Fire Safety Documentation Required for New Developments
New developments require a growing body of fire safety documentation at planning, building control and BSR gateway stages.
24 September 20244 min readFire Safety Services
Fire Safety Documentation Requirements for New Developments
New residential and commercial developments require a growing body of fire safety documentation at planning, building control, and — for higher-risk buildings — Building Safety Regulator gateway stages. Understanding what is required, when, and by whom is essential for developers, architects, and project managers to programme and budget accurately and to avoid delays at regulatory checkpoints.
At Planning Stage
Fire safety documentation requirements at planning stage depend on building type and location:
Gateway 1 fire statement — required for all higher-risk buildings (over 18 metres or seven storeys with at least two residential units) as part of the planning application. The HSE is a statutory consultee and will raise objections where the fire statement is inadequate.
London Plan Policy D12a fire statement — required for major applications in Greater London involving buildings of ten storeys or more, or buildings classified as higher risk under the Building Safety Act 2022. The GLA scrutinises D12a statements for major applications referred to them.
Heritage fire statement — some local planning authorities require a fire safety statement for applications involving listed buildings or development in conservation areas, addressing how fire safety will be balanced with heritage protection.
At Building Control / Gateway 2
For higher-risk buildings, the Building Safety Regulator Gateway 2 submission must include comprehensive fire safety documentation. For other buildings, the building control submission requires sufficient fire safety information to demonstrate compliance with Part B of the Building Regulations:
Fire strategy report — the core fire engineering document setting out the escape strategy, compartmentation, structural fire protection, detection and alarm, suppression systems, smoke control, and firefighting facilities
Fire door schedule — listing all fire doors in the building with their required fire resistance rating, leaf configuration, ironmongery specification, and any special requirements
Fire stopping specification — details of how all service penetrations through compartment walls and floors will be fire stopped
External wall fire safety statement — for buildings over 18 metres, confirmation that external wall materials comply with regulation 7(2), or fire engineering justification for any derogations
Sprinkler design basis — for buildings requiring sprinkler systems, the design basis document prepared by the sprinkler designer and referenced in the fire strategy
For Gateway 2, the BSR will not start its 8-week assessment clock until all required documentation is submitted in full. Incomplete submissions are returned and the clock restarts. Comprehensive, well-prepared submissions save significant programme time.
At Handover / Gateway 3
At practical completion and handover, the following fire safety documentation must be produced and handed over to the building owner or accountable person:
As-built fire strategy — updated to reflect any changes made during construction, forming the baseline fire safety record for the building
Operation and maintenance manuals — covering all fire safety systems including detection, suppression, smoke control, and emergency lighting
Fire door completion certificates — confirming that fire doors have been installed in accordance with the specification
Fire stopping completion records — photographic and written records confirming that all fire stopping has been installed correctly
Commissioning certificates — for all fire safety systems
Ongoing Documentation During Occupation
Once occupied, a building's fire safety documentation does not become static. Fire risk assessments must be carried out and reviewed regularly, maintenance and testing records must be kept, and the fire strategy must be updated whenever significant changes are made to the building. For higher-risk buildings, all this documentation forms part of the building safety case and the golden thread of information that accountable persons must maintain.
Frequently Asked Questions
What fire safety documents are needed for a planning application?
For higher-risk buildings, a Gateway 1 fire statement is required. For major applications in Greater London involving buildings of ten or more storeys, a London Plan Policy D12a fire statement is required. For other buildings, fire safety information may be requested by the planning authority as a condition.
Who produces the fire strategy for a building control submission?
The fire strategy must be produced by a competent fire engineer appointed by the developer. For higher-risk buildings, the lead fire engineer should hold Chartered Engineer status. Building control will not produce the fire strategy — they assess the submitted strategy for compliance.
What is a fire door schedule?
A fire door schedule is a document, typically produced by the fire engineer or architect, listing all fire doors in a building with their location, required fire resistance rating, leaf configuration, glazing specification, ironmongery, and any special requirements. It is a key deliverable at RIBA Stage 4.
How long should fire safety records be kept?
Under the RRO, fire safety records must be kept for at least 3 years. Under the Building Safety Act 2022, the golden thread of building information for higher-risk buildings must be maintained throughout the building's life.
What happens to fire safety documentation when a building is sold?
Fire safety documentation — particularly the fire strategy, fire risk assessment, and maintenance records — must be transferred to the new owner as part of the building handover. For higher-risk buildings, the golden thread of information must be maintained and transferred when ownership changes.
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