What Is a Fire Strategy? A Guide for Managing Agents
When a managing agent takes on a new building, the handover paperwork tends to follow a familiar pattern: service charge accounts, maintenance contracts, insurance schedules, copies of leases. What is less commonly found — and less commonly asked for — is the building's fire strategy. This is a gap that matters more than most agents realise, because the fire strategy is, in a very precise sense, the document that explains how the building was designed to be safe. Without it, the managing agent is operating a building whose fire safety logic they have not been able to read. They are, in effect, maintaining a system they do not fully understand.
That is not a comfortable position, particularly given the legal landscape since the Building Safety Act 2022 and the Fire Safety (England) Regulations 2022 came into force. The direction of travel in fire safety law has been towards greater documentation, greater accountability, and a much more explicit expectation that responsible persons — including managing agents — can demonstrate not just that they have acted, but that they understood what they were doing and why. A managing agent who takes on a block without a fire strategy, and does not take steps to understand or obtain one, is starting from a weaker position than they may realise.
This article explains what a fire strategy actually is, how it differs from a fire risk assessment, why so many existing buildings either lack one or have one that is no longer accurate, and what managing agents should do when they take over a building and find that the documentation is incomplete.
What is a fire strategy?
A fire strategy is the document that sets out the fire safety design intent for a building — the logic that underpins everything from the compartmentation of the structure to the evacuation procedure posted in the lift lobby. It records the assumptions that were made when the building was designed or assessed: what the building is made of, how fire and smoke are expected to behave within it, how long the structure will hold before fire can spread from one area to another, and what occupants and emergency services are expected to do in response to an alarm.
The simplest way to think about it is as the building's fire safety blueprint. It is the document that answers the question: why is this building arranged the way it is, and what is each element — the fire doors, the smoke vents, the protected staircase, the alarm system — actually there to do? A fire risk assessment, by contrast, is a snapshot of the current risk: what hazards exist right now, who is at risk, and what measures are in place to control those risks. The two documents serve different but complementary purposes, and each is considerably less useful without the other.
The distinction in plain terms: The fire strategy tells you how the building was designed to work. The fire risk assessment tells you whether it is currently working as intended. A competent assessor carrying out a fire risk assessment on a residential block will always want to see the fire strategy, because without it they are assessing the current state of the building without knowing what that state is supposed to look like. The two documents should inform each other throughout the life of the building.
In terms of content, a fire strategy for a residential block will typically cover the building's purpose and construction type, the applicable design standards used at the time of construction, the compartmentation strategy and the assumed fire resistance periods for walls, floors, and doors, the evacuation strategy — almost always a stay-put strategy for a purpose-built residential block — the fire detection and alarm system and its intended scope, the smoke control arrangements such as automatic opening vents or pressurisation systems, the means of escape from each part of the building, access and facilities for the fire service, and the ongoing management obligations that the building's design imposes on whoever is responsible for it. For a complex or high-rise building, the strategy may also address structural fire resistance, external fire spread, and the interface between different parts of the building used for different purposes.
Where does a fire strategy come from?
For buildings constructed or significantly altered after October 2010, Regulation 38 of the Building Regulations 2010 requires that fire safety information be handed to the responsible person on completion of the work. That information — which constitutes the basis of the fire strategy — is supposed to travel with the building from the moment it is signed off, forming part of the documentation that any incoming responsible person receives. In practice, compliance with Regulation 38 has been inconsistent, and the fire strategy is one of the most frequently missing items in the documentation of existing residential buildings, even relatively new ones.
For buildings constructed before October 2010 — which includes a large proportion of the residential blocks managed by agents across the North West — there was no equivalent requirement, which means a formal fire strategy may simply never have existed. The building may have been designed and built to the standards of its day, those standards may have been entirely adequate at the time, and yet there is no single document that records what those standards were and how they were applied. The fire safety logic is embedded in the building itself but has never been written down in a form that a managing agent, a fire risk assessor, or a fire authority inspector can read.
