Shopping-centre fire safety: tenant versus centre responsibilities
The shopping-centre operator and individual tenants can each have fire-safety duties to the extent of their control. A shop needs a suitable assessment for its own activities and premises; shared escape routes, alarms and evacuation arrangements must be coordinated. Article 22 of the Fire Safety Order requires responsible persons sharing premises to cooperate.
8 min readBy and technically reviewed by Awais Sarwar, MSc Updated 14 Oct 2026
The short answer
The shopping-centre operator and individual tenants can each have fire-safety duties to the extent of their control. A shop needs a suitable assessment for its own activities and premises; shared escape routes, alarms and evacuation arrangements must be coordinated. Article 22 of the Fire Safety Order requires responsible persons sharing premises to cooperate.
Article 3 of the Regulatory Reform (Fire Safety) Order 2005 identifies the Responsible Person. For a workplace this is normally the employer where the workplace is to any extent under their control. Other people may hold duties to the extent of their control. The lease and management agreement help explain practical arrangements but do not replace the statutory test. Start by naming the shop employer, landlord and centre-management contact and recording who controls which precautions.
Does a centre-wide assessment replace a tenant assessment?
Not automatically. The government offices-and-shops guidance explicitly includes individual units within shopping centres, while overall multi-use shopping-area management is addressed by separate large-places-of-assembly guidance. A centre report may cover shared infrastructure without evaluating your electrical equipment, stock, working practices, staff training or fit-out. Obtain the relevant extracts and identify the boundaries rather than commissioning duplicate whole-centre work or assuming no tenant work is needed.
The legal assessment duty
The Fire Safety Order applies to relevant non-domestic premises in England and Wales. This guide focuses on England and shopping-centre tenant arrangements.
The buildings behind this advice
Article 22: cooperation is a legal duty
Where two or more responsible persons share, or have duties in respect of, premises, Article 22 requires cooperation and coordination. Ask how your alarm connects to the wider system, what starts evacuation, which routes are available, who maintains relevant precautions, and how changes are communicated. Record uncertainty and follow it up. It is unsafe to assume “the landlord deals with it” if nobody has checked the interface.
A practical division of tasks
The tenant commonly manages stock, internal housekeeping, portable equipment, its staff information and the precautions within its control. Centre management commonly coordinates shared routes and building-wide systems within its control. Some items overlap. A fire door on a boundary, an alarm interface or a route through a service corridor needs an agreed maintenance and information arrangement. These are practical examples, not a universal allocation of liability for every lease.
Written records since October 2023
Section 156 changes require responsible persons to record their fire risk assessment in full and their fire-safety arrangements, not merely significant findings in qualifying larger businesses. Keep assessor identity, responsibilities and coordination information available. A report alone does not prove the action plan has been implemented; maintain records of work, training and checks.
What the enforcement figures actually say
England’s year-ending-March-2026 protection statistics report 8,932 audits of shops, 18% of all premises audits. Across all premises types, 60% of audits were satisfactory. Shops were the most-audited premises type. These figures show regulatory attention; they are not the proportion of shopping-centre shops that are unsafe, nor the number of fires in malls.
Documents to request from centre management
Request the relevant fire-strategy and evacuation information, alarm interface details, shared-route arrangements and relevant maintenance records. Identify who can answer technical questions and how you notify the centre of changes. You may not need the entire building file; ask for what is relevant to the unit and the assessment limitations.
If responsibilities are disputed
Escalate the question in writing to the parties with control, ask for the relevant agreements and obtain competent advice. Do not wait for a commercial dispute to resolve before addressing immediate hazards. Our tenant assessment can identify evidence gaps and action owners, but it does not settle lease disputes or replace specialist legal advice.
Preparation list to take to your site contact
Use this as a conversation checklist, not a substitute for a suitable assessment.
Name the Responsible Person and centre contact
Confirm unit scope, area, levels and operating use
Provide the relevant layout and centre fire-safety information
Arrange access to the unit and relevant escape routes
