How to Build a Fire Risk Assessment Action Plan

A fire risk assessment is only as effective as the action plan that follows it. While the Regulatory Reform (Fire Safety) Order 2005 requires a “suitable and sufficient” fire risk assessment, enforcement action most commonly arises not because an assessment is missing — but because its findings have not been properly implemented.

This guide explains how to build a structured, defensible fire risk assessment action plan that prioritises risk, assigns responsibility and demonstrates compliance.

If you require support developing or implementing an action plan, contact us for a free, no-obligation quotation.

Why an Action Plan Matters

Under Articles 8 and 9 of the Fire Safety Order, the Responsible Person must:

• Take general fire precautions
• Implement appropriate protective measures
• Maintain systems and equipment
• Keep arrangements under review

An assessment identifies risk.

An action plan controls it.

A “paper FRA” that is not implemented is a common enforcement failing.

Step 1: Extract All Significant Findings

A compliant fire risk assessment must record significant findings where required.

Your action plan should capture:

• Fire door defects
• Alarm coverage gaps
• Emergency lighting deficiencies
• Compartmentation breaches
• Inadequate evacuation procedures
• Training gaps
• Housekeeping concerns
• Contractor control weaknesses

Avoid rewriting the whole assessment. Extract the actions into a structured tracking document.

It is important to distinguish between a “finding” and an “action”. A finding describes the deficiency (for example, “Fire door to stairwell does not self-close”). The action defines what must be done (“Adjust or replace self-closing device and confirm compliance”). Clear wording prevents ambiguity and improves accountability.

Step 2: Categorise Actions by Risk Level

Prioritisation must be risk-based.

Most competent assessors will assign risk ratings such as:

• High risk – Immediate action required
• Medium risk – Action required within defined timeframe
• Low risk – Improvement recommended

High-risk issues typically include:

• Compromised escape routes
• Inoperative alarm systems
• Missing fire doors on protected routes
• Significant compartmentation failure

Your action plan should clearly distinguish urgency.

Step 3: Assign Responsibility

Every action must have:

• A named responsible person
• A target completion date
• A tracking status

Common failures include:

• “Maintenance team” assigned without accountability
• No deadline
• No progress tracking

Responsibility should sit with someone who has authority to implement change.

Step 4: Define Clear Timescales

There is no statutory fixed timeframe for completing actions, but delays must be reasonable and proportionate to risk.

Typical practical benchmarks:

• High risk → Immediate or within days/weeks
• Medium risk → Within 1–3 months
• Low risk → Planned within budget cycle

If delays occur, document the rationale.

Where immediate rectification is not possible, interim control measures should be considered. For example, increased monitoring, temporary fire wardens, restricted access or additional detection may reduce risk while permanent works are arranged. Failure to implement interim controls for high-risk issues may attract enforcement attention.

Step 5: Record Evidence of Completion

Inspection authorities will examine evidence.

Your action plan should include:

• Completion date
• Contractor certificates
• Photographic evidence
• Updated maintenance logs
• Sign-off confirmation

Without evidence, enforcement authorities may treat the action as incomplete.

Step 6: Integrate Into Routine Fire Safety Management

An action plan is not a one-off document.

It should align with:

• Weekly alarm testing
• Monthly emergency lighting checks
• Fire door inspection regimes
• Contractor permit systems
• Staff training schedules

Under Article 11 of the Fire Safety Order, the Responsible Person must establish appropriate fire safety arrangements. An action plan forms part of those arrangements.

Step 7: Monitor and Review Progress

The fire risk assessment must be kept under review.

Your action plan should include:

• Regular review meetings
• Progress updates
• Escalation procedures for overdue actions
• Governance reporting (where applicable)

Recurring defects may indicate systemic management issues.

Common Mistakes in Fire Risk Assessment Action Plans

• Generic spreadsheets without context
• No prioritisation
• No named responsibility
• No evidence tracking
• Actions closed without verification
• Long-term actions left open indefinitely

These weaknesses frequently appear in enforcement cases.

Action Plans in Multi-Tenant or Residential Buildings

In shared premises:

• Responsibilities may be split between landlord and tenant
• Managing agents may coordinate implementation
• Facilities managers may deliver operational measures

The Fire Safety Order requires duty holders to cooperate and coordinate.

Your action plan should clearly define who is responsible for each action in shared buildings.