This creates a particular problem in the leasehold residential sector, where buildings change hands between freeholders, where managing agents are appointed and replaced, and where the institutional memory of a building's fire safety design can easily be lost across a single management transition. The agent appointed today may be the third or fourth to manage a block since it was built, and the fire safety documentation — if it was ever assembled — may not have survived any of those transitions intact.
Why the fire strategy matters for a managing agent taking on a new block
A managing agent taking over an existing residential block inherits, to varying degrees, the fire safety obligations that attach to it. Under the Regulatory Reform (Fire Safety) Order 2005, the responsible person — in most cases the freeholder or the residents' management company, with the managing agent acting on their behalf — must ensure that the common parts are managed safely and that a suitable and sufficient fire risk assessment is in place. The managing agent's precise scope of duty depends on the management agreement, but in practice agents who take on day-to-day management of a block inevitably take on a degree of control over premises, and with it a degree of responsibility under the Order.
The fire strategy matters in this context for several distinct reasons, each of which a prudent agent should understand before they sign a management agreement and certainly before they commission a new fire risk assessment on the block.
It tells you what the evacuation strategy is — and whether it is still valid
The single most important piece of information the fire strategy contains, for a managing agent of a residential block, is the evacuation strategy: whether the building is designed for stay-put, simultaneous evacuation, or some hybrid arrangement. For purpose-built blocks of flats, stay-put is the default design assumption and it underpins the entire fire safety regime — the compartmentation, the alarm system, the absence of a communal alarm sounder in most cases. But stay-put is only valid if the compartmentation that supports it is intact and functioning. A fire strategy tells you what that compartmentation was designed to look like; a fire risk assessment tells you whether it still does. Without the first document, the second is harder to carry out with confidence, and any decision to change from stay-put to simultaneous evacuation — a decision with very significant practical and cost implications — needs to be grounded in an understanding of what the building was originally designed to do.
The stay-put versus simultaneous evacuation question has become considerably more complex since Grenfell and the legislative changes that followed. Managing agents dealing with buildings that have had EWS1 assessments, cladding reviews, or other post-Grenfell assessments will often find that the original fire strategy has been revised or superseded — or that a waking watch or interim evacuation protocol was put in place without anyone properly updating the underlying documentation. Understanding the current evacuation strategy, and the basis for it, is something every managing agent should be able to explain clearly, and the fire strategy is where that understanding should begin. Our article on what a fire escape and evacuation plan should contain covers the practical documentation requirements in detail.
It determines what the fire alarm system is supposed to do
In a residential block operating on a stay-put strategy, the fire detection and alarm system is typically not designed to alert all residents simultaneously. Smoke detectors in the common parts are there to protect the means of escape, not to trigger a building-wide evacuation. The system is designed to help the fire service locate and respond to a fire quickly, not to empty the building the moment smoke is detected. This is a deliberate design choice, not a deficiency, and it is one that a managing agent who does not understand the fire strategy may find alarming when they first encounter it — particularly if they have previously managed buildings with a different evacuation strategy.
Understanding what the alarm system is supposed to do also matters when the system develops faults or requires replacement. Our article on what to do about a long-term fault on a fire alarm system addresses the practical steps; but before any remedial action can be assessed against what is actually required, someone needs to know what the system was designed to achieve in the first place. That information lives in the fire strategy. A managing agent who replaces a system without understanding the original design intent risks either over-specifying — installing a communal alarm in a stay-put building that is not designed to support one — or under-specifying, leaving the building with detection coverage that falls short of what the strategy requires. Our guide to understanding fire alarm grades and categories explains the relevant standards in accessible terms.
It explains the significance of the fire doors
Fire doors are the physical expression of compartmentation, and compartmentation is the mechanism by which a residential block protects its residents while a fire is contained. Every flat entrance door in a residential block is a fire door. Every door to a riser cupboard, plant room, and bin store is likely to be a fire door. The protected staircase is only protected if the doors that lead into it are functioning correctly. The fire strategy sets out what fire resistance period each door is specified to provide — typically 30 or 60 minutes — and therefore what standard any replacement or remedial work must meet.
