Concise answer
Does a commercial landlord need a fire risk assessment?
A commercial landlord or freeholder can be a responsible person for common parts, building systems, vacant areas and other matters within its control. The employer or commercial tenant will commonly be responsible for its workplace, employees, activities and areas it controls. More than one responsible person can therefore exist in the same building.
The correct assessment arrangement depends on the premises, leases, management structure and control exercised in practice. Commissioning an assessor or appointing a managing agent does not automatically transfer the landlord’s legal duties, and a tenant FRA should not be assumed to cover landlord-controlled areas or shared systems.
Identify control
Map ownership, leases, service obligations, retained areas and the authority exercised in practice.
Define assessment boundaries
State whether the instruction covers the whole building, common parts, vacant units, one demise or several connected reports.
Coordinate dutyholders
Exchange relevant findings and building information with employers, tenants, managers and contractors.
Fund and verify action
Allocate operational and capital work, apply interim controls and retain suitable completion evidence.
Landlord and tenant duties
Separate contractual responsibility without separating the fire risk
Lease clauses, service agreements and fit-out licences can help explain who maintains or alters a part of the building. Fire-safety duties still depend on the statutory rules and actual control. Asset managers should not treat a repairing covenant or tenant obligation as evidence that the relevant risk has been assessed and managed.
Build a responsibility schedule for every multi-occupied asset and give it to the assessor. Where responsibilities overlap, the responsible persons must cooperate and coordinate rather than allow a gap between documents.
| Area or measure | Typical landlord or asset question | Tenant or occupier interface |
|---|---|---|
| Common stairs and final exits | Who controls capacity, condition, security and maintenance? | Do tenant occupancy and local routes rely on the shared provision? |
| Building fire alarm | Who owns, maintains and manages faults, zones and cause-and-effect? | Are local warning, audibility, staff response and tenant devices coordinated? |
| Fire separation | Who controls structure, risers, shafts, common doors and base-build fire stopping? | Who approves and verifies tenant partitions, doors and penetrations? |
| Emergency arrangements | Who coordinates reception, building evacuation, assembly and system impairments? | How does each employer’s plan connect with the building strategy? |
| Plant and firefighting facilities | Who maintains smoke control, sprinklers, lifts, risers and access? | Do tenant works or storage affect those systems and routes? |
| Remedial actions | Who can authorise common-parts or capital work? | Which actions sit inside a tenant’s control and how is completion reported? |
Portfolio assurance
Create one portfolio programme without applying one generic assessment
A portfolio programme can standardise property data, assessor appointments, report structure, action governance and management reporting. Every asset still needs an appropriate premises-specific scope, inspection, findings, limitations and review record.
Prioritisation should reflect risk and evidence rather than asset value or geography alone. Missing or doubtful FRAs, sleeping or vulnerable occupants, complex multi-occupation, significant changes, incidents, enforcement concerns and overdue high-priority actions should be visible to the people setting the programme.
- Maintain an asset register with address, use, height, storeys, floor area and occupancy
- Record ownership, responsible persons, managing agent, facilities team and tenant contacts
- Record the current FRA date, scope, limitations, review status and open actions
- Flag multi-tenant, mixed-use, tall, fire-engineered and unusually complex assets
- Record significant fire-door, compartmentation, alarm and evacuation concerns separately
- Prioritise missing evidence, material changes, incidents and overdue life-safety actions
- Set consistent reporting, escalation, quality-assurance and document-naming requirements
- Track each asset separately even when one provider assesses the wider portfolio
Acquisition and disposal
Use fire-safety information to understand an asset—not to promise an outcome
During acquisition, refinancing, leasing or disposal, existing FRAs and fire-safety records can reveal scope limitations, open actions and areas requiring further investigation. A vendor report may be useful evidence, but it may not reflect the proposed ownership, occupation, control arrangements or current condition.
The asset team should distinguish document review from a new site assessment and from specialist due diligence. A standard life-safety FRA may identify the need for separate fire-door, compartmentation, alarm, external-wall, structural or fire-engineering work without determining every defect or capital cost.
Check scope and age
Confirm the premises, areas, dutyholder and conditions assessed—not only the report date.
Reconcile actions
Establish which actions remain open, who owns them and whether completion evidence is reliable.
Test change
Compare the report with current tenants, layout, systems, occupancy and proposed use.
Record limitations
Identify inaccessible areas, missing construction information and specialist work still required.
