---
title: "Fire Risk Assessments for Blocks of Flats: Legal Duties for RMC and RTM Directors"
url: https://manage.management/blog/fire-risk-assessments-for-blocks-of-flats-legal-duties-for-rmc-and-rtm-directors
description: "Fire risk assessments for blocks of flats: who the responsible person is, how often to review, fire door checks over 11m and the 2022 Regulations."
author: "Franklin Baeza"
published: 2026-11-10T06:33:37.000Z
updated: 2026-11-10T07:38:20Z
categories: ["Maintenance & Safety","Governance & Compliance"]
publisher: Manage.Management
language: en-GB
---

# Fire Risk Assessments for Blocks of Flats: Legal Duties for RMC and RTM Directors

Fire risk assessments for blocks of flats: who the responsible person is, how often to review, fire door checks over 11m and the 2022 Regulations.

Every block of flats in England with shared common parts must have a suitable and sufficient fire risk assessment under article 9 of the Regulatory Reform (Fire Safety) Order 2005, and since 1 October 2023 the whole assessment must be recorded in writing. The duty falls on the "responsible person", which for a resident-led block is usually the RMC or RTM company. If the top storey is more than 11 metres above ground, the Fire Safety (England) Regulations 2022 add quarterly checks of communal fire doors and best-endeavours annual checks of flat entrance doors.

This guide sets out who the responsible person is, what the assessment must cover, how often to review it and which extra duties apply as a block gets taller. It is written by Manage.Management, the UK block management platform for RTM and RMC directors, leaseholders and managing agents, and covers the law in England.

## Key takeaways

- The responsible person for the common parts, usually the freeholder, RMC or RTM company, must carry out and regularly review a fire risk assessment.
- Since 16 May 2022, the assessment must cover the building's structure, external walls including balconies, and flat entrance doors.
- Since 1 October 2023, the full assessment, the fire safety arrangements and the name of the assessor must be recorded.
- The law sets no fixed review period; Home Office guidance says an annual review is good practice for small and simple premises.
- Blocks over 11 metres need fire door checks, and high-rise blocks of 18 metres or seven storeys need plans, a secure information box and monthly equipment checks.

## Who is the responsible person in a block of flats?

The responsible person is whoever controls the common parts in connection with a business or undertaking, or otherwise the owner. In a self-managed block, that is usually the RMC or RTM company, and the directors make sure the company meets the duty.

[Article 3 of the Fire Safety Order](https://www.legislation.gov.uk/uksi/2005/1541/article/3) defines the responsible person for non-workplace premises as the person in control "in connection with the carrying on by him of a trade, business or other undertaking (for profit or not)", or the owner where that person does not exist. A not-for-profit RMC or RTM company running the common parts is an undertaking for this purpose. A managing agent with contractual control can also carry duties, but appointing an agent does not remove the company's own responsibility.

The flats themselves are outside the Order. It applies to the common parts: stairs, corridors, plant rooms, bin stores and, since the Fire Safety Act 2021, the structure, external walls and flat entrance doors. If your block is also a higher-risk building, you have separate duties as an accountable person, covered in our guide to [accountable persons for RMC and RTM directors](https://manage.management/blog/building-safety-act-accountable-persons-what-rmc-and-rtm-directors-are-responsible-for).

## What must a fire risk assessment cover?

It must identify fire hazards and the people at risk, assess the risk and set out the precautions needed, and it must now cover the structure, external walls and flat entrance doors as well as the common parts.

[Section 1 of the Fire Safety Act 2021](https://www.legislation.gov.uk/ukpga/2021/24/section/1), in force in England from 16 May 2022, added to article 6 of the Order that, where a building contains two or more sets of domestic premises, the Order covers "the building's structure and external walls and any common parts" and "all doors between the domestic premises and common parts". External walls include windows, doors and anything attached to them, including balconies.

A typical assessment for a block of flats looks at:

- ignition sources such as electrical installations, communal heating and stored items in escape routes
- the evacuation strategy, whether "stay put" or simultaneous evacuation
- compartmentation, fire doors and self-closers
- emergency lighting, signage, smoke ventilation and any alarm system
- the external walls and any combustible cladding or balconies
- residents who may need help to escape

Under [article 9](https://www.legislation.gov.uk/uksi/2005/1541/article/9), the responsible person must record "the findings of the assessment" and any group identified as especially at risk. The word "significant" was removed by the Building Safety Act 2022 from 1 October 2023, so the whole assessment must now be written down, not just the main findings.

