The Regulatory Triggers for Fire Strategy Reports

The question of when a fire strategy report is required is one of the most common enquiries we receive. The short answer is: more often than many people assume. A fire strategy report — also called a fire safety strategy or fire engineer's report — is required at multiple stages of a building's lifecycle, and for a wider range of project types than is generally understood.

New Build Projects

A fire strategy report is required for virtually all new build projects submitted for building control approval. Building control bodies — whether local authority building control (LABC) or private approved inspectors — require a fire strategy to verify that the design meets the requirements of Approved Document B (ADB), BS 9991 (for residential buildings) or BS 9999 (for commercial and mixed-use buildings).

For residential buildings, BS 9991 sets out specific requirements for fire strategies including means of escape, compartmentation and firefighting facilities. Approved Document B provides the prescriptive guidance for other building types.

Higher-Risk Buildings Under the Building Safety Act 2022

For higher-risk buildings — those over 18 metres or 7 storeys containing at least two residential units — the Building Safety Act 2022 introduces specific requirements at three stages:

• Gateway 1 (Planning): A fire statement must be submitted with the planning application demonstrating fire safety has been considered from the outset
• Gateway 2 (Pre-Construction): A detailed fire strategy report must be submitted to and approved by the Building Safety Regulator before construction can begin
• Gateway 3 (Completion): Updated fire safety documentation must be submitted confirming the building was constructed as designed

Planning Applications in Greater London

London Plan Policy D12a requires a fire statement for all major planning applications in Greater London, regardless of building height. This applies to any development requiring full planning permission that involves the creation of dwellings or other significant floor area. The fire statement must address all ten fire safety requirements of Policy D12a.

Refurbishment and Change of Use

A fire strategy report is required where refurbishment affects the fire strategy of an existing building — for example by altering escape routes, changing compartmentation, removing protected corridors or changing the use of any floor. Change of use projects almost always require a fire strategy because the fire safety requirements change with the occupancy.

Existing Buildings and BSR Registration

Existing higher-risk buildings required to register with the Building Safety Regulator need a building safety case, of which the fire strategy is a central component. Many existing higher-risk buildings have no fire strategy on record, requiring a retrospective fire strategy report to be produced.