How the Building Safety Act 2022 Changed Fire Strategy Requirements

The Building Safety Act 2022 represents one of the most significant shifts in fire and building safety legislation in a generation. Introduced in response to the Grenfell Tower tragedy, the Act aims to create a safer built environment through stronger regulations, clearer accountability, and better fire safety planning, particularly for higher-risk buildings.

For developers, landlords, managing agents, and dutyholders, the implications of the Act are wide-ranging. One key area affected is fire strategy documentation, which now plays a more central and legally accountable role in a building’s lifecycle.

In this article, we break down what the Building Safety Act 2022 means for fire strategies, who is affected, and how you can remain compliant under the new framework.

The Building Safety Act is a UK law passed to improve the design, construction, and occupation of buildings, particularly those classified as “higher-risk buildings” (HRBs). These are generally defined as:

• Residential buildings that are 18 metres or more in height, or
• Have 7 or more storeys, and
• Contain 2 or more residential units

The Act introduces new regulatory bodies, duties, and oversight mechanisms, including:

• The Building Safety Regulator (BSR), which oversees safety and performance
• The Accountable Person, responsible for building safety risks during occupation
• The requirement for a Safety Case Report for HRBs
• A Golden Thread of digital building safety information, including fire strategies

1. Fire Strategy Becomes a Core Compliance Document
Under the new regime, the fire strategy is no longer optional or static. It is now a central document in both the design and occupation phases. It must demonstrate how the building manages fire safety risks and how these risks are controlled over time.

The fire strategy must form part of the Golden Thread of information, meaning it must be:

• Up to date
• Accurate
• Accessible
• Digitally stored
• Maintained across the building’s lifecycle

What this means:
Developers and design teams must create high-quality, clear, and robust fire strategies during the planning and construction phases. Building owners and managing agents must maintain, update, and be able to produce them throughout the occupation phase.

2. Greater Scrutiny During Planning and Gateway Submissions
The Act introduces three key Gateways at which fire safety information must be submitted to the Building Safety Regulator:

• Gateway One: At planning application stage
• Gateway Two: Before construction begins (replaces Building Control sign-off)
• Gateway Three: Before occupation

At Gateway Two, a detailed fire strategy must be submitted alongside other safety documentation. This fire strategy must explain:

• Means of escape
• Compartmentation
• Detection and alarm systems
• Access for fire services
• Resident evacuation strategy
• Material fire performance

What this means:
You can no longer afford to treat fire strategy as an afterthought. It must be fully integrated into the design and be ready for submission during early-stage reviews.

3. Responsibility Falls on the “Accountable Person”
During the occupation phase of a building, the law introduces the role of the Accountable Person (or Principal Accountable Person if there is more than one). This person is legally responsible for managing building safety risks, including fire, and must:

• Prepare and maintain the building’s fire strategy
• Keep residents informed
• Submit a Safety Case Report to the BSR
• Cooperate with other responsible persons (e.g. fire risk assessors)

What this means:
Fire strategy is no longer just for engineers. Landlords, housing providers, and property managers must understand the fire strategy, ensure it remains up to date, and use it as a core reference point for ongoing safety management.

4. Fire Strategy Must Support the Safety Case Report
All higher-risk buildings must submit a Safety Case Report to the BSR, which demonstrates how building safety risks are being managed. The fire strategy is one of the foundational documents for this report.
It must show:

• Identified risks and how they’re mitigated
• Current fire systems and evacuation plans
• Design assumptions and how they are maintained in practice
• Interventions taken since the building was occupied

What this means:
If you don’t have a clear and professional fire strategy, you cannot complete your Safety Case Report—and may not be granted permission to legally occupy or manage the building.

5. Ongoing Fire Strategy Updates Are Now Mandatory
Gone are the days of “write it and file it.” The fire strategy must evolve with the building. If there are material changes, such as a refurbishment, layout modification, change of use, or updated fire systems—the fire strategy must be reviewed and updated accordingly.

What this means:
All building stakeholders must treat fire strategy as a living document. You need internal procedures to ensure it’s reviewed regularly and kept in sync with real-world building conditions.

The fire strategy changes under the Building Safety Act 2022 primarily apply to:

• Residential buildings over 18m or 7 storeys
• Multi-occupancy flats or apartment buildings
• Student accommodation
• Hospitals, care homes, and similar facilities (some exceptions may apply)
• New buildings, refurbishments, and existing stock

Even if your building doesn’t qualify as “higher risk,” the Act sets a new standard of due diligence that is quickly becoming best practice for all types of property.

At Fire Safety Services, we specialise in preparing and maintaining fire strategies that meet the highest standards of compliance. Our experienced fire engineers work with:

• Developers and design teams at planning stage
• Contractors during the construction phase
• Building owners and managers post-occupancy
• Housing associations and managing agents preparing for Safety Case Reports

We help ensure your fire strategy:

• Satisfies Gateway submissions
• Aligns with Building Regulations and Approved Document B
• Supports the Golden Thread
• Reduces the risk of enforcement or occupation refusal
• Protects residents and property

Don’t leave fire strategy to chance. Whether you’re at concept design, preparing for Gateway Two, or managing an occupied high-rise building, our expert team can guide you through the requirements of the Building Safety Act.

📧 Email: hello@fire-safety-services.co.uk
📞 Call 020 3797 3050 to speak with our fire consultants

Fire strategy isn’t just paperwork, it’s a critical compliance tool and a legal necessity. Let Fire Safety Services help you get it right.