Fire Strategy vs Fire Risk Assessment: What Is the Difference?

These two documents get conflated constantly, including by people who should know better. A developer asks for a fire risk assessment when they need a fire strategy. A managing agent inherits a fire strategy and files it as though it discharges their assessment duty. Both mistakes cost money.

The distinction is straightforward once you see it.

The one-line answer

A fire strategy is an engineering design document. It sets out how a building is designed to achieve fire safety and it exists to demonstrate compliance with the Building Regulations before and during construction.

A fire risk assessment is an operational risk evaluation. It examines a building in use, with real occupants, real hazards and real management arrangements and it exists to discharge the duty under the Regulatory Reform (Fire Safety) Order 2005.

One answers "will this building be safe if we build it like this?" The other answers "is this building safe as it is being used today?"

Side by side

What a fire strategy contains

A fire strategy explains, in engineering terms, how the design satisfies the functional requirements of Part B of Schedule 1 to the Building Regulations: means of warning and escape, internal fire spread over linings, internal fire spread from structure, external fire spread and access and facilities for the fire service.

A typical strategy covers:

• The design approach: prescriptive compliance with Approved Document B, a code-based approach using BS 9991:2024 for residential buildings or BS 9999:2017 for other buildings or a fire engineered approach under BS 7974 where the design departs from prescriptive guidance
• Occupancy characteristics and design occupant numbers
• The evacuation strategy: simultaneous, phased, stay put or progressive horizontal evacuation
• Means of escape: travel distances, exit widths and capacities, stair numbers and widths, protected routes, refuges and evacuation lifts
• Compartmentation: the compartment strategy, fire resistance periods, cavity barriers
• Structural fire resistance
• Fire detection and alarm: system category and design principles
• Suppression: sprinklers or water mist and where the design relies on them
• Smoke control: natural or mechanical and how it is expected to perform
• External fire spread: boundary distances, external wall construction, reaction to fire classifications
• Firefighting provisions: firefighting shafts, fire mains, vehicle access, hydrants
• Any departures from prescriptive guidance and the engineering justification for them
• Management assumptions: what the strategy assumes the operator will do

That last point is where the two documents meet and it is the single most useful thing to understand about the relationship between them.

The critical connection: assumptions

A fire strategy makes assumptions about how a building will be occupied, managed and maintained. Extended travel distances justified by sprinkler protection. A stay put strategy relying on compartmentation being maintained. A phased evacuation relying on trained staff and a working voice alarm. An escape route relying on a door being kept clear.

The fire risk assessment is the mechanism by which those assumptions are tested against reality, year after year.

That is why BS 9792:2025 and PAS 79-1:2020 both list, as part of the first of their nine steps, obtaining information on the fire strategy for the building where a documented fire strategy exists. BS 9792:2025 notes that other than in small, simple premises, the fire strategy is likely to be of value to the assessor.

Without the strategy, the assessor is reverse-engineering the design intent from what they can see. They can do it, competently and often have to. But they cannot tell you whether the sprinkler system was a design requirement compensating for an extended travel distance or a voluntary addition. That distinction changes everything about how a defect is prioritised.

Regulation 38: how the strategy is supposed to reach you

Regulation 38 of the Building Regulations 2010 requires that where building work consists of or includes the erection or extension of a building to which the Fire Safety Order applies or is carried out in connection with a relevant change of use, the person carrying out the work must give fire safety information to the responsible person, no later than the date of completion or the date of first occupation, whichever is earlier.

Approved Document B states that the aim is achieved when the responsible person has all the information needed to:

• understand and implement the fire safety strategy of the building
• maintain any fire safety system provided
• carry out an effective fire risk assessment of the building

It also states that where a fire safety strategy has been prepared as part of the design and construction process, it should be made available to the relevant duty holder.

What changed on 1 October 2023

Regulation 38 was substantially strengthened by the Building Regulations etc. (Amendment) (England) Regulations 2023. The new paragraphs added a closed loop:

• Regulation 38(2A): the responsible person must give the person carrying out the work a notice acknowledging receipt of the fire safety information and confirming it is sufficient to enable them to understand, operate and maintain the building and its fire safety systems.
• Regulation 38(2B): the person carrying out the work must notify the relevant authority that they have given the information and that they have received the acknowledgement, or, if they have not, what steps they took to obtain it and when.
• Timescales are tight: five days in most cases, thirty days where self-certification applies, seven days where third party certification applies.

The practical effect is significant. Handover of fire safety information is no longer a courtesy that quietly gets skipped at practical completion. It is a recorded, notifiable event and the responsible person now has to state whether what they received is sufficient.

If you are a client, buyer or incoming managing agent, ask for the regulation 38 information and the acknowledgement notice. If it does not exist, that is a finding in itself.

