When Is a FRAEW Required? (Fire Risk Appraisal of External Walls)

A FRAEW (Fire Risk Appraisal of External Walls) is a risk-based fire safety appraisal of a building’s external wall system carried out in accordance with PAS 9980:2022. It is used to determine whether cladding, insulation or other façade components present a life safety risk and whether proportionate remediation or interim measures are required.

Understanding when a FRAEW is required is critical for building owners, Responsible Persons, managing agents, and developers — particularly in the wake of the Fire Safety Act 2021 and ongoing regulatory scrutiny of external wall fire risk.

In this guide, we explain the key triggers for when a FRAEW should be commissioned, how risk drives the decision (rather than height alone), and what factors assessors use to determine the need for appraisal.

Quick Answer: When Is a FRAEW Required?

A FRAEW is required where external wall systems in a multi-occupied residential building may present a life safety risk. This typically includes buildings with cladding, combustible insulation, or façade systems that could contribute to fire spread. The requirement is risk-based under PAS 9980 and UK fire safety legislation, not determined by height alone.

What Does “Required” Really Mean?

A FRAEW is not an automatic statutory requirement for every building. Instead, it becomes necessary when risk indicators suggest that external wall construction may affect life safety.

This reflects the UK legal framework, where the Regulatory Reform (Fire Safety) Order 2005 places a duty on the Responsible Person to ensure fire risks — including those from external walls — are identified and mitigated so far as is reasonably practicable. The Fire Safety Act 2021 clarifies that external walls, cladding, balconies and attachments fall within the scope of that duty.

PAS 9980 requires a structured evaluation of both the likelihood of fire spread over the external wall and the potential consequences for occupants. A FRAEW becomes necessary where external wall risk cannot be reasonably discounted through available documentation review or non-intrusive inspection.

PAS 9980 requires assessors to consider both the probability of external fire spread and the consequences for occupants, including the effectiveness of evacuation strategy (such as stay-put or simultaneous evacuation), the reliability of compartmentation and the potential for rapid vertical fire spread via façade systems.

PAS 9980 applies specifically to existing multi-occupied residential buildings in England.

In practical terms, a FRAEW is required where external wall construction could materially affect life safety, including evacuation strategy, compartmentation integrity, or rapid fire spread across façades — not simply because a building exceeds a particular height threshold.

What Types of Buildings Does FRAEW Apply To?

FRAEW is primarily relevant to existing multi-occupied residential buildings where external wall systems could affect life safety.

This typically includes:

• Blocks of flats
• Purpose-built apartment buildings
• Multi-occupied residential buildings with shared escape routes
• Residential buildings where external walls form part of compartmentation strategy

FRAEW is not generally required for:

• Single private dwellings
• Small low-rise buildings without external wall systems of concern
• Commercial-only buildings (unless residential elements are present)

The requirement is driven by risk and occupancy type, not simply building height.

Key Factors That Trigger a FRAEW

Here are the main situations where competent practitioners will typically recommend or require a FRAEW:

1. Presence of Cladding or Composite Facades

Buildings with cladding or composite wall systems — particularly those with combustible components — have an elevated potential for fire spread. Where such systems are present, a FRAEW helps determine whether that risk is significant and what actions are required.

2. Buildings with Combustible Insulation

Certain types of insulation materials are more likely to contribute to rapid fire spread. If insulation in the external wall is not clearly non-combustible or fire-tested, this is a trigger for FRAEW — even if the cladding itself is compliant.

3. Fire Risk Assessment Identifies External Wall Concerns

A competent fire risk assessment may flag external wall systems as a potential risk influencing life safety. In these cases, a FRAEW is the logical next step to investigate façade performance more deeply.

Fire risk assessors should refer to PAS 9980 when deciding whether external wall risk requires formal appraisal.

External wall systems are typically considered with reference to Approved Document B, which sets out fire performance expectations under the Building Regulations in England.

4. Enforcement or Regulatory Direction

Fire and Rescue Authorities or Building Control may require a FRAEW where external wall risk is identified during inspection, audit or enforcement activity. This is particularly common where external wall concerns intersect with means of escape or compartmentation.

5. Post-Legislative Clarification and Industry Guidance

Following the Fire Safety Act 2021, responsibility for external walls is clearly within fire safety legislation’s scope. Professional guidance (including PAS 9980) now explicitly considers external wall fire risk as part of a suitable and sufficient risk assessment where relevant.

Common Misconception: Height Alone Doesn’t Trigger FRAEW

Many stakeholders assume that external wall appraisal is automatically required above a certain building height (for example, 11m or 18m). In practice:

• FRAEW is risk-driven, not height-driven.
• Height can be an indicator of greater consequence, but it is not the sole determinant.
• The actual decision should consider façade design, materials, occupancy, evacuation complexity and risk to life safety.

That said, buildings over 18 metres with cladding or complex façades are much more likely to require a FRAEW because the potential consequences of fire spread are higher.

