Fire safety for serviced
apartments & aparthotels.Properly assessed, from £295.
A serviced apartment sits in a genuinely ambiguous position under fire safety law. It looks like a flat. It functions like a hotel. Guests stay for anything from one night to six months. Depending on the building, the operator, and how the apartments are used, it may be subject to the fire safety order, the Housing Act, or both, and the responsible person picture is often unclear. We carry out fire risk assessments for serviced apartments, aparthotels, and short-term letting operations across the North West and North Wales, built for the way these premises actually work.
Who is the Responsible Person?
In a serviced apartment the duty depends on how the premises is used and how the building is managed, and it is one of the most commonly misunderstood positions in hospitality.
Where apartments are let to short-term paying guests who are not making the property their permanent home, the fire safety order applies in the same way as to a hotel or B&B. The operator is the Responsible Person for the common parts and any areas under their control.
Where apartments are let on a longer-term basis, typically over 28 days, the position may move towards the Housing Act rather than the fire safety order, though the fire safety order continues to apply to common areas and any non-domestic elements of the building.
The operator is always the Responsible Person for common areas, including corridors, stairwells, lobbies, and shared facilities, regardless of the lease length of individual apartments.
Where a building contains both long-term residents and short-term serviced apartment guests, the responsible persons for each part must co-operate, and the interaction between the two uses needs to be addressed in the assessment.
The problems we
hear most often
Fire safety in a serviced apartment operation often falls between the hotel team and the property management team. These are the gaps we find most regularly.
"We are not sure whether we need to treat our apartments as a hotel or as a residential block for fire safety purposes. Our solicitor and our insurer have given us different answers."
This is the most common position we encounter with serviced apartment operators. The legal answer depends on how the apartments are used, how long guests stay, and how the building is managed, and it is genuinely fact-specific. We assess the regulatory position for your operation specifically, and produce a fire risk assessment that addresses the framework that applies, rather than assuming either the hotel or residential answer is right.
"Guests check in through a lockbox or a remote system. There is no reception and no staff on site. We are not sure our arrangements work for a fire at 2am with nobody there."
Unstaffed or remotely managed serviced apartments present a specific fire safety challenge: there is nobody to raise the alarm, assist guests, or liaise with the fire service in an emergency. The detection, alarm, and communication arrangements need to work without a member of staff being present, and guests need to receive fire safety information at check-in rather than from a receptionist who isn't there.
"We have had a building converted or have taken on a new property, and we are not confident the fire safety provision in the building is adequate for short-term letting use."
A building designed for residential use may not be adequate for short-term letting, where guests are unfamiliar with the building and the turnover of occupants is much higher. The compartmentation, detection, and escape arrangements that are adequate for long-term residents may not be sufficient for guests who arrived an hour ago. We assess the building against the actual use rather than the original design intent.
What makes serviced apartments
different to assess
A serviced apartment operation sits between hotel and residential, which means it carries the risks of both and the clear regulatory framework of neither.
Hotel or residential, or both
Serviced apartments do not fit neatly into any single fire safety category. The fire safety order applies to all non-domestic elements. The Housing Act may apply to longer stays. The interaction between the two, and which parts of the building are covered by which framework, needs to be explicitly addressed in the assessment.
Lockbox and remote check-in
Many serviced apartment operations run without on-site staff, with guests checking in via lockbox, key safe, or remote digital systems. There is no one to raise the alarm, assist an impaired or confused guest, or liaise with the fire service. Detection, communication, and the information given to guests at check-in all need to compensate for the absence of staff.
Guests unfamiliar with the building
A guest who checked in last night via a lockbox, who has never spoken to a member of staff, and who does not know the building layout is in a more vulnerable position than even a hotel guest. Fire safety information at check-in, visible escape signage, and reliable detection all matter more in the absence of a staffed reception.
Domestic kitchens in a guest setting
Serviced apartments typically have kitchens, which guests use at any hour. Unattended or overnight cooking is a common cause of fire, and a kitchen fire in an apartment that then spreads to the corridor is the primary fire scenario for this building type.
Residential and short-term alongside each other
Many serviced apartment operations occupy part of a building that also contains long-term residents, offices, or retail. The interaction between the uses, the shared escape routes, and the different fire safety frameworks that apply to different parts need to be addressed explicitly.
Building owners and operators
Serviced apartment operations often separate building ownership from management, with the operator running the business and the landlord owning the asset. The split of fire safety responsibility between the two, particularly for works to the building fabric, needs to be documented clearly.
Fire safety information at check-in — what guests need when there is no receptionist
In a staffed hotel a guest can always ask the receptionist where the fire exits are. In a serviced apartment with lockbox check-in there is no receptionist, and guests may go from the street to a room without speaking to anyone at all. The fire safety information that would otherwise be communicated by a member of staff has to be delivered through the check-in process, the in-apartment information, the signage, and the alarm system. We assess whether your remote check-in arrangements adequately communicate fire safety information to guests who will never meet a member of your team.
Three services.
One point of contact.
Fire risk assessments, fire door inspections, and fire safety training, delivered by one company that understands the specific regulatory position and operational reality of serviced apartment letting.
