How Often Does a Fire Risk Assessment Need to Be Reviewed or Updated?

This is the single most misunderstood point in fire safety compliance. Two beliefs are common and both are wrong:

• "It lasts twelve months and then expires."
• "We had one done so we are covered."

Neither reflects the law. The correct position is that a fire risk assessment has no fixed expiry date but it carries a continuing duty to review and certain events trigger that duty immediately.

What the law says

Article 9(3) of the Regulatory Reform (Fire Safety) Order 2005 requires that the assessment:

must be reviewed by the responsible person regularly so as to keep it up to date and particularly if there is reason to suspect that it is no longer valid or there has been a significant change in the matters to which it relates, including where the premises, the special, technical and organisational measures or the organisation of the work undergo significant changes, extensions or conversions.

Where the review shows changes are needed, the responsible person must make them.

Note what that provision does and does not do. It does not set an interval. It sets a standard: the assessment must remain valid. If it has stopped reflecting your building, your occupancy or your management arrangements, it has failed that standard, whether it is eleven months old or three weeks old.

Since 1 October 2023, Article 9(6) also requires you to make a record of the review, not just the original assessment. A review that leaves no documentary trace is difficult to evidence.

What the standards say

Both current codes of practice treat the review date as part of the assessment itself.

PAS 79-1:2020 and BS 9792:2025 each set out a nine-step assessment process and in both, the ninth and final step is to determine the date by which the assessment is to be reviewed. BS 9792:2025 states directly that the documented assessment should record the date by which it is to be subject to review.

In other words: an assessment that does not tell you when to look at it again is incomplete. If your current report has no review date, that is a defect in the report.

So how often, in practice?

There is no single right answer and any assessor who gives you one without seeing the building is guessing. That said, established practice across the sector runs broadly as follows.

Suggested review intervals by risk

Two clarifications because the terms get used loosely.

A review is a check that the existing assessment remains valid: has anything changed, has the action plan been completed, are the management arrangements still in place. It is often desktop work supported by a shorter site visit.

A reassessment is a fresh assessment carried out from first principles, producing a new report.

Reviewing annually and reassessing periodically is the pattern most enforcing authorities, insurers and auditors expect to see. Where a building is stable, well managed and low risk, longer intervals between full reassessments can be justified, provided the justification is recorded.

Note also that insurers, lenders, licensing authorities and some framework contracts routinely impose their own intervals, most commonly annual. Those are contractual obligations rather than statutory ones but they bite just as hard.

The triggers that require a review regardless of date

This is the part that matters most. Whatever your scheduled interval, the following should prompt a review straight away.

Changes to the building

• Any structural alteration, extension or conversion
• Internal reconfiguration: new partitions, removed walls, altered corridors
• New or altered service penetrations through fire-resisting construction
• Change to escape routes, exits or staircases
• Installation, alteration or removal of fire doors
• Works to external walls, cladding, balconies, insulation or render
• New or altered heating, ventilation or electrical installations
• Solar panels, battery energy storage or electric vehicle charging points

Changes to how the building is used

• Change of use or change of use of any part
• A significant increase or decrease in occupancy
• New processes, machinery or equipment
• Introduction or increase of flammable liquids, gases or combustible dusts
• Change in storage arrangements, quantities or stock height
• Change from daytime-only to overnight occupancy
• Subdivision or new tenancies in a multi-let building

Changes to the people

• Occupants with mobility, sensory or cognitive impairments now present
• Changes to care provision in supported or sheltered housing
• Lone working arrangements introduced
• Significant staff turnover, particularly among fire wardens, nominated persons and management
• New shift patterns or out-of-hours working

Events

• A fire however small. Including one extinguished with a portable extinguisher.
• A near miss. A pan fire, an electrical fault, a smouldering event, arson.
• A pattern of unwanted fire signals from the alarm system
• Failure of a fire protection system: alarm, emergency lighting, sprinkler, smoke control
• Findings from a fire door survey or compartmentation survey that contradict assumptions in the assessment
• An inspection by the fire and rescue authority, an insurer or an auditor
• Service of an alterations, enforcement or prohibition notice

External changes

• New or amended legislation
• New or revised guidance and British Standards
• New information about the building's construction, for example from an external wall appraisal or intrusive survey
• A change in the responsible person, the owner, the managing agent or the freeholder

That last one is regularly overlooked. When a new managing agent takes over a block or a business acquires new premises, the existing assessment does not transfer as a clean bill of health. It is a document produced for someone else, based on assumptions the new duty holder has not verified.

Common mistakes

Treating the review as a renewal. Reprinting last year's report with a new date on the front is not a review and it is transparent to anyone auditing it.

Reviewing the report but not the action plan. If the previous action plan is still 60% outstanding, that is the finding. BS 9792:2025 specifically expects a review to record actions identified previously that had not been carried out.

Not recording the review. Since October 2023 the record requirement applies to reviews as well as assessments.

Assuming a Type 1 covers works inside flats. If intrusive works have been carried out in dwellings, a Type 1 assessment of the common parts has not looked at them.

Waiting for the anniversary after a significant change. The duty under Article 9(3) is triggered by the change, not the calendar.

What we recommend

For most Liverpool duty holders, a defensible approach looks like this:

1. Ensure the current assessment carries an explicit review date, as both PAS 79-1:2020 and BS 9792:2025 require.
2. Diarise a formal annual review, recorded in writing.
3. Maintain a standing instruction to your management team that any of the trigger events above prompts a review, regardless of the diary.
4. Schedule a full reassessment at an interval proportionate to the risk, typically every one to three years.
5. Track the action plan continuously, not annually. Enforcement officers ask about outstanding actions before anything else.

Frequently asked questions

Does a fire risk assessment expire after 12 months? No. There is no statutory expiry date. The duty is to keep it up to date, which for most premises means an annual review and a periodic full reassessment.

Is an annual fire risk assessment a legal requirement? Not in itself. Article 9(3) requires regular review, without specifying an interval. Annual review is widely accepted best practice and is frequently imposed as a condition by insurers, lenders and licensing authorities.

What is the difference between a review and a new assessment? A review checks whether the existing assessment remains valid and whether actions have been completed. A reassessment is a fresh assessment producing a new report. Both must be recorded.

We have had a small fire. Do we need a new assessment? You need at least a review and the fire itself is evidence relevant to it. A fire of any size indicates that either a hazard was not controlled or a control failed and the assessment should say which.

Our building has not changed at all. Do we still need to review? Yes. Occupancy, management arrangements, staff, guidance and legislation all change even when the building does not. A review can conclude that the assessment remains valid but that conclusion needs to be reached and recorded.