When Is a Fire Strategy Report Required Under UK Regulations?

The Regulatory Triggers for a Fire Strategy Report

A fire strategy report is required whenever a building project must demonstrate compliance with fire safety requirements to a statutory body. The specific trigger depends on the type of project, the building classification, and whether the project falls within the scope of the Building Safety Act 2022.

Understanding when a fire strategy is required — and commissioning it at the right stage — prevents costly delays at building control, planning, and Gateway 2 submissions to the Building Safety Regulator.

New Build Projects and Building Control

For new build projects, a fire strategy report is required as part of the building control submission. Building control bodies — whether local authority building control or an approved inspector — require evidence that the design meets the functional requirements of Part B of the Building Regulations (fire safety) before issuing building control approval.

The applicable code depends on building type. For residential buildings, BS 9991:2015 is the primary standard. For non-residential buildings, Approved Document B and BS 9999 apply. For higher-risk residential buildings over 18 metres, the Building Safety Regulator has additional requirements under the Building Safety Act 2022.

Higher-Risk Buildings and the Gateway Process

The Building Safety Act 2022 introduced a three-stage gateway process for higher-risk buildings — those over 18 metres in height or more than seven storeys, containing at least two residential units. All three gateways have fire strategy implications:

• Gateway 1 (Planning) — a fire statement must be submitted with the planning application. This is a high-level document demonstrating that fire safety has been considered in the design, that fire service vehicle access is achievable, and that the development can be built in accordance with fire safety principles.
• Gateway 2 (Pre-construction) — the Building Safety Regulator must approve detailed fire safety documentation before construction can commence. This includes a full fire strategy report. The BSR will not pass Gateway 2 without this document.
• Gateway 3 (Completion) — the fire strategy must be updated to reflect as-built conditions and submitted as part of the golden thread of building information.

London Plan Applications — Policy D12a

London Plan Policy D12a requires a fire safety statement to accompany planning applications for development in Greater London that involves a building of ten storeys or more, or any building that would be classified as a higher-risk building under the Building Safety Act 2022. This applies to applications submitted to the Greater London Authority as well as to local planning authorities within Greater London.

The fire safety statement must be produced by a suitably qualified fire engineer and must address fire service access, means of escape, and the overall fire safety strategy for the development.

Refurbishment, Change of Use and Retrospective Reports

A fire strategy report is also required for:

• Major refurbishment — any work that affects means of escape, fire compartmentation, structural fire protection or external wall construction
• Change of use — particularly where the new occupancy has different fire safety requirements from the previous use, such as converting offices to residential
• Retrospective reports for existing higher-risk buildings — buildings over 18 metres are required to register with the Building Safety Regulator and provide a building safety case. Where no fire strategy exists on record, a retrospective fire strategy must be produced.

When a Fire Strategy Is Not Required

Simple low-rise domestic extensions, like-for-like replacements of building elements, and minor fit-out works that do not affect fire safety provisions generally do not require a formal fire strategy report. However, a fire engineer should always be consulted if there is any doubt — the cost of a brief consultation is significantly less than the cost of a building control rejection or a redesign at an advanced stage.