Fire risk assessments
From £295 per assessmentA thorough assessment that addresses the regulatory framework that applies to your operation, covers unstaffed check-in, guest profile, cooking risk, and any mixed use in the building. Clear written report and documentation suitable for your insurer and the fire authority.
- Regulatory framework assessed for your specific operation
- Unstaffed and remote check-in fire safety arrangements reviewed
- Guest fire safety information at check-in assessed
- Cooking risk in apartment kitchens covered
- Mixed-use building interaction addressed
- Responsible person split with building owner documented
Fire door inspections
From £14 per doorServiced apartment fire doors protecting corridor escape routes, apartment entrance doors, and communal areas are critical. We inspect every component and give you a clear, photographed condition record.
- Frame, leaf, intumescent seals, hinges & hardware
- Self-closing devices and smoke seals
- Apartment entrance, corridor, and final exit doors
- Photographic evidence per door
- Prioritised remedial recommendations
Fire safety training
From £395 per sessionFire safety training for any on-site or remote management staff, focused on the serviced apartment environment including remote guest communication, fire service liaison, and the specific challenges of an unstaffed building.
- Fire safety awareness for management and property staff
- Remote and unstaffed operation emergency procedures
- Guest communication at check-in
- Hands-on extinguisher use on a live fire
- Certificates issued to all attendees
The framework
serviced apartments work within
A serviced apartment operation sits at the intersection of the fire safety order, the Housing Act, and potentially licensing, and the framework that applies depends on the specific operation.
The Regulatory Reform (Fire Safety) Order 2005 applies to all non-domestic premises and to all common parts of buildings containing sleeping accommodation. For serviced apartments let to short-term guests who are not making the property their permanent home, the fire safety order applies to the whole operation in the same way as it applies to a hotel or B&B. The operator is the Responsible Person for common areas regardless of the let length.
For longer-stay lets, typically over 28 days, where tenants are making the apartment their temporary home, the position moves partly towards the Housing Act 2004 and the Housing Health and Safety Rating System, which applies to residential premises. In practice, many serviced apartment operations span both frameworks, and the assessment needs to address the position accurately for the actual mix of let lengths in the building.
The Fire Safety Act 2021 and the Fire Safety (England) Regulations 2022 impose additional duties on the Responsible Person for buildings containing two or more residential units, including requirements to share fire safety information with residents and to maintain records of checks. For a building containing both serviced apartments and permanent residents, these requirements apply to the residential elements.
Regulatory Reform (Fire Safety) Order 2005
Always appliesApplies to all non-domestic elements and common parts. For short-term guest lets, applies to the whole operation as sleeping accommodation.
Housing Act 2004
Longer letsMay apply where apartments are let for more than 28 days and guests are making the property their temporary home. Interacts with the fire safety order for common areas.
Fire Safety (England) Regulations 2022
Mixed residential buildingsApplies to buildings containing two or more residential units. Requires fire safety information to be shared with residents and records of checks to be maintained.
Sleeping accommodation guide
Short-term guest letsThe government sleeping accommodation guide applies to short-term serviced apartment lets in the same way as to hotels and B&Bs. Sets the benchmark for assessment.
Experience you can
put in a report.
Tim founded Fletcher Risk Management to bring genuine expertise and personal accountability to fire safety consultancy in the North West. With more than 30 years in the fire industry, he has assessed serviced apartment operations and aparthotels across the region. He understands the specific regulatory ambiguity of this sector and knows how to produce an assessment that addresses the framework that actually applies to the operation, rather than defaulting to either the hotel or the residential answer. When you book with Fletcher Risk, Tim carries out the work.
- ABBE Level 4 Diploma in Fire Risk Assessment
- NEBOSH National General Certificate
- FPA Fire Safety Management Certificate
- Member — Fire Protection Association
Sam oversees operations and brings both fire safety qualifications and a legal background to the practice. For hospitality operators navigating licensing obligations or insurer requirements alongside fire safety law, Sam's LLB and operational background mean the documentation is framed to satisfy all three.
- ABBE Level 4 Certificate in Fire Risk Assessment
- Bachelor of Laws (LLB)
- Master of Business Administration (MBA)
- 10+ years fire safety experience
"We have engaged Fletcher Risk Management to carry out surveys on a number of our sites for a very important client. The work produced exceeded our expectations by far. I would definitely recommend using this company." — Marie Morgan · EIS Ltd ★★★★★
"Without doubt one of the best and most professional businesses I have used for our Fire Risk Assessment. Tim Fletcher is a highly regarded professional in his field. Don't take a chance — protect your staff, protect your building."
"We have engaged Fletcher Risk Management to carry out surveys on a number of our sites. I would never hesitate to send Tim — always professional, friendly and accommodating. The work exceeded our expectations."
"Thorough, professional, and excellent value. The report was clear and the action points prioritised in a way that made it easy to know exactly what to tackle first. Would recommend without hesitation."
Book an assessment
built for your operation.
Whether you need a fresh assessment, clarity on which regulatory framework applies to your operation, or help with your remote check-in fire safety arrangements, we can help. Call us for an honest conversation with no obligation.