How the Fire Safety Act 2021 Now Hits Every Multi-Occupied Deal

If you manage a building that isn't a single-family home, the Fire Safety Act 2021 now applies to you. Not just high-rise residential. Not just blocks over 18 metres. Every multi-occupied building in England and Wales. Hotels. Student accommodation. Offices with shared common areas. Mixed-use developments. The extension came into full force in October 2023, and enforcement is picking up speed.

What the Fire Safety Act 2021 Actually Changed

The Act amended the Regulatory Reform (Fire Safety) Order 2005. It did two things. First, it made clear that the Responsible Person must assess and manage fire risks in the building's structure, external walls, and common parts — including balconies and cladding. Second, it extended this duty to all multi-occupied residential buildings, not just those over 18 metres.

For commercial and hospitality buildings, the change is less about new legal duties and more about scope. The Fire Safety Order already applied to most non-domestic premises. But the Act clarified that the Responsible Person's duties include the building fabric and any flat entrance doors. That matters for hotels with residential-style suites and for mixed-use buildings where commercial and residential spaces share a structure.

The practical effect: your fire risk assessment now needs to cover the external wall system, the structure itself, and any common areas more thoroughly than before. If your last assessment only looked at escape routes and fire alarms, it is no longer sufficient.

Who Is the Responsible Person Now

The Act did not change who holds responsibility. The Responsible Person is still the employer, the owner, or the person with control of the premises. For a hotel, that is typically the operator or the owner. For a multi-let office building, it is the landlord or managing agent. For a purpose-built student block, it is the management company.

What changed is the scope of what they must manage. The Responsible Person must now ensure that the fire risk assessment covers the building's structure and external walls, including any cladding, balconies, and windows. They must also manage the risk of fire spread between units. That means knowing what materials are on the outside of your building and what fire-stopping is in place between floors and compartments.

If you manage a building built before 2000, this is where the work starts. Many older buildings have cavity barriers that were never properly installed or have been compromised by later works. A fire risk assessor who knows the Act will look for these.

What This Means for Hotels and Hospitality

Hotels have always been subject to fire safety regulation. But the Act brings a sharper focus on the building fabric. For a 280-room hotel in central London, that means the fire risk assessment must now explicitly consider the external wall system. If the hotel has had a recent refurbishment that added cladding or changed the facade, the assessor needs the specification and certification for those materials.

It also means flat entrance doors within the hotel — for example, in a serviced apartment wing — are now explicitly within scope. The Responsible Person must ensure these doors are fire-resisting and self-closing. That is not new best practice. It is now a legal requirement under the Fire Safety Order as amended.

For hotel chief engineers, the practical impact is straightforward. You need to check that your fire risk assessment has been updated since October 2023. If it has not, instruct your fire risk assessor to review it against the Act's requirements. You also need to ensure that any records of fire door inspections, compartmentation surveys, and external wall assessments are current and accessible.

Enforcement Is Real and Growing

Local fire and rescue authorities enforce the Fire Safety Order. They can issue prohibition notices, alteration notices, and enforcement notices. They can also prosecute. Since the Act came into force, enforcement activity has increased. In 2024, several local authorities in London and the South East issued prohibition notices for buildings where fire risk assessments did not meet the new standard.

The most common failings so far: inadequate compartmentation, missing or defective fire doors, and external wall systems that the Responsible Person could not document. In one case, a 12-storey hotel in Manchester received an enforcement notice because the fire risk assessment had not been reviewed since 2019 and did not consider the external wall system at all.

If you receive an enforcement notice, you have a legal duty to comply within the timeframe specified. Failure to do so is a criminal offence. The maximum penalty is an unlimited fine and, in serious cases, imprisonment.

What a Compliant Fire Risk Assessment Looks Like Now

A compliant fire risk assessment under the Fire Safety Act 2021 must include:

• An assessment of the building's structure, including fire resistance of walls, floors, and ceilings
• An assessment of the external wall system, including cladding, insulation, balconies, and windows
• An assessment of flat entrance doors (in residential and hotel settings)
• An assessment of common areas, including corridors, stairwells, and lobbies
• A clear record of who the Responsible Person is and what their duties are
• A clear record of any fire safety deficiencies and a plan to address them

The assessment must be carried out by a competent person. That means someone with sufficient training, experience, and knowledge of the building type and the relevant regulations. For complex buildings — high-rise hotels, large mixed-use developments, buildings with unusual cladding — the assessor should have specific competence in fire engineering or building pathology.

If your current fire risk assessment does not cover all of these points, it is not compliant. You need a new one.

Where to Start

First, check the date of your last fire risk assessment. If it is older than 12 months, or if it was completed before October 2023, instruct a competent fire risk assessor to review it against the Fire Safety Act 2021. Second, gather your building documentation: external wall specifications, fire door inspection records, compartmentation surveys, and any records of recent refurbishment works. Third, if you find gaps, create a plan to address them. Prioritise life safety issues — defective fire doors, missing compartmentation, combustible cladding — and set a timeline for remediation.

If you manage multiple buildings, this is a lot of paperwork. That is where a platform like Herman helps. Herman tracks compliance documents, flags expiring assessments, and lets you ask questions about your building's fire safety status in plain English. No spreadsheets. No chasing PDFs. Just a single view of what is compliant and what needs attention.

See how Herman handles compliance tracking at hermanwa.com.

— The HermanWa Team