## How often must a fire risk assessment be reviewed?

The law requires a review "regularly" and whenever the assessment may no longer be valid or something significant changes, but it sets no fixed period. Home Office guidance says an annual review is good practice for small and simple premises, and the assessor should set a review date.

The [Home Office guide for persons with duties under fire safety legislation](https://www.gov.uk/government/publications/people-with-duties-under-fire-safety-laws/a-guide-for-persons-with-duties-under-fire-safety-legislation-accessible) says the Order "does not specify the frequency with which fire risk assessments should be reviewed" and that "for small and simple premises, an annual review is recognised as good practice". A review is not always a full new assessment. It can confirm that earlier actions were completed, that nothing material has changed and that fire doors and other measures still work.

Trigger a review sooner after a fire, major works, a change to the evacuation strategy, new information about the external walls, or a significant change in who lives in the building. Our guide to [planned preventive maintenance for leasehold blocks](https://manage.management/blog/planned-preventive-maintenance-a-guide-for-leasehold-blocks) shows how to fit review dates into the block's yearly calendar.

## What extra duties apply as a block gets taller?

The duties step up at two heights: above 11 metres, and at 18 metres or seven storeys. Every block with common parts has some duties under the Fire Safety (England) Regulations 2022, in force since 23 January 2023.

| Building | Duty under the Fire Safety (England) Regulations 2022 | How often |
| --- | --- | --- |
| All blocks with two or more flats and common parts | Give residents fire safety instructions, including the evacuation strategy and how to report a fire | On moving in, then at least every 12 months |
| All blocks with two or more flats and common parts | Give residents information on fire doors: keep them shut, do not tamper with closers, report faults | On moving in, then at least every 12 months |
| Top storey above 11 metres | Check all communal fire doors, including self-closers | At least every 3 months |
| Top storey above 11 metres | Use best endeavours to check flat entrance doors and record attempts to gain access | At least every 12 months |
| High-rise: 18 metres or 7 storeys | Floor plans and a single-page building plan sent electronically to the fire and rescue service | Update when the layout changes |
| High-rise: 18 metres or 7 storeys | Record of external wall design and materials sent to the fire and rescue service | Update after significant changes |
| High-rise: 18 metres or 7 storeys | Secure information box with the responsible person's details and plans | Inspect at least annually |
| High-rise: 18 metres or 7 storeys | Wayfinding signs showing floor and flat numbers | Maintain and check regularly |
| High-rise: 18 metres or 7 storeys | Checks of firefighting lifts, rising mains, smoke control and alarm systems; report faults not fixed within 24 hours | Monthly |

The fire door wording comes from [regulation 10](https://www.legislation.gov.uk/uksi/2022/547/regulation/10), and the high-rise duties are summarised in the Home Office guide to [fire safety responsibilities under the 2022 Regulations](https://www.gov.uk/government/publications/check-your-fire-safety-responsibilities-under-the-fire-safety-england-regulations-2022/check-your-fire-safety-responsibilities-under-the-fire-safety-england-regulations-2022). The guidance says the fire door checks are visual and can be done by a caretaker, managing agent or director with suitable instruction, without a specialist.

## What must be recorded and shared with residents?

Since 1 October 2023, the responsible person must record the full assessment, the fire safety arrangements and the name of anyone who carried out or reviewed the assessment, and must share key fire safety information with residents.

The Home Office guidance on [section 156 of the Building Safety Act 2022](https://www.gov.uk/government/publications/check-your-fire-safety-responsibilities-under-section-156-of-the-building-safety-act-2022/fire-safety-responsibilities-under-section-156-of-the-building-safety-act-2022) lists the duties. In a block of flats, residents must be given the risks identified in the assessment, the preventive and protective measures, the name and UK address of the responsible person, and the identity of any assessor. When a block changes hands or management passes to an RTM company, the outgoing responsible person must pass on all relevant fire safety information.

Store the assessment, door check records and service certificates where every director can find them. The [Manage.Management building safety tracker](https://manage.management/features/building-safety) holds fire risk assessments and certificates with reminders for review dates, and its document vault keeps the history in one place when directors change.