A managing agent overseeing fire door maintenance and inspection without access to the fire strategy is in the position of maintaining components to a standard they cannot verify. They may be replacing a 60-minute door with a 30-minute one without realising it, or accepting a contractor's assurance about a door's specification that they have no way to check independently. A systematic fire door inspection programme carried out by qualified inspectors — as we set out in our article on what fire door inspector qualifications are actually required — should always be read against the building's fire strategy to confirm that what is in place is what the strategy specifies.
It governs what alterations are and are not permissible
Residential blocks are not static. Leaseholders fit new kitchens and bathrooms. Common areas are refurbished. New services are run through existing walls and floors. Mobility scooter storage is introduced. Each of these changes has the potential to affect the building's fire strategy — a hole drilled through a compartment wall to run a cable, if not correctly fire-stopped, can undermine a fire separation that the entire evacuation strategy depends upon. A managing agent who is not aware of the fire strategy cannot assess whether a proposed alteration is consistent with it, and in a leasehold building where alterations are a routine part of management, that is a significant gap.
This is one of the practical reasons why the Building Safety Act 2022 placed such emphasis on the "golden thread" concept — the idea that fire safety information should be maintained, updated, and passed on in a form that allows anyone responsible for the building at any point in its life to understand what it was designed to do and whether it still does it. For managing agents, the golden thread starts with having a fire strategy in the first place.
A common scenario: A managing agent takes over a 1990s residential block. The previous agent left incomplete records. There is a fire risk assessment from three years ago, but no fire strategy. The assessor who carried it out made reasonable assumptions about the compartmentation based on the building's age and construction type, but noted that documentary evidence was not available and recommended that records be sought. Nothing was done. A leaseholder subsequently fitted a new bathroom and had a contractor run waste pipes through a riser wall. Nobody checked the fire-stopping. The compartment is now compromised — but without a fire strategy, the managing agent has no baseline against which to identify that anything has changed. This is not a hypothetical; it is a description of the position many managing agents find themselves in, across blocks of every size and age.
The difference between a fire strategy, a fire risk assessment, and an evacuation plan
These three documents are frequently confused, and the confusion matters because each serves a distinct purpose and the absence of any one of them represents a different kind of gap.
- Fire strategy The design intent document. Produced at the planning or construction stage, or retrospectively for existing buildings that lack one. Sets out what the building was designed to do in the event of a fire: how it contains fire and smoke, how occupants are expected to behave, what systems are provided and why, and what ongoing management the design requires. Should remain largely stable throughout the building's life unless the building is significantly altered or the evacuation strategy changes. The responsible person should hold a copy and any fire risk assessor commissioned to assess the building should be given access to it.
- Fire risk assessment The current-state compliance document. Carried out under the Regulatory Reform (Fire Safety) Order 2005. Identifies hazards, evaluates risk, and records the measures in place to control it. Should be reviewed regularly and revised whenever material changes occur — as we explored in our article on how often a fire risk assessment should be reviewed. For a residential block, it applies to the common parts only: the individual flats sit outside its scope under the Order, though the flat entrance doors — as fire doors — fall squarely within it following the Fire Safety Act 2021. The FRA is a point-in-time assessment that references the building as it currently stands; the fire strategy is the reference against which that assessment should be made.
- Fire evacuation plan The operational document. Sets out what residents, staff, and visitors should do if the alarm activates or if they discover a fire. In a stay-put building it will typically advise residents to remain in their flat unless directly affected by fire or smoke, to close doors, and to call 999. In a simultaneous evacuation building it will describe the evacuation routes and assembly point. The evacuation plan should be derived from the fire strategy — it is, in essence, the resident-facing translation of the strategy's evacuation provisions. Our article on what a fire escape and evacuation plan is covers the content requirements, and under the Fire Safety (England) Regulations 2022, responsible persons for blocks above 11 metres must provide residents with information about the evacuation strategy for their building at least annually.
