kept indefinitely. Training records should be kept for the duration of employment and for a reasonable period afterwards. Records relating to alterations or building works should be kept for the life of the building, alongside the original construction documentation.
What good looks like
A well-documented building has, available within five minutes to whoever is on site: the current fire risk assessment, the fire safety arrangements document, the current logbook with weekly and monthly entries up to date, the most recent annual service certificates for each system, the current training register, the most recent evacuation drill record, any open enforcement correspondence, and the contact details of the responsible person and any co-RPs.
None of this is expensive to maintain. The cost of building it from scratch after an enforcement notice has been served is several orders of magnitude greater than the cost of maintaining it month by month. The buildings that get this right are not the largest or most lavishly resourced; they are the ones that have decided someone is going to own the documentation, and have given that person the authority to do so.
How Fletcher Risk can help
We carry out fire risk assessments, fire door inspections and fire safety training for buildings across Chester, Cheshire, the Wirral, Merseyside, Greater Manchester and North Wales. Where responsible persons are unsure whether their existing documentation meets the standard set by Section 156, we offer a documentation review alongside the assessment, identifying gaps and providing the templates and structure to close them. We work with managing agents, landlords, employers and trustees who would prefer to find out what their files look like before an enforcing officer does.
Confident your fire safety records would survive an audit?
If you are responsible for a building and want to be sure your documentation meets the standard the law now expects, please get in touch.
Contact Fletcher Risk