Risk-Based Approach to Action Planning

Risk level should reflect:

• Likelihood of fire
• Consequence of fire
• Occupant vulnerability
• Building complexity
• Means of escape quality

Higher-risk buildings (sleeping accommodation, care settings, high-rise residential) require faster implementation and more frequent monitoring.

Digital vs Manual Action Tracking

Modern compliance systems often use:

• Digital dashboards
• Centralised document management
• Automated reminders
• Escalation alerts

Manual spreadsheets can work — but must be actively managed.

Consistency and audit trail are more important than format.

What Happens If You Don’t Implement Actions?

Failure to implement significant findings may result in:

• Enforcement Notices
• Prohibition Notices
• Criminal prosecution
• Unlimited fines
• Reputational damage

Breach of the Fire Safety Order is a criminal offence.

Under Article 32 of the Fire Safety Order, failure to comply with duties may result in prosecution. Enforcement authorities frequently examine whether known risks identified in an assessment were left unaddressed.

Enforcement commonly focuses on whether known risks were ignored.

Example Fire Risk Assessment Action Plan Structure

A clear action plan typically includes the following columns:

• Reference number
• Description of deficiency
• Risk rating
• Recommended action
• Responsible person
• Target completion date
• Status (open / in progress / closed)
• Evidence reference
• Completion date

Consistency in structure improves clarity and defensibility.

Fire Risk Assessment Action Plan – Quick Checklist

A compliant action plan should:

• Capture all significant findings
• Prioritise actions based on risk
• Assign named responsibility
• Set realistic deadlines
• Record evidence of completion
• Be reviewed regularly
• Integrate with wider fire safety management

If these elements are present, your action plan is far more likely to withstand inspection.

Conclusion

A fire risk assessment identifies risk — but it is the action plan that demonstrates compliance.

Building a structured, risk-based and evidence-backed action plan is essential for meeting your duties under the Regulatory Reform (Fire Safety) Order 2005. Whether you are a landlord, facilities manager, managing agent or Responsible Person, implementation is the point at which fire safety becomes real.

At Fire Risk Assessment Network, we support organisations across the UK not only in delivering compliant fire risk assessments, but in structuring practical, defensible action plans that stand up to inspection.

If you require support developing or implementing your fire risk assessment action plan, contact our team today.

If your current action plan lacks structure, prioritisation or evidence tracking, we can help review and strengthen your existing arrangements.

Frequently Asked Questions

Is a Fire Risk Assessment Action Plan a Legal Requirement?

The law requires the Responsible Person to implement appropriate fire safety measures and act on the significant findings of a fire risk assessment. While the Fire Safety Order does not prescribe a specific “action plan format”, failure to address identified risks may result in enforcement action. In practice, a structured action plan is essential to demonstrate compliance.

How Long Do I Have to Complete Fire Risk Assessment Actions?

There is no fixed statutory timeframe. Actions must be completed within a reasonable period based on risk. High-risk deficiencies (such as compromised escape routes or inoperative fire alarms) require immediate attention. Lower-risk improvements may be scheduled within planned maintenance cycles, provided the delay is proportionate and documented.

Can I Prioritise Actions Based on Budget Constraints?

Cost does not remove legal responsibility. While scheduling and budgeting are practical considerations, risk level must determine priority. High-risk issues cannot be deferred solely for financial reasons. If delays occur, the rationale should be documented and interim risk control measures considered where appropriate.

What Evidence Should Be Kept When Closing an Action?

You should retain clear evidence that the issue has been properly resolved. This may include contractor certificates, photographs, updated maintenance records, invoices, commissioning documents or written confirmation of remedial works. Without evidence, enforcement authorities may treat the action as incomplete.

What Happens If Fire Risk Assessment Actions Are Overdue?

If significant findings are not implemented within a reasonable timeframe, the Responsible Person may be in breach of the Fire Safety Order. Enforcement authorities may issue Enforcement Notices or, in serious cases, pursue prosecution. Overdue high-risk actions present particular regulatory concern.

Who Is Responsible for Completing Actions in Multi-Tenant Buildings?

Responsibility depends on control of the premises. In multi-tenant or mixed-use buildings, landlords, managing agents and tenants may each have duties. The Fire Safety Order requires duty holders to cooperate and coordinate. An action plan should clearly allocate responsibility for each item.

Should Fire Risk Assessment Actions Be Reviewed Regularly?

Yes. The fire risk assessment must be kept under review, and the action plan should form part of that ongoing management process. Regular review meetings, progress tracking and escalation procedures help demonstrate effective fire safety arrangements under Article 11 of the Fire Safety Order.