For a managing agent taking over a block, the ideal position is to have all three documents, to understand how they relate to each other, and to ensure they are kept current and consistent. In practice, many agents take on buildings where one or more of these documents is missing, out of date, or inconsistent with the others. Knowing which gap is most serious — and what to do about it — requires understanding what each document is actually for.
What happens when the fire strategy is missing
The absence of a fire strategy is more common than the sector generally acknowledges. Buildings constructed before the widespread use of performance-based fire engineering, buildings that changed hands multiple times without adequate documentation, buildings that have been refurbished or altered without anyone updating the original records — all of these may present to a new managing agent with no fire strategy at all. This is not automatically a compliance failure: there is no direct legal requirement under the Fire Safety Order for a fire strategy to exist as a standalone document. But the practical consequences of its absence are significant, and the direction of regulatory expectation is clearly towards comprehensive documentation rather than away from it.
When a fire strategy is missing, a competent fire risk assessor carrying out a new assessment of the building will note the gap and make assumptions based on the building's age, construction, and apparent design. Those assumptions may be reasonable, but they are assumptions nonetheless, and they carry less weight than documented evidence of design intent. An assessor who notes that compartmentation appears adequate but cannot confirm the specified fire resistance periods is in a different position from one who can point to the fire strategy and confirm that the current state matches what was designed. As we explored in our article on competence and fire risk assessment, the quality of an assessment depends heavily on the information available to the assessor, and missing documentation is one of the most common constraints on assessment quality.
Where a fire strategy is missing and the building is of sufficient complexity or risk to make its absence a genuine problem, the appropriate response is to commission a retrospective fire strategy. This is a document produced by a qualified fire safety consultant who carries out a site assessment of the building as it currently stands, reviews whatever historical documentation is available, and produces a document that records the current fire safety design of the building, identifies any gaps or inconsistencies, and sets out the management obligations that the building's design requires. It is not the same as the original fire strategy — it cannot recreate design intent that was never recorded — but it provides a defensible, documented basis for ongoing management that is considerably better than having nothing at all.
Regulation 38 and the golden thread: Under Regulation 38 of the Building Regulations 2010, anyone carrying out building work is required to provide fire safety information to the responsible person on completion. This requirement has not always been consistently observed, but it establishes the principle that fire safety documentation should travel with a building from the point of construction onwards. The Building Safety Act 2022 reinforced this through the golden thread concept: for higher-risk buildings (those above 18 metres with two or more residential units), the accountable person must maintain a digital record of the building's fire safety information and keep it current throughout the building's life. For buildings below that threshold, the principle is the same even if the specific requirements are less prescriptive: responsible persons should hold and maintain the documentation that allows them to manage fire safety competently.
Taking over a building: what to ask for and what to check
When a managing agent takes on a new residential block, the fire safety documentation review should be a structured part of the handover process, not an afterthought. The questions below are not exhaustive, but they represent the minimum a prudent agent should be asking before they accept responsibility for a building's fire safety management.
- Does a fire strategy exist? Ask for a copy as part of the handover documentation. If the previous agent or the freeholder cannot produce one, establish whether the building was constructed after October 2010 — in which case Regulation 38 should have resulted in fire safety information being handed over — or before, in which case a retrospective strategy may need to be commissioned. Do not proceed on the assumption that the absence of a strategy is normal and therefore acceptable.
- Is the fire strategy current? A fire strategy produced at the time of construction should remain valid as long as the building has not been materially altered. But many buildings have been altered — extensions added, layouts changed, new services installed, common areas reconfigured — and those changes may have made the original strategy inaccurate. Check whether the strategy has been reviewed following any significant work on the building, and whether the current physical state of the building is consistent with what the strategy describes.
