The FRAEW waiting game is over: What September's guidance means for you

New government guidance and a revised PAS 9980 have removed the main reason for putting off external wall appraisals. Here is what changed, which buildings it affects, and the one question to ask of every block you manage.

Two publications, one message

On 14 September 2026, the Ministry of Housing, Communities and Local Government published consolidated guidance on fire risk appraisals of external walls (FRAEWs). It is aimed squarely at building owners, landlords, managing agents, responsible persons and residents, and covers when an FRAEW may be needed, how to commission one, what a good report looks like and how findings feed into wider fire safety management.

At the same time, BSI republished the technical standard behind these appraisals. PAS 9980:2026 replaces PAS 9980:2022 as the code of practice assessors must follow. BSI describes the revision as clarifying the methodology, streamlining the content and reflecting industry developments. Government guidance is clear that it gives a more structured process but does not significantly change how risk is assessed.

Taken together, these two publications remove a defence quietly relied upon across the sector for several years: that the position was too uncertain, the methodology too contested, or the guidance too thin to justify acting. That argument has now run out of road.

Height is not the filter many assume

One of the most important clarifications concerns which buildings are in scope. An FRAEW may be needed for blocks of flats of any height, not only high-rise or medium-rise. Portfolios that have treated three- and four-storey blocks as out of scope should be reviewed.

Equally, the guidance does not suggest every block needs one. Buildings with traditional brick or masonry walls are generally lower risk, and the FRA will often provide enough information. But the construction must be confirmed as brick or masonry, rather than brick slip over combustible insulation, for example. An assumption drawn from a visual inspection at ground level is not confirmation.

New buildings should comply with current Building Regulations, including the ban on combustible materials in the external walls of relevant buildings. They should not normally need an FRAEW on completion. But later changes can alter the picture: façade alterations, overcladding, balcony replacements and insulation upgrades can all create a need for an update.

What the outcome actually tells you

A PAS 9980 appraisal gives one of four outcomes, based on the likelihood and consequences of fire spreading via the external walls and the proportionality of reducing risk further:

• Low: the walls are unlikely to contribute to external fire spread. No remediation needed.
• Tolerable: some risk exists, but spread would be limited and/or suitable mitigation keeps residents safe. No remediation needed.
• Medium: further assessment, mitigation or remediation is needed to reach an acceptable level of risk.
• High: significant risk of rapid fire spread and compromised escape. Remediation is strongly recommended.

The outcome isn’t a score. It depends on professional judgement about the building’s design, how it’s occupied and the fire safety measures already in place. Visual tools such as risk matrices should support that judgement, not substitute for it.

The point owners most often miss is that “low” and “tolerable” are real outcomes, requiring no remediation work. A well-conducted FRAEW often confirms that a building is safe, and PAS 9980:2026 allows for shorter reports where walls are expected to perform well. The appraisal is as likely to close the question as to open it.

Already have an FRAEW?

An FRAEW completed by a competent assessor under PAS 9980:2022 remains valid until it’s due for review. There’s no need to commission a new one just because the standard has been revised. A new appraisal is usually needed only if the external walls change, or a later FRA recommends one.

The one question to ask of every block

Does the current fire risk assessment recommend an FRAEW, and if so, has one been carried out?

building’s external walls, and where it finds concerns, its action plan must recommend an FRAEW. So, where the answer is yes and no, you have an outstanding action in your own compliance records, visible to any enforcing authority.

Commissioning an FRAEW is not an admission that a building is unsafe. It’s how you find out, how you show you’ve met your duties, and how you avoid paying for remediation that a proportionate assessment would never have called for.