Because compliance isn’t about paperwork; it’s about proof.
The Building Safety Act 2022 has fundamentally reshaped how property owners and managers approach fire risk. For Higher-Risk Buildings (HRBs) – those over 18 metres or seven storeys containing residential units – the era of basic, box-ticking Fire Risk Assessments is over.
The regulator now demands evidence; not just intention. And that means your Fire Risk Assessment (FRA) isn’t a form; it’s a foundation.
“Under the Building Safety Act, a Fire Risk Assessment must do more than identify hazards, it must prove control. The BSR wants justification, not just documentation.”
1.The Building Safety Act in Context
The Building Safety Act (BSA) creates a new, legally enforceable framework for the design, construction, and management of higher-risk buildings. It introduces new roles; including the Accountable Person (AP) and Principal Accountable Person (PAP), who are responsible for demonstrating that their building is safe to occupy and safe to stay in.
For these individuals, the Fire Risk Assessment has become a critical piece of evidence within the Safety Case Report, required to achieve a Building Assessment Certificate (BAC) from the Building Safety Regulator.
Key requirements under the BSA:
- Maintain a suitable and sufficient FRA, reviewed regularly and after material changes.
- Integrate the FRA into your Safety Case Report.
- Provide evidence of how fire risks are identified, assessed, and controlled.
- Ensure findings are managed through a competence-based, auditable system.
2. Where the Fire Risk Assessment Fits
A common misunderstanding is that the FRA is a standalone requirement. In reality, it’s the fire safety backbone of the Building Safety Act.
Below is the lifecycle flow every HRB must follow:
Design → Construction → Operation → Safety Case → BAC → Continuous Fire Risk Management
At each stage, the Fire Risk Assessment plays a different role:
| Stage | Fire Risk Assessment Purpose |
| Design | Verify that passive and active fire protection systems are built into plans. |
| Construction | Validate as-built specifications and identify changes that could affect fire integrity. |
| Operation | Conduct full FRA aligned to Building Safety Act and Fire Safety (England) Regulations 2022. |
| Safety Case | Use FRA data as key evidence for your Safety Case Report submission. |
| BAC | Demonstrate ongoing fire risk control to satisfy the Building Safety Regulator. |
| Continuous Management | Monitor, review, and evidence performance through digital systems like QUOODA®. |
3. What the BSR Expects from an HRB Fire Risk Assessment
The Building Safety Regulator expects FRAs for HRBs to show five things:
1). Clarity of Control: How each fire hazard is mitigated, who’s responsible, and how effectiveness is monitored.
2). Evidence of Competence: Proof that assessments were undertaken by qualified professionals.
3). Traceable Documentation: All findings and actions must be auditable.
4). Resident Consideration: Inclusion of Person-Centred Fire Risk Assessments (PCFRAs) and Personal Emergency Evacuation Plans (PEEPs).
5). Integration with the Golden Thread: All information must be digital, secure, and accessible.
Ark’s Fire Risk Assessments for Higher-Risk Buildings are designed around these five pillars; ensuring your FRA is not just compliant, but regulator-ready.
“Buildings that can demonstrate evidence of control, competence and traceability will achieve faster approvals and stronger insurance terms.”
4. Why HRB Fire Risk Assessments Must Go Beyond Compliance
Too many FRAs still focus on listing issues, not proving outcomes. The Building Safety Act demands a proactive, evidence-driven approach; where every risk identified is followed by a traceable action, completion record, and verification step.
The regulator doesn’t want to see what you know, they want to see what you’ve done about it.
That’s why many of our clients integrate their FRAs into QUOODA®, our digital risk, compliance and safety management platform. It links your fire risk data directly to actions, responsibilities, and audit trails; creating a live record of accountability.
Discover how digital fire risk management strengthens your Safety Case.
5. How Often Should HRB Fire Risk Assessments be Reviewed?
Under the Building Safety Act, FRAs for Higher-Risk Buildings must be:
- Reviewed annually or after significant works / occupancy changes.
- Updated immediately if new information indicates a change in risk.
- Digitally version-controlled within your golden thread.
Ark advises treating FRAs as living documents; reviewed, verified, and evidenced continuously, not just every 12 months.