How often should a fire risk assessment be reviewed?

Specific triggers that mean you cannot wait for the anniversary

Regardless of when the last full assessment was carried out, certain events legally require an immediate review rather than waiting for the next scheduled date. We see landlords get caught out here more often than on the annual cycle itself — a building that was reviewed six months ago but has since had a change of use, or a new HMO licence, or a fire in a neighbouring flat, still needs an immediate review even though the anniversary is nowhere near.

• Any building works, refurbishment or alteration affecting escape routes, compartmentation, or fire doors, including seemingly minor works such as replacing a communal door or adding a bin store.
• A change of use, in whole or part, of the building, including converting a house into a licensable HMO.
• A significant change in occupancy numbers or the profile of occupants, for example a change from single-family to multiple-occupation use, or an increase in residents needing evacuation assistance.
• A fire, near-miss, or any incident revealing that the existing assessment underestimated a risk, even a small one contained to a kitchen or bin store.
• New legislation or guidance materially changing the required standard, as happened with the Fire Safety Act 2021 and the Fire Safety (England) Regulations 2022.
• Findings from an external wall survey (EWS1) or an intrusive fire door or compartmentation survey suggesting fire safety implications not previously identified.
• A formal complaint from a resident, employee, or the fire and rescue service raising a specific, credible concern about fire safety arrangements.

The difference between a full reassessment and a review

Not every review needs to be a full new survey from scratch, and treating every review as a complete re-inspection is both unnecessary and, for larger portfolios, unaffordable. Where nothing material has changed, a documented review confirming the existing findings and action plan remain valid, dated and signed by a competent person, can be sufficient in genuinely lower-risk situations. Where there has been material change, or where a significant amount of time has passed, a full reassessment involving a fresh site visit is the appropriate response.

• A desk-based review is appropriate where the assessor (or a competent person on their behalf) can confirm, with evidence, that nothing material has changed since the last physical inspection.
• A full reassessment is required wherever the building, its use, or its occupancy has changed, or wherever a substantial period has passed since the last physical site visit.
• A desk-based review alone will not be defensible if the building itself has moved on since the last physical inspection — an enforcement officer will ask when the assessor was last actually on site, not just when the document was last dated.
• Mixing the two appropriately, rather than defaulting to either extreme, is what a genuinely well-run review programme looks like in practice.

What happens if you let an assessment lapse

An overdue assessment is one of the most common findings enforcement officers cite, and is treated as a breach in its own right independent of the physical condition of the building — even a building in genuinely good physical condition can still receive an enforcement notice purely for an absent or significantly out-of-date assessment. It also creates practical friction well before any enforcement visit reaches that stage: insurers may query cover or decline a claim, and lenders or buyers' solicitors will almost always ask for the current assessment during any sale or refinancing on a leasehold flat.

A practical review calendar for a managing agent

Most well-run buildings settle into a simple, repeatable pattern rather than treating each review as a one-off decision made under pressure. We recommend clients build the review date into the same calendar as their other statutory and insurance obligations, rather than relying on memory or an assessor's unprompted reminder email.

Why annual review has become the de facto standard even without a statutory number

Ten years ago it was more common to see fire risk assessments reviewed every two or three years on lower-risk residential blocks, with informal reliance on 'nothing has changed' as the justification. Since Grenfell, that has shifted decisively. Insurers now routinely ask for the date of the last assessment as a condition of renewal, several London boroughs treat an out-of-date assessment as an automatic HMO licensing failure, and the Fire Safety (England) Regulations 2022 introduced quarterly and annual checks that only make sense sitting underneath an annually reviewed parent assessment. Annual review is no longer just good practice advice; it is the only interval that keeps pace with the checks now required around it.

• Insurers increasingly request the review date directly, not just confirmation an assessment exists somewhere.
• HMO licensing renewal in most London boroughs expects a current assessment as standard supporting evidence.
• The quarterly door checks required by the Fire Safety (England) Regulations 2022 are most useful when they feed into an assessment reviewed at least as often as annually.
• Managing agents increasingly build the review into their own KPI reporting to freeholders and RTM boards, making an annual cycle the practical norm regardless of the statutory minimum.

Reviewing after a change of responsible person

A change of freeholder, managing agent or RTM company does not reset the clock on the existing assessment, and it is a common misconception that a new owner or agent gets a grace period before fire safety duties apply to them. Liability under the Order attaches to whoever is the responsible person at the relevant time. What a change of management does justify, and what we would strongly recommend, is an immediate independent review to confirm the incoming responsible person understands exactly what they have inherited, rather than relying on a handover summary from the outgoing party who may have different priorities or incomplete records.

Documentation that supports a defensible review history

When an enforcement officer, insurer or solicitor asks to see the review history for a building, what they are really testing is whether fire safety has been managed continuously rather than in occasional bursts of activity triggered by a scare. A single folder holding every assessment, review note and completed action item, in date order, is worth more than an impressively long original report that has never been revisited.

• The original full assessment and every subsequent review or reassessment, dated and signed by whoever carried it out.
• A live action plan showing which findings have been closed out, by whom, and on what date, not just a list of open items.
• Records of the specific triggers considered at each review point — what changed, what didn't, and why the reviewer reached the conclusion they did.
• Supporting maintenance records for fire doors, alarms and emergency lighting, cross-referenced to the relevant review date.
• Correspondence with residents, contractors or the fire and rescue service that bears on any of the above.