Fire Risk Assessment for Managing Agents

If you are a managing agent in the UK, you are often responsible for day-to-day fire safety compliance in residential blocks and mixed-use buildings — and in many cases you may also be treated as the Responsible Person for the common parts.

Where the Regulatory Reform (Fire Safety) Order 2005 applies, it covers the common parts of multi-occupied residential buildings, and for shared areas the Responsible Person is commonly the landlord, freeholder or managing agent.

The law has also been strengthened in recent years, including clarification of duties in buildings containing flats via the Fire Safety Act 2021, and additional requirements affecting building management under the Building Safety Act 2022 (especially in higher-risk residential buildings).

This guide explains when a fire risk assessment is required for managing agents, how responsibility is allocated in shared premises, and what you should have in place to remain compliant.

If you need a compliant fire risk assessment anywhere in the UK, contact us for a free, no-obligation quotation.

Do Managing Agents Need a Fire Risk Assessment?

In most cases, yes — because managing agents typically manage common areas, and the Fire Safety Order applies to those shared parts of multi-occupied residential buildings.

However, the key legal question is not whether you are a managing agent — it is whether you have control of the premises (or common parts) and therefore have duties as the Responsible Person, or duties to cooperate with the Responsible Person.

When Is a Managing Agent the Responsible Person?

A managing agent is commonly treated as the Responsible Person where they have control of the common parts under a management agreement, or where the landlord/freeholder has delegated practical control of fire safety management to them.

Government guidance makes this explicit: for common or shared areas, the Responsible Person is likely to be the landlord, freeholder or managing agent.

In shared premises (for example, mixed-use blocks or buildings with multiple duty-holders), it’s also common for there to be more than one Responsible Person, and you must coordinate and cooperate to ensure the overall fire safety strategy works.

However, contractual delegation does not automatically remove legal responsibility. If practical control of fire safety management sits with the managing agent, enforcement authorities may treat the agent as the Responsible Person in respect of those duties. Clear allocation of responsibilities within the management agreement is essential.

What Parts of the Building Does the Fire Risk Assessment Cover?

For managing agents, the fire risk assessment usually covers the common parts, including (where present):

• Entrance lobbies and reception areas
• Stairwells, corridors and escape routes
• Risers, plant rooms and service cupboards
• Communal lounges, bin stores and cycle stores
• Dry risers, wet risers and firefighting shafts (where applicable)

In buildings containing flats, the scope has been clarified further in recent years, including elements such as flat entrance doors and (in relevant contexts) external wall considerations as part of fire safety responsibilities for the building.

What Is a Managing Agent’s Legal Duty Under the Fire Safety Order?

Under Article 8 and Article 9 of the Fire Safety Order, the Responsible Person must take general fire precautions and carry out a “suitable and sufficient” fire risk assessment, keeping it under review where necessary.

In practical terms, managing agents should ensure that:

• Fire risks are identified and reduced so far as reasonably practicable
• Escape routes and compartmentation are protected and kept clear
• Fire safety systems (alarms, emergency lighting, etc.) are maintained
• Routine checks, testing and servicing are planned and evidenced
• Actions from the fire risk assessment are tracked to completion

Maintaining a clear audit trail — including inspection records, contractor reports, and evidence of remedial works — is critical to demonstrating compliance if inspected by the Fire and Rescue Authority.

Where required, the significant findings of the assessment must be recorded (for example, where five or more employees are employed, where the premises are licensed, or where an inspector requires it).

Fire Safety (England) Regulations 2022: Extra Duties Managing Agents Must Deliver

For multi-occupied residential buildings in England, the Fire Safety (England) Regulations 2022 introduced additional requirements that often fall into the managing agent’s operational workload — particularly around resident information and fire door checks.

These requirements include (building-dependent):

• Providing residents with fire safety instructions (based on the building’s evacuation strategy)
• Providing information about the importance of fire doors and how residents should report faults
• Undertaking (or ensuring) routine checks for certain fire doors, and keeping records where appropriate

Because this guidance assumes an FRA is already in place, the fire risk assessment remains the foundation for deciding what checks and controls are suitable for the building.

Small Blocks of Flats: New Practical Guidance for Managing Agents

Government has also published additional practical guidance aimed at improving fire safety in small blocks of flats in England (for example, up to three storeys and up to six flats), intended to support agents, building managers and owners.

If you manage smaller blocks, this is a common inspection and enforcement focus area, and the fire risk assessment should reflect the realities of the building’s layout, escape routes, and fire safety provisions.

What Happens If a Managing Agent Does Not Comply?

If a managing agent is the Responsible Person (or acting on their behalf) and fire safety duties are not met, enforcement action may include:

• Alterations Notice
• Enforcement Notice
• Prohibition Notice
• Criminal prosecution and unlimited fines

Government guidance highlights that Responsible Persons must coordinate in shared premises — and enforcement bodies can act where risks are not managed properly.

In addition, insurers may refuse to honour claims if a required fire risk assessment was not in place or was clearly inadequate, exposing freeholders, managing agents and clients to substantial financial loss following a serious incident.

What Type of Fire Risk Assessment Do Managing Agents Need?

