The Consequences of Missing or Inadequate Fire Strategies

A surprising number of buildings — particularly those built or significantly refurbished before fire strategies became standard practice — have no fire strategy on record. For occupied existing buildings, this is a gap in the building's safety documentation that carries regulatory and liability implications. For buildings in design or construction, the absence of a fire strategy causes more immediate and tangible harm: programme delays, planning refusals and building control rejections.

For Buildings in Design — Planning Refusals

For higher-risk buildings, the Building Safety Act 2022's Gateway 1 requirement means that a planning application submitted without a fire statement will be refused or returned as invalid. Planning authorities in Greater London face the same situation under Policy D12a.

Even for buildings not subject to these specific requirements, local planning authorities are increasingly requesting fire safety information at planning stage — particularly for large residential developments — and a failure to provide it can result in planning conditions that delay the programme.

For Buildings in Design — Building Control Rejection

A building control application for any significant project without a fire strategy will almost certainly be queried or rejected. Building control bodies cannot approve a building's fire safety without a fire strategy demonstrating compliance. The time taken to produce a fire strategy, agree it with the building control body, and resubmit adds weeks to the programme — and if the fire strategy identifies design issues that require redesign, months.

For Existing Buildings — Regulatory Risk

For occupied buildings, the absence of a fire strategy creates regulatory risk in several ways:

• Building Safety Regulator registration for higher-risk buildings requires a building safety case, which must include a fire safety assessment. Without a fire strategy, this assessment must be produced retrospectively — a significant undertaking
• Insurance — some insurers are now requiring evidence of fire strategies for buildings above certain height or complexity thresholds
• Fire service enforcement — where a fire risk assessment identifies inadequate compartmentation or means of escape, enforcement action under the RRO 2005 may follow

The Solution — Retrospective Fire Strategy

For existing buildings without a fire strategy, the solution is a retrospective fire strategy report — an assessment of the building as it exists against current fire safety standards, identifying any gaps and recommending remedial works. This document provides the building owner with a clear understanding of the fire safety position and a prioritised action plan.