As fire-safety professionals, we all know the drill: the Regulatory Reform (Fire Safety) Order 2005 requires every dutyholder to review their fire risk assessment regularly to ensure it remains valid and up to date.
But here lies the problem.
The legislation does not define what “regularly” means. There is no statutory timeframe. No mandatory review cycle. No explicit benchmark.
And in that silence, a significant loophole has been allowed to grow.
For high-risk environments—sleeping accommodation, care homes, HMOs, hotels, boarding schools, supported living, and other complex residential premises—this ambiguity is no longer tenable. Yet, on a weekly basis, assessors across the UK continue to hear the same refrain:
“Show me where the legislation says it must be reviewed annually, and I’ll do it.”
This is the wrong question—and it leads to the wrong outcomes.
The Danger of Leaving ‘Regular’ Undefined
The Fire Safety Order was deliberately performance-based, avoiding prescriptive timeframes in favour of risk-based judgement. But in practice, the lack of defined intervals has created several issues:
- Dutyholders interpret “regularly” as infrequently as possible – We see it constantly—major organisations implementing three-year review cycles, often written into internal policy to save costs. In low-risk, simple premises, perhaps this is justifiable. But in sleeping-risk environments, it is indefensible.
- High-risk premises are treated the same as low-risk – A single-storey shop with two staff and a back door is treated the same as a hotel with 500 sleeping guests, a care home with vulnerable residents, a block of flats with complex evacuation strategies, or a building containing mixed occupancy and compartmentation challenges.
- Fire-safety professionals constantly have to justify what should be obvious – We all spend countless hours explaining to owners, landlords, and FM managers why annual reviews are necessary—only for them to say: “If it was that important, it would be written in the law.”
- It creates perverse incentives to delay reviews – If there is no legal minimum, the cheapest option becomes the default option.
High-Risk = High Frequency: Why Sleeping Accommodation Must Have Mandatory Annual Reviews
It is indefensible that premises with sleeping occupants—the highest life-risk category—are not explicitly required by law to undergo fire risk assessment review at least annually.
Sleeping environments are inherently high-risk:
- Occupants are unconscious
- Evacuation times are significantly longer
- Staff-to-occupant ratios are often low
- Many residents may be elderly, disabled, or require assistance
- Vertical evacuations are common
- Evacuation strategies rely heavily on the assessment being correct and current
Simple Low-Risk Premises Could Justify a 24-Month Cycle
Not all premises need annual reviews. For simple, low-risk, single-storey premises with stable occupancy, a two-year review may be appropriate. But this must not become the standard for everyone. Large corporations routinely exploit ambiguity in the law to justify three-year cycles—regardless of risk.
Aligning with the Building Safety Act: A Blueprint for Reform
The Building Safety Act already provides clear definitions and accountability frameworks. The same clarity must now apply to fire risk assessment review cycles.
A mandatory annual review requirement for all sleeping-risk premises would:
- Remove ambiguity
- Support professional judgement
- Improve national consistency
- Align with the principles of the Building Safety Act
Conclusion: The Law Needs to Catch Up with Reality
High-risk, sleeping-risk premises must have a statutory 12-month fire risk assessment review cycle. Until the law catches up, fire-safety professionals will remain stuck in the same loop: explaining what every competent practitioner knows, while some organisations hide behind ambiguity to delay critical reviews.
It’s time to fix the loophole.