The right assessment depends on the building type, complexity and risk profile, but common scenarios include:

• Communal fire risk assessment for blocks of flats (purpose-built or converted)
• Mixed-use building assessment where there are commercial units beneath residential floors
• HMO common parts assessment (where a managing agent has control)
• Higher-risk / complex building assessments where additional competence and deeper inspection are required

Good assessments follow a structured approach aligned with established practice and ensure actions are clear, prioritised and trackable.

How Often Should a Managing Agent Review the Fire Risk Assessment?

There is no fixed statutory interval, but the assessment must be reviewed where necessary — particularly when:

• There are material alterations or refurbishment works
• The building layout or occupancy changes
• A fire occurs (or a significant near miss)
• Fire safety systems change (alarms, doors, emergency lighting, etc.)
• New risks are identified or previous controls prove ineffective

In practice, many managing agents schedule at least an annual review alongside routine compliance cycles.

Managing Agent Fire Risk Assessment – Quick Compliance Summary

If you control (or manage) the common parts of a building containing flats, you are likely to have fire safety duties under the Fire Safety Order — and you may be the Responsible Person for shared areas.

Your fire risk assessment should be current, suitable and sufficient, and supported by evidence of maintenance, checks, and action tracking. In England, additional duties introduced by the Fire Safety (England) Regulations 2022 commonly fall into managing agent workflows, particularly resident information and fire door-related requirements.

How Much Does a Fire Risk Assessment for Managing Agents Cost?

The cost of a fire risk assessment depends on the size, layout and complexity of the building. A small, low-risk block with simple escape routes is typically quicker to assess than a mixed-use building, a complex conversion, or a larger block with higher-risk features.

Factors affecting cost include:

• Number of storeys and stair cores
• Number of flats / occupants
• Mixed-use or commercial units
• Complexity of escape routes
• Fire door numbers and condition
• Presence of external wall systems (where relevant)
• Existing fire safety provisions and maintenance history

Managing agents should be cautious of unusually low-cost assessments, as enforcement cases often reveal generic or copied reports that do not meet the “suitable and sufficient” standard.

For an accurate quotation, contact us for a free assessment proposal.

Why Professional Assessment Matters for Managing Agents

Managing agents are often judged not only on whether an assessment exists, but on whether the building is being actively managed in line with it. Common failings identified across industry guidance include:

• Generic risk assessments not tailored to the building
• Unclear action plans with no ownership or deadlines
• Poor fire door condition and weak inspection records
• Blocked escape routes or poor housekeeping
• Inadequate resident communication under England Regulations

A competent, building-specific assessment gives you a defensible baseline and a clear plan of action.

Contact Fire Risk Assessment Network

We provide:

• Fully compliant fire risk assessments across the UK
• Experienced, qualified fire safety professionals
• Clear, prioritised action plans
• Fast turnaround times
• Competitive pricing

We work with portfolio managing agents, resident management companies and national property managers, providing consistent reporting formats and clear prioritisation to support portfolio-wide compliance.

If you are a managing agent and need a compliant fire risk assessment, contact us for a free, no-obligation quotation.

Conclusion

Managing agents are frequently at the centre of fire safety compliance for residential buildings, particularly where they manage or control common parts. Under the Fire Safety Order, a suitable and sufficient fire risk assessment must be in place and kept under review, and in England additional duties introduced by the Fire Safety (England) Regulations 2022 often form part of day-to-day building management.

At Fire Risk Assessment Network, we work with managing agents, freeholders and resident management companies across the UK to deliver compliant, building-specific assessments with clear action plans. If you need support, speak to our team today.

Frequently Asked Questions

Are Managing Agents Legally Responsible for Fire Safety?

Managing agents are often responsible for delivering fire safety management in practice and may be treated as the Responsible Person where they control the common parts of a building. Government guidance states that for shared areas in multi-occupied residential buildings, the Responsible Person is commonly the landlord, freeholder or managing agent. Responsibility depends on who has control under the management agreement.

Do Managing Agents Need a Fire Risk Assessment for Blocks of Flats?

Yes. The Regulatory Reform (Fire Safety) Order 2005 applies to the common parts of buildings containing flats. Where a managing agent controls those areas, a suitable and sufficient fire risk assessment must be in place and kept under review. This typically includes stairwells, corridors, entrance halls and plant rooms.

What Is the Legal Basis for a Fire Risk Assessment?

Article 9 of the Regulatory Reform (Fire Safety) Order 2005 requires the Responsible Person to carry out a suitable and sufficient assessment of fire risks. The assessment must identify hazards, evaluate risk, implement appropriate precautions and be reviewed where necessary.

What Additional Fire Safety Duties Apply in England?

The Fire Safety (England) Regulations 2022 introduced additional requirements for multi-occupied residential buildings in England. These include providing residents with fire safety information and, in certain buildings, carrying out and recording fire door checks. Managing agents commonly oversee these operational duties.

How Often Should a Managing Agent Review a Fire Risk Assessment?

There is no fixed statutory review period. However, a fire risk assessment must be reviewed if there are material alterations, changes in occupancy, significant changes to fire safety measures, or following a fire. Many managing agents adopt an annual review cycle as best practice.