The Three Routes to a Fire Safety Statement Requirement

A fire safety statement may be required for a planning application through three distinct routes: the Building Safety Act 2022's Gateway 1 requirement, the Greater London Authority's London Plan Policy D12a requirement, or a specific requirement imposed by a local planning authority outside of London. Understanding which route applies to your project determines what the fire statement must contain and how it will be reviewed.

Route 1: Gateway 1 Under the Building Safety Act 2022

Gateway 1 applies to planning applications for higher-risk buildings — buildings that will be, when built, over 18 metres tall or have at least 7 storeys, and will contain at least two residential units. For these applications, a fire statement on the prescribed government form must be submitted with the planning application.

The fire statement is validated as part of the planning application and is reviewed by the local planning authority, which will consult the Health and Safety Executive (HSE) on behalf of the Building Safety Regulator. Where the fire statement is inadequate, the planning authority can request further information, impose conditions, or refuse permission.

Route 2: London Plan Policy D12a

Policy D12a of the London Plan (2021) requires a fire statement for all major planning applications in Greater London — regardless of building height. A major application is one for 10 or more dwellings, or over 1,000m² of floorspace. The D12a fire statement must address all ten fire safety requirements of the policy, covering: means of escape; evacuation strategy; firefighting facilities; water supply; external envelope; internal safety design; management; access and circulation; sensitive sites; and fire safety standards.

D12a fire statements are reviewed by the borough planning authority and, for the largest applications, by the Greater London Authority. All London boroughs now expect D12a fire statements for all qualifying applications.

Route 3: Local Planning Authority Requirements

Outside London, local planning authorities have increasingly been requesting fire safety information for planning applications — particularly for large residential developments, buildings in sensitive locations, or schemes where fire safety has been raised as a planning concern. This is not a standardised requirement and varies between authorities.

What If Your Project Triggers Multiple Routes?

A higher-risk building in Greater London triggers both the Gateway 1 and D12a requirements. In practice, a single well-prepared fire statement can address both requirements — but it must meet the specific requirements of both the Gateway 1 prescribed form and Policy D12a. Fire Safety Services regularly produces combined Gateway 1 / D12a fire statements for London higher-risk building applications.