- What is the evacuation strategy, and is it clearly communicated to residents? Confirm whether the building operates on stay-put or simultaneous evacuation, understand the basis for that decision, and check that the information provided to residents — via the evacuation plan, signage in the common parts, and any resident communications — accurately reflects that strategy. A building with stay-put signage but a simultaneous evacuation protocol, or vice versa, is a building whose fire safety management is contradicting itself.
- When was the fire risk assessment last carried out, and by whom? Obtain the most recent fire risk assessment and check the date, the scope, and the qualifications of the assessor. Review the outstanding actions: are there items that have been carried forward from previous assessments without being addressed? Has the assessment been updated following any changes to the building or its use? Our article on how to commission a fire risk assessment that actually protects you covers what to look for when evaluating the quality of an existing assessment.
- What is the condition of the fire doors? Fire doors are the most frequently compromised element of compartmentation in residential blocks, and their condition degrades continuously through normal use. Ask for the most recent fire door inspection report and check what remedial actions were identified. If no inspection has been carried out recently, commission one as a priority. Given that flat entrance doors are now explicitly within scope of the Fire Safety Order following the Fire Safety Act 2021, this applies to every flat in the block — a point that some managing agents have been slow to act on.
- What maintenance records exist for fire safety systems? The alarm system, emergency lighting, smoke control systems, and automatic opening vents all require regular testing and maintenance, and the records of that testing form part of the fire safety documentation that a responsible person must maintain. Gaps in the maintenance record are not just an administrative issue — they are evidence that systems may not have been functioning as required and that the responsible person was not discharging their duties under the Order. Our article on alarm receiving centres is relevant for any block where the system is monitored remotely.
- Is there any history of enforcement action or prohibition notices? Check whether the fire authority has issued any enforcement notices, improvement notices, or prohibition notices against the building or the previous responsible person. Enforcement history is disclosable and a new managing agent should not take on a block with unresolved enforcement action without understanding exactly what was required, what has been done, and what remains outstanding.
The relationship between the fire strategy and ongoing management
The fire strategy is not a document that sits in a filing cabinet and is never opened again. It is, or should be, a live reference point for the management of the building — consulted whenever maintenance work is carried out that might affect the building's fire safety systems, whenever a leaseholder requests consent for alterations, whenever a contractor proposes a change to the common parts, and whenever a fire risk assessor is commissioned to review the building's compliance. The fire strategy should not change unless the building changes in a way that requires it to be revised; but it should be consulted regularly to ensure that the building's current state remains consistent with what the strategy describes.
In practice, this means that managing agents need to hold the fire strategy in an accessible form and ensure that it is part of the information pack given to any contractor, assessor, or consultant working on the building. It means reviewing the strategy whenever significant works are proposed and asking, explicitly, whether those works are consistent with the building's fire safety design. And it means flagging to the freeholder or residents' management company when the building appears to have drifted from the strategy — when doors have been altered, when compartmentation has been compromised, or when systems have been modified in ways that the strategy does not anticipate.
This kind of active engagement with the building's fire safety documentation is exactly what the Building Safety Act 2022 was designed to encourage, and it is increasingly what fire authorities and, in the case of higher-risk buildings, the Building Safety Regulator will expect to see evidence of. Managing agents who can demonstrate that they understand their buildings' fire strategies, that they maintain them as accurate records, and that they make decisions by reference to them are in a significantly stronger compliance position than those who cannot. As we set out in our article on compliance reality in property management, the gap between agents who take documentation seriously and those who treat it as a box-ticking exercise tends to become visible precisely when it matters most.
When to commission a retrospective fire strategy
Not every residential block needs a full retrospective fire strategy. A modern, purpose-built block of straightforward construction, with a complete set of handover documentation, a current fire risk assessment, and a well-maintained set of fire safety systems, may not need one at all — the existing documentation is likely sufficient. But a retrospective fire strategy should be considered seriously in any of the following circumstances.
