Fire strategy reports for buildings and flats

A fire strategy for a block of flats sets out how the building contains a fire inside the flat where it starts. It covers compartmentation between dwellings, common escape route protection, flat entrance doors, external wall construction, smoke control, detection and fire service access, and it states whether the building operates a stay put approach.

Almost everything in a residential block follows from one design decision: whether a fire is expected to stay in one flat. If it is, the building carries a heavy compartmentation burden and the common areas can stay comparatively simple. If it is not, the escape routes and the alarm system have to do far more work.

The three kinds of residential building this covers

The phrase “buildings and flats” covers three quite different problems, and confusing them is the most common mistake in residential enquiries.

Purpose-built blocks. Designed as flats from the outset, usually with compartment floors and walls, a protected common stair and a stay put approach. The documentation question is normally whether the design intent was ever recorded, and whether the building still matches it after decades of alterations.

Converted buildings. A house, an office or a warehouse turned into flats. Compartmentation has to be created rather than inherited, and it frequently is not achieved to the standard assumed. Converted blocks are where the gap between the paperwork and the building is widest.

Mixed use. Flats above a shop, a restaurant, a gym or a car park. The commercial use below is often the dominant risk, the two parts may have separate responsible persons, and escape routes and compartmentation have to be resolved across the boundary between them.

The higher-risk threshold, and why it changes everything

The Building Safety Act 2022 introduced a separate regime for buildings defined as higher-risk, and the definition is worth stating rather than paraphrasing.

In England, during the occupation phase, a higher-risk building is one that is at least 18 metres in height or has at least 7 storeys, and contains at least 2 residential units. It is height or storey count, either one, and then the residential units on top. Storeys are counted from the storey at ground level to the top storey, ignoring storeys below ground, rooftop machinery and plant rooms, and gallery floors covering less than half the storey below.

Wales sets its own criteria and they are not the same. Under the Building Safety (Description of Higher-Risk Building) (Design and Construction Phase) (Wales) Regulations 2023, a building at the design and construction stage is higher-risk if it is at least 18 metres in height or has at least 7 storeys, and contains at least one residential unit, or a hospital with at least one bed intended for an overnight stay, or a care home, or a children’s home, and is not an excluded building. One residential unit rather than two, and care settings named outright, so a building outside the English definition can sit inside the Welsh one.

Crossing that threshold changes the process, not just the paperwork. In England, design and construction work on a higher-risk building runs through the Building Safety Regulator’s gateway process rather than through ordinary building control. There are three statutory gateways: gateway 1 at planning, gateway 2 before work starts, and gateway 3 at completion, which the building must clear before occupation. The Regulator became a standalone body sponsored by the Ministry of Housing, Communities and Local Government on 27 January 2026, having previously sat within the Health and Safety Executive. Dutyholder roles are defined in regulation, and the building carries golden thread obligations, meaning building safety information must be accurate, maintained and accessible throughout its life.

Wales operates its own arrangements, and they are still being stood up. The Building Safety (Wales) Act 2026 is on the statute book and the Welsh Government published an implementation consultation on 15 June 2026.

The practical consequence for a fire strategy is that it stops being a design-stage deliverable and becomes a living record. It needs an owner, a version history and a trigger for review. A document written once, filed and never updated does not satisfy a golden thread duty, however good it was on the day it was issued.

Below the threshold, the Building Regulations still apply in full, and so does the fire safety information handover duty in regulation 38 of the Building Regulations 2010: the information must reach the responsible person no later than the date of completion or the date of occupation, whichever comes first. England strengthened that duty from 1 October 2023, adding acknowledgement of receipt by the responsible person and notification to the relevant authority. Wales brought equivalent requirements in from 1 July 2026. Being outside the higher-risk regime is not the same as being outside the requirement.

What the fire strategy has to resolve in a block of flats

What a fire strategy for flatted accommodation has to establish, and why each item matters in a residential block specifically.

Stay put, and when it stops being safe

Stay put is a design conclusion, not a default and not a policy anyone can simply adopt. It holds only while the compartmentation between flats holds and the common escape routes stay protected.

That means a stay put approach is only as good as its evidence. A block operating stay put should be able to show what the compartment lines are, that the flat entrance doors meet the assumed specification, that service penetrations through compartment walls and floors are properly sealed, and that the common areas are kept clear.

Where that evidence does not exist, or where a survey finds defects, the usual course is a temporary change to simultaneous evacuation, often with a temporary common alarm and sometimes a waking watch, until the defects are resolved. The National Fire Chiefs Council’s Simultaneous Evacuation Guidance, fourth edition of 17 August 2022, is the reference for making that change, and it discourages prolonged waking watch where a common alarm would do. That is expensive and disruptive, which is why establishing the design intent early is worth doing before somebody else forces the question.

The number of stairs matters here too. Single-stair residential buildings have been the subject of significant recent guidance change. In England the threshold is settled: new residential buildings above 18 metres require a second staircase. The Approved Document B amendment was published on 29 March 2024 and comes into force on 30 September 2026, with transitional provisions where an application was made earlier and work is sufficiently progressed, meaning concrete poured for foundations or piling. Do not rely on what was accepted on a previous scheme.

Existing blocks with no documentation

This is the most common residential enquiry. A managing agent is asked for the fire strategy by a lender, an insurer, a fire risk assessor or a new freeholder, and there is nothing in the file.

The route is a retrospective fire strategy: survey what is actually there, establish what the design intent must have been, identify where the building departs from it, and record the compartment lines on drawings the managing agent can hand to anyone who asks. See fire strategy drawings for what that drawing set contains.

Two things usually run alongside it. An appraisal of the external wall construction, which is a separate specialist exercise with its own methodology. The reference document is PAS 9980:2022, the code of practice for fire risk appraisal of external wall construction and cladding of existing blocks of flats. It is current, and a revision is under way, so check the edition when scoping. And the fire risk assessment, which is a different document with a different purpose: it examines how the building is managed, whereas the strategy establishes what it was designed to do. Assessors routinely carry findings they cannot close because the design intent is unknown, and the strategy is what closes them.

How to take this forward

For a new residential scheme, commission at concept stage. The evacuation approach, stair provision and compartmentation strategy all set the plan form, and changing them after the layout is fixed is expensive.

For an existing block, start with what you can evidence, then fill the gaps. A fire strategy report written for a residential block is only useful if it reflects the building as it stands, not as it was drawn.

Residential blocks carry a high liability profile, so these projects are taken case by case rather than as standard work. Tell us the building, its height and storey count, whether it is purpose-built or converted, and what documentation already exists, and fit will be confirmed before any quote is issued. Reports are arranged across England and Wales through a network of chartered fire engineers, and the higher-risk regime differs between the two nations, so the jurisdiction is established at the outset. For the wider service, see fire strategy consultant.