Asset change
Connect leasing, fit-out and void management to FRA review
Tenant churn and building work can change escape, occupancy, warning, fire separation and emergency arrangements. Asset approvals should require enough fire-safety information to decide whether the FRA, fire strategy and other documents need review before or after work and before occupation.
| Asset event | Questions to resolve | Assessment implication |
|---|---|---|
| New lease or occupier | Use, occupancy, hours, hazards, fit-out and areas of control | Review whether landlord and tenant assessment scopes remain suitable |
| CAT A or CAT B fit-out | Partitions, doors, ceilings, alarms, sprinklers, escape and penetrations | Review the completed workplace and affected building arrangements |
| Vacant unit or floor | Security, contents, utilities, detection, work and effect on occupied areas | Include relevant void risks and shared-system interfaces |
| Change of use | People, activities, sleeping risk, capacity and building strategy | Obtain competent advice and reassess the altered risk |
| Building works | Temporary routes, isolations, hot work, contractors and fire stopping | Apply construction controls and review the occupied premises as necessary |
| Management handover | Documents, contacts, actions, defects, contracts and interim measures | Verify continuity rather than accepting an incomplete data-room transfer |
Comparable quotations
Give assessors a commercial property brief they can price properly
For one building, define the ownership and occupation, areas in scope, shared systems, access, existing evidence and reason for the instruction. For a portfolio, provide a structured property schedule and ask providers to state assumptions, site attendance, exclusions and pricing rules against the same information.
The lowest headline price may represent a narrower scope, shorter visit or different deliverable. Confirm whether the quotation includes document review, occupied and vacant areas, photographs, action planning, quality assurance, report clarification, travel and VAT.
- Address, use, floors, approximate size, occupancy and tenant count
- Landlord, tenant, manager and facilities areas of control
- Existing FRA, fire strategy, plans, action plan and known limitations
- Shared alarms, escape routes, fire doors, compartmentation and specialist systems
- Acquisition, lease, fit-out, insurer, lender, review or enforcement context
- Required access to tenant areas, voids, basements, roofs, plant and service rooms
- Report format, action allocation, portfolio identifiers and required delivery date
- Named assessor, competence evidence, insurance and comparable commercial experience
Actions and capital planning
Turn assessment findings into governed operational and capital work
An asset-level FRA is not complete in practical terms when the report is filed. Actions should enter a controlled register with a clear risk priority, accountable owner, target date, interim controls and evidence standard. The asset manager should be able to distinguish a new finding, commissioned investigation, approved budget, completed work and verified closure.
Some findings need specialist investigation before the right scope or cost is known. Avoid closing an FRA action only because a quotation was obtained or a contractor attended. The required fire-safety outcome and any effect on the assessment should be confirmed.
Operational work
Allocate housekeeping, records, training, local management and routine maintenance to the controlling team.
Capital work
Separate design, investigation, approval, procurement, installation and verification milestones.
Tenant action
Issue relevant findings with a defined outcome, evidence requirement and escalation route.
Portfolio reporting
Show overdue priority, interim measures, dependencies and residual uncertainty—not only completion percentages.
Asset records
Keep a decision trail that survives changes in owner, agent and occupier
Commercial property teams change. Maintain an asset fire-safety record that allows a new owner, asset manager, managing agent or facilities team to understand the current assessment, material risks, open actions, system impairments and recent decisions without reconstructing them from email chains.
- Current assessment, review decisions and superseded-report history
- Responsible-person, tenant, manager and emergency contacts
- Fire strategy, plans, system information and relevant change records
- Action register, approvals, interim measures and completion evidence
- Specialist surveys, limitations and areas requiring further investigation
- Incident, enforcement, insurer and relevant authority correspondence
- Fit-out approvals, penetrations, commissioning and handover information
- Handover sign-off for changes in ownership, management or occupation
Competence and appointment
Match assessor competence to the most complex commercial asset
Ask who will inspect and write each report, how competence is allocated across the portfolio and how complex or unusual assets will be escalated. Relevant experience may include multi-tenant offices, mixed-use buildings, tall commercial premises, engineered strategies, extensive fit-outs or buildings with specialist systems.
BAFE SP205 can provide evidence about an organisation’s life-safety FRA process, while NFRAR records individually assessed fire risk assessors and their displayed competency level. Check both where relevant, then verify current status, insurance, assignment-specific experience and the written scope.
Named people
Identify the assessor, report author, validator and any proposed substitutions.
Asset matching
Route each building according to occupancy, construction, systems and management complexity.
Quality assurance
Understand technical review, factual corrections, escalation and consistency controls.
Clear deliverables
Confirm inspection, evidence review, limitations, findings, actions and post-report support.