Practical Example

For example, a 12-metre residential building with combustible insulation and poorly detailed cavity barriers may require a FRAEW, while a 20-metre building constructed entirely with non-combustible materials and robust compartmentation may not.

The decision depends on façade construction, materials, and life safety impact — not height alone.

Other Situations Where FRAEW May Be Recommended

Change of Use or Major Alteration

If a building undergoes a significant change of use, occupancy or structural modification — particularly affecting external walls — a new appraisal should be considered.

Sale or Transfer of a Residential Building

While distinct from EWS1 forms (which support lending/valuation), a FRAEW may be recommended during due diligence if façade fire risk is present — particularly where lenders or purchasers express concern.

EWS1 is governed by lender and valuation protocols, as outlined in RICS EWS1 guidance, and serves a different purpose to FRAEW.

Periodic Re-evaluation of Façade Performance

External walls can change over time due to:

• Maintenance issues
• Remedial works elsewhere
• Material degradation
• New attachments or alterations

If any of these occur, a FRAEW can help reassess risk.

Who Decides Whether a FRAEW Is Required?

The decision should be made by a competent professional with:

• Knowledge of PAS 9980 methodology
• Understanding of façade fire performance
• Experience with external wall systems and fire dynamics
• Access to relevant construction information

This may include fire engineers, façade consultants or specialist fire risk assessors with external wall expertise.

Importantly, the Responsible Person remains legally accountable for ensuring the correct appraisal is carried out where required.

How a FRAEW Requirement Is Evidenced

A competent FRAEW report should clearly explain:

• Why an appraisal was deemed necessary
• What construction features or materials triggered the requirement
• What methodology was used (e.g. PAS 9980)
• What the risk outcome was
• What actions or measures are recommended

Clear documentation helps demonstrate that the Responsible Person has taken reasonable steps to assess and manage fire risk, which is critical in enforcement or audit situations.

Professional FRAEW Support

At Fire Risk Assessment Network, we provide PAS 9980-aligned FRAEW services across the UK. Our specialists help duty holders understand when an appraisal is required, how risk is assessed and what actions can reduce life safety risk. Contact us today for expert guidance and a free quotation.

Our FRAEW appraisals are aligned with PAS 9980 and current UK fire safety legislation.

Conclusion

A FRAEW is required when external wall systems pose a potential life safety risk — not simply because of building height or typology.

Key triggers include:

• Cladding or combustible façade materials
• Insulation that may contribute to fire spread
• Fire risk assessment findings
• Regulatory or enforcement direction
• Changes to building use or structure

Because FRAEW is risk-based and tied to life safety outcomes, the decision to commission one should always be evidence-led and aligned with current UK fire safety legislation and PAS 9980 methodology.

Frequently Asked Questions

When is a FRAEW required?

A FRAEW (Fire Risk Appraisal of External Walls) is required when external wall systems may present a life safety risk. This typically includes buildings with cladding, combustible insulation, or façade systems that could contribute to fire spread. The decision is risk-based and aligned with PAS 9980 guidance rather than determined by height alone.

Is a FRAEW legally required in the UK?

The term FRAEW does not appear directly in legislation. However, under the Regulatory Reform (Fire Safety) Order 2005, as clarified by the Fire Safety Act 2021, Responsible Persons must assess fire risks relating to external walls where they may affect life safety. In many buildings, this requires a formal FRAEW carried out in accordance with PAS 9980.

Does building height automatically require a FRAEW?

No. FRAEW is risk-driven rather than height-driven. Although buildings over 11 metres or 18 metres are more likely to require appraisal due to the potential consequences of façade fire spread, the need for FRAEW depends on façade construction, materials used and life safety impact — not height alone.

Who decides whether a FRAEW is necessary?

A competent professional with knowledge of PAS 9980 and external wall fire performance should determine whether a FRAEW is necessary. This may include a fire engineer, façade specialist or suitably experienced fire risk assessor. The Responsible Person remains legally accountable for ensuring appropriate appraisal is undertaken.

What triggers the need for a FRAEW?

Common triggers include the presence of cladding systems, combustible insulation, concerns raised during a fire risk assessment, enforcement action by authorities, or significant changes to building use or structure. A FRAEW is typically commissioned where these factors indicate potential external wall fire risk.

Is FRAEW the same as an EWS1?

No. FRAEW is a life-safety fire appraisal carried out in accordance with PAS 9980 to assess external wall fire risk for compliance purposes. EWS1 is a lender-driven form used to support mortgage and valuation decisions. They serve different purposes and are not interchangeable.

What happens if a FRAEW identifies significant risk?

If a FRAEW identifies significant risk, the Responsible Person must record findings, prioritise actions, implement proportionate control measures and integrate the outcome into the building’s fire risk assessment. Clear documentation and evidence of decision-making are essential to demonstrate compliance.