Direct answer
Most small blocks still need the relevant fire risks assessed
The Fire Safety Order applies to the common parts of buildings containing domestic premises. The Fire Safety Act 2021 clarified that, for a building containing two or more sets of domestic premises, the Order also reaches the building’s structure, external walls and doors between domestic premises and common parts.
Government has published a dedicated guide for small blocks, confirming that responsible persons must carry out and record a fire risk assessment. A building being low rise, containing only owner-occupiers or having fewer than six flats does not by itself remove that duty.
Assessment boundary
What is—and is not—normally within the FRA
The Fire Safety Order generally does not apply inside an individual flat used only as a private domestic dwelling. Its residential-building scope includes relevant common parts and building-wide elements. Separate housing, lease and landlord duties can apply inside flats.
The assessment should define the actual boundary instead of assuming that “no hallway” means “nothing to assess”. External access, structure, walls, balconies, service routes and doors may still be relevant, depending on the arrangement.
| Area or element | Typical Fire Safety Order position | Questions to establish |
|---|---|---|
| Communal hall, landing or stair | Normally within the common-parts assessment scope. | Are escape, lighting, doors, storage and maintenance suitable? |
| Structure and external walls | Within scope for a building containing two or more domestic premises. | Is construction understood and are alterations, balconies or wall systems relevant? |
| Flat entrance doors opening onto common parts | Within scope; responsibility for maintenance may depend on control and agreements. | Who inspects, repairs and records the doors and self-closing devices? |
| Inside a private flat | Generally excluded from the Fire Safety Order domestic-premises scope. | What separate housing, alarm, tenancy or lease duties apply? |
| Separate external entrances or open-air access | May reduce common-area scope but does not automatically remove every building element from consideration. | Is there shared structure, an external wall, balcony, escape route, plant or another controlled area? |
Who must arrange it
Owner-occupiers can still share a responsible organisation
The responsible person may be the freeholder, resident management company, right-to-manage company, housing provider, landlord or another person with control. A managing agent can perform tasks, but its appointment does not automatically transfer every legal duty away from the owner or management body.
Where the leaseholders collectively own the freehold, the company or other entity through which they control the building may hold the duty. The residents living in their own flats does not turn the whole building into a single private home.
Freeholder
May control the structure, common parts and building-wide precautions.
Resident management or RTM company
May control maintenance and fire-safety arrangements under its legal and contractual role.
Managing agent
May carry out defined functions and can have duties to the extent of its control.
Leaseholders and tenants
May hold responsibilities for particular doors or actions under leases, tenancies or actual control.
Arrangement matters
Purpose-built, converted and maisonette arrangements need different judgement
Government’s entry-level small-block guide is limited to purpose-built blocks, or blocks converted in accordance with the 1991 or later Building Regulations, of no more than three storeys and normally no more than six flats, designed around a stay-put strategy. Buildings outside that description need the more detailed applicable guidance and suitable competence.
Older conversions can have uncertain compartmentation, shared escape, doors and service penetrations. A small converted house may therefore require more investigation than a larger modern purpose-built block. The number of flats alone is a poor measure of complexity.
- Confirm whether the block is purpose-built or converted and when work was completed
- Identify every internal, external or open-air route used to reach safety
- Establish the intended evacuation strategy rather than inventing one from the building’s size
- Check compartmentation, flat entrance doors, service penetrations and roof-space separation
- Record balconies, external-wall materials, bin stores, meters, plant and charging risks
- Use housing-specific guidance and competence where the small-block guide does not fit
Below 11 metres
A low-rise block is not outside fire-safety law
Some duties in the Fire Safety (England) Regulations 2022 apply only when a residential building reaches specified heights. For example, additional routine checking requirements apply to certain fire doors in buildings over 11 metres. Other duties apply more broadly to buildings containing two or more domestic premises.
These thresholds change the package of additional measures; they do not switch off the requirement for the responsible person to assess relevant fire risks, maintain precautions and keep the assessment under review.
Before requesting help
Information that helps define the assessment scope
A useful initial enquiry can be brief. Give the building arrangement, tenure, control and reason for asking. An assessor can then confirm what additional records or access are needed before quoting.
Do not describe only the number of flats. Two four-flat buildings can have very different risk because one is a modern purpose-built block while the other is an older conversion with a shared staircase and uncertain fire separation.
- Full address, number of flats, storeys and approximate age
- Purpose-built or converted status and date of conversion if known
- Shared internal areas, external balconies, stairs and separate entrances
- Freeholder, management company, managing agent and maintenance responsibilities
- Existing FRA, plans, fire-door records and known alterations or defects
- Any request from an insurer, lender, council, agent, buyer or other party