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Fire safety law in the United Kingdom has undergone one of its most significant transformations in decades — and 2026 marks a pivotal year. New regulations came into force on 6 April 2026. Further major changes take effect on 30 September 2026. If you own, manage, or operate any property in the UK, the question of who is responsible for making a fire risk assessment has never carried more legal weight.
This guide sets out exactly who UK law holds accountable in 2026 — drawing on the Regulatory Reform (Fire Safety) Order 2005, the Fire Safety Act 2021, the Building Safety Act 2022, and the landmark Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 — and what responsible persons across Manchester, Birmingham, Warrington, and the West Midlands need to do right now.
The starting point remains the Regulatory Reform (Fire Safety) Order 2005 — the primary legislation governing fire safety in non-domestic premises across England and Wales. Under this Order, legal responsibility sits with one defined individual: the Responsible Person.
In 2026, the Responsible Person is defined as:
Since October 2023, under Section 156 of the Building Safety Act 2022, all Responsible Persons must formally record all fire risk assessment findings, document their fire safety management arrangements, and identify all other Responsible Persons sharing the building. In 2026, enforcement bodies are taking an increasingly firm stance on how businesses and landlords demonstrate this compliance.
For every workplace — office, restaurant, warehouse, retail unit, or industrial premises — the Responsible Person is the employer or the person with overall control of the premises. All businesses, regardless of size, must have a fully written fire risk assessment UK and a formal record of fire safety arrangements. In 2026, BS 9792:2025 — the updated British Standard — defines the methodology and documentation standard every compliant assessment must meet.
Landlords of Houses in Multiple Occupation remain firmly within scope. A written fire safety risk assessment is a mandatory condition of every HMO licence issued by Manchester City Council, Birmingham City Council, Warrington Borough Council, and all West Midlands metropolitan boroughs. Without a current, 2026-compliant assessment, your licence application will be refused — or your existing licence revoked.
This is where 2026 brings the most significant change. The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025, which came into force on 6 April 2026, introduce major new duties for Responsible Persons of qualifying residential buildings:
| 2026 Requirement | What This Means for You |
| Identify ‘relevant residents’ | You must identify all residents with mobility, sensory, or cognitive impairments that may affect their ability to evacuate independently |
| Person-centred fire risk assessments | Your fire risk assessment must now specifically address the evacuation needs of each vulnerable resident — not just the building as a whole |
| Written Personal Emergency Evacuation Plans (PEEPs) | A tailored, written PEEP must be created for each relevant resident — with their consent — outlining their specific evacuation arrangements |
| Applies to buildings over 11m with simultaneous evacuation | Any residential building above 11 metres using a ‘get out and stay out’ strategy falls within scope — affecting thousands of UK landlords |
| GDPR & Equality Act compliance required | Handling sensitive resident data for PEEPs requires GDPR-compliant processes and awareness of Equality Act 2010 obligations |
Commercial landlords retain responsibility for the structure, external walls, and all shared common areas of their buildings — regardless of how the property is tenanted. This responsibility cannot be informally delegated. A formal, written assignment within the lease is required to transfer any specific fire safety duty to a commercial tenant.
For buildings above 18 metres (or seven or more storeys), the Building Safety Act 2022’s higher-risk building regime remains fully in force. Responsible Persons must ensure registration with the Building Safety Regulator, maintain a Golden Thread of safety information, and comply with all BSR-issued requirements. From 30 September 2026, major updates to Approved Document B take effect — including mandatory second staircases for new residential buildings over 18m, stricter cladding standards, and enhanced sprinkler requirements.
UK law requires the assessment to be carried out by a competent person. In 2026, the definition of competence is more demanding than ever:
The ‘suitable and sufficient’ standard required by UK law is a high bar — particularly for HMOs, residential blocks, and commercial properties with complex risk profiles. In 2026, enforcement bodies are scrutinising not just whether an assessment exists, but whether it genuinely meets this standard.
Non-compliance with UK fire safety legislation remains a criminal offence — and penalties have not softened:
Greater Manchester Fire and Rescue Service, West Midlands Fire Service, Warrington Fire and Rescue Service, and Birmingham Fire Service all actively enforce these requirements across our service areas. In 2026, enforcement activity is increasing — not decreasing.
At Fire Safety Risk Assessment, our assessments are fully updated to reflect every 2026 regulatory change — including the new PEEP obligations, BS 9792:2025 requirements, and Building Safety Act 2022 duties. Here is what every client across Manchester, Birmingham, Warrington, and the West Midlands receives:
The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 came into force on 6 April 2026. These regulations require Responsible Persons of qualifying residential buildings to identify vulnerable residents, carry out person-centred fire risk assessments, and create written Personal Emergency Evacuation Plans (PEEPs) for those who may need assistance evacuating. The regulations apply to multi-occupied residential buildings above 11 metres using a simultaneous evacuation strategy.
Yes — if your building falls within scope of the April 2026 regulations, or if your existing assessment was completed before BS 9792:2025 came into effect, an urgent review is required. Any significant change to legislation constitutes a trigger for reassessment under UK fire safety law. Fire Safety Risk Assessment provides 2026-compliant reassessments for all existing clients and new enquiries across Manchester, Birmingham, Warrington, and the West Midlands.
A Personal Emergency Evacuation Plan (PEEP) is a written, tailored evacuation plan for an individual resident who may not be able to self-evacuate during a fire emergency — due to mobility, sensory, or cognitive impairments. From 6 April 2026, PEEPs are a legal requirement for qualifying residential buildings. With resident consent, the Responsible Person must create and maintain a PEEP for every relevant resident, updated when their circumstances change.
Approved Document B is the UK government’s guidance on fire safety in building design and construction. From 30 September 2026, major updates take effect — including mandatory second staircases in new residential buildings over 18 metres, enhanced sprinkler requirements, and stricter cladding and external wall standards. These changes affect new builds and major refurbishments — and have implications for the fire risk assessments required in high-rise residential buildings.
The question of who is responsible for making a fire risk assessment has a clear answer in 2026 — and the consequences of getting it wrong are more significant than ever. Whether you are an employer in Manchester, a landlord in Birmingham, a managing agent in Warrington, or a property owner across the West Midlands, your legal duties are non-negotiable and actively enforced.
The April 2026 PEEP Regulations are already in force. The September 2026 Approved Document B updates are approaching. If your fire risk assessment was written before these changes, it needs to be reviewed — now.
At Fire Safety Risk Assessment, our 2026-compliant assessments protect your property, your occupants, and your legal position. Contact us today for a free, no-obligation quote — and let our certified team ensure you are fully compliant with every change UK fire safety law brings in 2026.
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Updated for April 2026 PEEP Regulations · BS 9792:2025 Compliant · All Property Types
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Trusted Fire Risk Assessment specialists serving Birmingham, Manchester, West Midlands, Warrington, and across the UK. FSRA provides fully compliant Fire Risk Assessments, Asbestos Surveys, and Legionella Risk Assessments to help businesses and landlords protect people, property, and meet legal obligations.