Where the Building Safety Act fits

For higher-risk buildings, generally those at least 18 metres in height or at least seven storeys with at least two residential units, the Building Safety Act 2022 introduced a regime with three formal Gateways that must be passed in sequence:

• Gateway 1: planning stage, with a fire statement
• Gateway 2: before building work starts, requiring building control approval from the Building Safety Regulator
• Gateway 3: completion, before occupation

Linked to the Gateways is the requirement to create, store and update a golden thread of building information throughout the building's lifecycle.

A robust fire strategy is central to a Gateway 2 application. It is the document that demonstrates how the design meets the functional requirements and it is scrutinised. Weak or absent strategies are a recognised cause of Gateway 2 rejections and delays.

Note that certain buildings are excluded from the higher-risk definition, including care homes, hospitals, military and secure residential institutions and hotels, even where they exceed the height threshold. Those still require competent design and a fire strategy, they simply sit outside the Gateway regime.

When you need which

You need a fire strategy if you are:

• Constructing a new building
• Extending an existing building
• Carrying out a material change of use, for example office to residential, warehouse to gym, house to HMO or church to flats
• Refurbishing in a way that affects means of escape, compartmentation or fire systems
• Making a Gateway 2 application for a higher-risk building
• Departing from Approved Document B and needing engineered justification
• Unable to find the original strategy for a building you now manage and needing to establish the design basis before altering it

You need a fire risk assessment if you are:

• Operating or occupying any premises to which the Fire Safety Order applies
• Responsible for a building containing two or more sets of domestic premises
• Taking on a new building, tenancy or management contract
• Reviewing after a change to the building, its use, its occupants or its management
• Responding to enforcement action
• Satisfying an insurer, lender, licensing authority or purchaser

You need both if you are:

• Developing a building you will then occupy or manage
• Converting a building and then letting it
• Managing a building where the strategy exists but has never been tested against how the building is actually used

The pre-occupation assessment

There is a useful third document that sits between the two and it is worth knowing about because it prevents a common and expensive failure.

A pre-occupation fire safety assessment, a term defined in PAS 79-1:2020, is carried out on a newly built or newly refurbished building before it is occupied. It checks that the fire safety measures the strategy called for have actually been installed, commissioned and are working and that the management arrangements needed to operate the building safely are in place.

The failure it prevents is this: a building is designed correctly, built with a series of small deviations, handed over with incomplete commissioning evidence, occupied and then twelve months later a fire risk assessment discovers that the smoke control system was never properly commissioned and the compartmentation was breached during fit-out. At that point the contractor has gone, the retention has been released and the responsible person owns the problem.

A pre-occupation assessment finds it while someone else is still on the hook.

Common mistakes

"We have a fire strategy so we do not need a fire risk assessment." The strategy discharges nothing under the Fire Safety Order. Article 9 requires an assessment of a building in use.

"We have a fire risk assessment so we do not need a fire strategy." An assessment does not demonstrate compliance with the Building Regulations and building control will not accept one.

"The fire risk assessment will pick up the design problems." It may but it is the wrong tool and the wrong stage. Design defects found after occupation are vastly more expensive to fix than the same defects found at design stage and some cannot be fixed at all without engineering compensation.

Altering a building without revisiting the strategy. Removing a wall, changing a layout or converting a space can invalidate the basis on which the design was approved. If the strategy relied on a compartment line and the compartment line has gone, the strategy no longer describes the building.

Treating a fire risk assessment as a snagging report. BS 9792:2025 makes the point directly in its model pro forma: the report must not be used as a snagging report against building regulations. The two exercises have different purposes and different benchmarks.

Frequently asked questions

Is a fire strategy a legal requirement? Not by that name. The Building Regulations impose functional requirements under Part B and a fire strategy is the normal means of demonstrating compliance. For anything beyond the simplest project and for any Gateway 2 application, it is effectively essential. Regulation 38 also requires the strategy to be passed to the responsible person where one has been prepared.

Who writes a fire strategy? A fire engineer or fire safety designer. Where the design departs from prescriptive guidance and relies on fire engineering under BS 7974, it requires a chartered fire engineer.

Can my fire risk assessor write my fire strategy? Some organisations do both but they are different disciplines. PAS 79-1:2020 makes the reverse point too, noting that fire safety specialists experienced only in the design of new buildings might not appreciate the standards against which older buildings were designed and the possible continued acceptability of those standards.

We have lost the fire strategy for our building. What now? Not unusual, particularly in buildings predating regulation 38. A fire strategy can be reconstructed from survey, drawings and inspection, sometimes called a retrospective or as-built strategy. It is worth doing before any significant alteration and before any Gateway or Building Safety Regulator engagement.

Does a change of use need a fire strategy? A material change of use engages Part B and normally requires one. Converting a house to an HMO, offices to flats or a retail unit to a restaurant are all common examples.

What is the difference between a fire strategy and a fire safety plan? A fire strategy is a design document. A fire safety plan or emergency plan, is an operational document setting out what people do in a fire. The emergency plan flows from the assessment, not the strategy, though it must be consistent with both.