The hidden cost of an expired EPC

Before Grenfell, a fire risk assessment for a small block of flats was often a half-day exercise resulting in a five-page report nobody read. After the Building Safety Act 2022, after Section 156 amendments to the Regulatory Reform (Fire Safety) Order, and after the regulator’s 2024 enforcement push, an FRA is something else entirely.

This is what a defensible FRA looks like in 2026, what changes by property type, and what the responsible person has to keep on record.

The responsible person

Article 3 of the Fire Safety Order names the “responsible person”. For a let property, that is whoever has control of the premises in connection with carrying on a trade, business or undertaking — in plain English, the landlord, agent or managing agent.

If the property is a HMO or a building containing two or more dwellings, there can be more than one responsible person. The Section 156 amendments now require those responsible persons to record who they are, what they are responsible for, and how they cooperate. The casual “our agent does it” is no longer enough.

PAS 79, in plain terms

PAS 79 is the publicly available specification that sets out a methodology for fire risk assessments. It does not have legal force, but courts and regulators treat it as the de facto standard. A FRA that does not follow PAS 79 (or PAS 79-2 for housing) is a FRA you have to defend.

Five things the methodology requires:

1. Identify hazards. Sources of ignition, sources of fuel, sources of oxygen.
2. Identify people at risk. Tenants, visitors, contractors, anyone with reduced mobility, anyone alone at night.
3. Evaluate, remove, reduce, protect. What is left after you have done what is reasonable.
4. Record, plan, train. The documentation, the emergency plan, the people who know what to do.
5. Review. At a stated interval, and after any material change.

An FRA that says “low risk, review in 12 months” without showing its working in those five steps is paperwork, not assessment.

Frequency by property type

The Order itself does not specify a frequency. The expectation in 2026 is:

• Single private let, two-storey. Annually, lighter touch. Smoke alarm tests, fire door checks if applicable, electrical sense-check.
• HMO (3+ unrelated occupants). Annually, full PAS 79.
• Block of flats (under 18m / under 7 storeys). Annually, with a more detailed assessment every three years, and a Type 1 (non-destructive) external review.
• Higher-risk building (18m+ or 7+ storeys, or care home, or hospital). Under the Building Safety Act regime: annual FRA, plus the building safety case held by the principal accountable person.

Crucially, “whenever there is a material change” means: a new tenant in a HMO, a fire incident anywhere on the property, a structural alteration, the replacement of a fire door, or any new significant fire load (a workshop set up in a garage, a large delivery of cardboard waiting in a hallway).

What “recorded” means now

Section 156 made record-keeping mandatory for all premises covered by the Order, not just non-domestic ones. The minimum record is:

• The significant findings of the FRA.
• Any actions taken or planned.
• The names of any individuals present in the assessment.
• The cooperation arrangements with other responsible persons.
• A current emergency plan and the means of its dissemination to those affected.

If a fire happens and a fatality follows, that record is the first thing the fire service’s investigators will request. A landlord who can produce it within an hour is in a different position to one who is forwarding emails to a former managing agent.

Self-assessment vs external assessor

For most simple single-let domestic properties, the responsible person can carry out the FRA themselves, provided they are competent. For HMOs, blocks and anything with shared escape routes, an external competent assessor is the realistic answer.

The assessor should be on a recognised register: BAFE SP205 or the Institution of Fire Engineers register are the two most commonly accepted. A “FRA” written by a generic surveyor without fire competence is a regulatory risk you do not want.

The administrative side

The thing that catches landlords out is not the assessment. It is the actions arising from it. A typical FRA produces five to fifteen actions, each with a target date. Six months later, half are done, two are scheduled, three are forgotten, and one was misunderstood.

That is where the platform comes in. Assigning each action to a person, tracking the close-out date, attaching evidence (a photo of the new fire door, the receipt for the smoke alarm replacement) and re-flagging at the next review.

Our property system handles FRA tracking, action assignment and evidence attachment as part of the standard compliance cycle. If you would like to see how your own portfolio looks under that lens, we are happy to take a look.