Where no fire strategy exists and the building is of sufficient complexity that its fire safety design cannot reasonably be inferred from visual inspection alone — multi-staircase blocks, buildings with smoke control systems, buildings with fire-engineered solutions such as pressurisation or sprinklers, or any building where the compartmentation arrangements are not straightforwardly apparent from the layout — a retrospective strategy is the appropriate tool for establishing what the building was designed to do and whether it still does it.
Where a building has been significantly altered since the original strategy was produced, and the alterations have not been reflected in updated documentation, a retrospective strategy can reset the baseline. This is particularly relevant for blocks that were originally constructed for a different purpose and subsequently converted to residential use, where the fire safety logic of the conversion may not be properly documented, and for blocks where major refurbishment — new cladding, new balconies, new roofing — has changed the external fire spread characteristics of the building in ways the original strategy did not anticipate.
Where the managing agent is taking over a building with a poor compliance history — unresolved fire risk assessment actions, a history of enforcement notices, or evidence of systematic maintenance failures — a retrospective strategy is a way of establishing a clear and documented starting point for the remediation work that will inevitably follow. It provides a defensible record of the building's current state and a framework for prioritising remedial actions, and it signals to the fire authority that the new management is taking a proactive approach to compliance rather than inheriting and perpetuating the problems of the previous regime.
The cost of a retrospective fire strategy varies considerably with the size and complexity of the building, but it should be considered in the context of what it replaces: the liability exposure of managing a building whose fire safety design is not documented, and the cost of getting fundamental decisions wrong — about evacuation strategy, about alarm systems, about fire door specifications — because the information needed to make those decisions correctly was never properly established. We cover the broader question of how to evaluate and commission fire safety professional services in our article on how to commission a fire risk assessment that actually protects you, and the same principles of competence and independence apply when appointing a consultant to produce a retrospective fire strategy.
A note on higher-risk buildings
Everything above applies to residential blocks of all sizes, but managing agents responsible for buildings above 18 metres in height — or with seven or more storeys — face additional specific requirements under the Building Safety Act 2022. These buildings are classified as higher-risk buildings, regulated by the Building Safety Regulator, and the accountable person (typically the freeholder) must register the building, maintain a safety case, and keep a digital golden thread of fire safety information that includes all the documentation described in this article and considerably more besides.
For managing agents appointed to manage higher-risk buildings, the fire strategy is not just good practice — it is a component of a regulated documentation regime that the Building Safety Regulator can inspect and audit. The consequences of non-compliance in a higher-risk building are serious: the Regulator has powers to require remediation, to prosecute accountable persons and principal accountable persons, and, in extreme cases, to prohibit occupation. Managing agents who are in scope of these requirements should ensure they have professional advice on their specific obligations, and should not assume that their existing compliance practices for lower-risk buildings are sufficient for a higher-risk building portfolio. Our articles on the Building Safety Act 2022 for managing agents and on the review obligation cover the overlapping documentation duties in detail.
We work with managing agents across Chester, Cheshire, the Wirral, North Wales, and the wider North West on fire risk assessments, fire door inspections, and fire safety training for residential blocks of all sizes and ages. If you are taking on a new building and are uncertain about the completeness or accuracy of the fire safety documentation you have inherited, or if you manage an existing block and have concerns about whether the current documentation reflects the building's actual fire safety design, please get in touch.
Managing agents: talk to us about your buildings
We carry out fire risk assessments and fire door inspections for residential blocks across the North West and North Wales. If you are taking over a new building, reviewing your fire safety documentation, or concerned about the compliance position of a block in your portfolio, please get in touch.
Get in touch Fire Risk Assessments Fire Door Inspections Managing AgentsThis article is intended as general guidance on fire strategy documentation for managing agents and responsible persons in England and Wales. It does not constitute legal advice. Managing agents and responsible persons should seek professional advice in relation to the specific circumstances of their buildings. Fletcher Risk Management Ltd is based in Chester and provides fire risk assessments, fire door inspections, and fire safety training across the North West and North Wales.