## How should RMC and RTM directors manage the process?

Appoint a competent assessor, act on the findings within the timescales given, and keep a dated record of every action. These steps work for most low and medium-rise blocks.

1. Confirm who the responsible person is and record the company's name and UK address.
2. Measure or confirm the height of the top storey, so you know whether the 11-metre and 18-metre duties apply.
3. Appoint a fire risk assessor with suitable training and experience, and record their name and organisation.
4. Give the assessor plans, the previous assessment, service records and any external wall reports.
5. Turn the action plan into dated tasks, with an owner for each, and budget for the work in the service charge.
6. Issue fire safety instructions and fire door information to every resident, then repeat them every 12 months.
7. Diary fire door checks every three months for communal doors and every 12 months for flat entrance doors if the block is over 11 metres.
8. Set the next review date and add it to the block calendar.

Fire safety works paid through the service charge may need consultation. If the cost of a qualifying works project exceeds £250 for any one leaseholder, follow our [Section 20 consultation checklist](https://manage.management/blog/section-20-consultation-a-step-by-step-checklist-for-blocks). For routine tasks, our [building maintenance schedule template](https://manage.management/blog/building-maintenance-schedule-template-for-blocks-of-flats) gives a ready list.

## What happens if the responsible person gets it wrong?

Fire and rescue authorities enforce the Order and can issue enforcement or prohibition notices. Failing to comply in a way that puts people at risk of death or serious injury is a criminal offence under article 32, with up to two years in prison on indictment.

Under [article 32](https://www.legislation.gov.uk/uksi/2005/1541/article/32), the offence carries a fine on summary conviction and, on indictment, a fine or imprisonment for up to two years, or both. For volunteer directors, the practical protection is a current assessment, completed actions and a record showing what was done and when.

## Frequently asked questions

### Do small blocks of flats need a fire risk assessment?

Yes, if the building has two or more flats and shared common parts such as a staircase or hallway. The Fire Safety Order applies to the common parts of every such block in England, whatever its height. A converted house with two flats and no shared escape route may fall outside the 2022 Regulations, but most blocks with a communal entrance and stairs are covered and need a written assessment.

### Can an RMC director carry out the fire risk assessment?

In principle, yes, but only if they have enough training and experience or knowledge to do it properly. Home Office guidance offers a checklist for small blocks of flats, but most RMC and RTM companies appoint a professional assessor. Whoever does it, the company must record the assessor's name and, where relevant, their organisation, and share that identity with residents under the 2023 changes.

### Do leaseholders have to let the responsible person check their flat entrance door?

The 2022 Regulations require the responsible person to use best endeavours to check flat entrance doors every 12 months in blocks over 11 metres, and to record attempts to gain access. The Regulations themselves do not force entry. Most leases give the landlord or management company a right of access on notice, so directors should give notice in writing and offer a range of times.

### Who pays for a fire risk assessment in a block of flats?

Usually the leaseholders, through the service charge, if the lease allows the cost of complying with statutory obligations or managing the common parts to be recovered. The cost must be reasonable under section 19 of the Landlord and Tenant Act 1985. Remedial works that follow, such as replacing fire doors, may also be recoverable, subject to Section 20 consultation and the building safety leaseholder protections.

### Is a fire risk assessment the same as an external wall assessment?

No. A fire risk assessment covers the whole building's fire risk, including the external walls since 2022, but it may recommend a separate specialist appraisal of the external walls, known as an FRAEW. That appraisal looks in detail at cladding, insulation and balconies. In high-rise blocks, the responsible person must also send a record of the external wall design and materials to the fire and rescue service.

## A written assessment and a dated record

For RMC and RTM directors, fire safety compliance comes down to a current, written fire risk assessment, completed actions and records you can produce on request. Check your building's height, diary the reviews and door checks, and share the right information with residents every year.

Last reviewed: 10 November 2026 by Franklin Baeza, Manage.Management. This article is general information for England and Wales, not legal advice. Check the current position with a qualified adviser before acting.

---

Source: [Fire Risk Assessments for Blocks of Flats: Legal Duties for RMC and RTM Directors](https://manage.management/blog/fire-risk-assessments-for-blocks-of-flats-legal-duties-for-rmc-and-rtm-directors) on the Manage.Management blog.