Who Can Carry Out a Fire Risk Assessment? Competence Under BS 8674:2025

There is no licence to practise as a fire risk assessor in England. No statutory register. No legal bar on anyone offering the service tomorrow.

That places the burden on you. As the responsible person, you carry the duty to ensure your assessment is suitable and sufficient and you are expected to appoint competently without being an expert yourself. This guide explains what the law requires, what the competence framework now says and what questions to ask before you appoint.

What the law actually says

Article 9(1) of the Regulatory Reform (Fire Safety) Order 2005 requires a suitable and sufficient assessment. It says nothing about who carries it out.

Article 18(1) requires the responsible person to appoint one or more competent persons to assist in undertaking the preventive and protective measures. Article 18(5) defines competence: a person is competent where they have sufficient training and experience or knowledge and other qualities, to enable them to assist properly.

Note two features of that definition. It is deliberately broad and it is relative. There is no named qualification. And what counts as sufficient depends entirely on the premises.

Article 18(8) adds a point that is often overlooked: where there is a competent person in the responsible person's employment, that person must be appointed in preference to an external competent person. The law does not assume consultants are better, it assumes in-house competence, where it exists, should be used.

The Article 9A myth

You will read on many fire safety websites that Article 9A of the Fire Safety Order requires the responsible person not to appoint anyone to assist with the assessment unless they are competent.

Article 9A is not in force. Section 156(4) of the Building Safety Act 2022 would insert it. Every other provision of section 156 was commenced in England on 1 October 2023. Section 156(4) was not and remains outstanding. The Fire Risk Assessment National Practice Guide of December 2025 confirms this explicitly.

This matters less than it might seem because the duties above already require competence in substance. But if a firm is citing a provision that has never been commenced as the basis for their pitch, it tells you something about the care they take with the rest.

BS 8674:2025: the competence framework

BS 8674:2025, Built environment. Framework for competence of individual fire risk assessors. Code of practice, is the current benchmark. It gives recommendations for the competence criteria to be met by individuals undertaking general fire risk assessments and guidance on the skills, knowledge, experience and behaviours expected.

It defines three core levels of competence: Foundation, Intermediate and Advanced, where Advanced is the highest, each progressively building on the previous one. Together they create a tiered career pathway: entrants achieve Foundation after supervised learning and development, progress to Intermediate with further experience and continue to Advanced.

The Fire Risk Assessment National Practice Guide maps these to Regulated Qualifications Framework levels:

Qualifications are not the whole of competence. BS 8674:2025 is concerned with skills, knowledge, experience and behaviours and it includes a model code of conduct covering professional integrity, honesty, accepting appropriate responsibility, diligent performance, maintaining competence, interdisciplinary co-operation, workplace safety, reporting and whistleblowing, clear communication and liability and indemnity.

Matching the level to your building

This is the practical question and BS 8674:2025 answers it in Annex C, which relates competence levels to building risk profiles using five key fire risk factors. Any one factor alone may raise the risk level or a combination may.

Foundation level, low fire risk premises

Typical characteristics include a low occupancy level of around 60, often a single person or family or low staff numbers, occupants very familiar with the layout and only occasional visitors.

Typical uses include:

• Common parts of small multi-occupied buildings, such as converted houses, HMOs and residential apartments
• Small offices and retail or commercial enterprises
• Small public venues such as village halls
• Open, internally undivided small warehouses and production buildings

Intermediate level, moderate fire risk premises

Larger, more complex or more heavily occupied buildings, where the layout is less familiar to occupants, where there is greater subdivision or where the consequences of fire are more serious.

Advanced level, high fire risk premises

BS 8674:2025 does not describe high risk premises in Annex C, stating that they would require the Advanced level of competence. It identifies high fire risk premises as including those having complex fire strategies, higher risk buildings under section 65 of the Building Safety Act 2022, specialised housing and buildings under construction.

The Practice Guide adds that specialised risks are not covered by BS 8674 at all and would require Advanced endorsements: high hazard industries, acute care hospitals, buildings requiring major fire engineered solutions and buildings using non-conventional construction materials, systems or elements including external walls.

The honest summary

A small shop and a fifty-bed care home are not the same job and an assessor competent for one is not automatically competent for the other. The most common competence failure in this industry is not incompetence. It is a competent Foundation-level assessor working on an Intermediate or Advanced building.

The limits of competence

BS 8674:2025 Clause 5 is worth quoting in substance because it sets the professional standard:

Fire risk assessors should understand the limits of their competence and should only undertake assessments at the level appropriate to their ability. Where an assessment is likely to be beyond an individual's competence level, that individual should not continue unless supervised and supported by another appropriately competent assessor.

Where specialist advice is needed, the assessor should know where to source it. The standard is explicit that an assessor is not expected to be an expert in all subjects that might bear on the outcome, such as electrical installations or the detailed construction of external wall systems but they are expected to have an awareness of such matters and to recognise where specialist advice is required.

An assessor who tells you that something is outside their competence and needs a specialist is demonstrating competence, not admitting a deficiency. Treat it as a good sign.

What BS 8674:2025 does not cover

Important because it is where over-claiming happens. The standard expressly does not cover:

• The process for undertaking a fire risk assessment. That is PAS 79-1:2020 and BS 9792:2025
• Fire risk appraisals of external wall construction and cladding. That is PAS 9980:2022
• Destructive inspections to assess structure and building materials
• Competence of organisations. That is where BAFE SP205 comes in
• Duty holder responsibilities
• Compliance audits, design assessment, product performance and installation assessment
• Specialised fire safety engineering beyond the Advanced level

It also applies predominantly to non-invasive assessments and to buildings constructed using conventional materials and systems.

So an assessor with an Advanced-level competence claim is still not, by that fact, competent to carry out a PAS 9980 external wall appraisal or an intrusive Type 4 investigation. Those need separate evidence.

Can I do it myself?

Legally, yes. Nothing prohibits a responsible person from carrying out their own assessment and Article 18 actually prefers in-house competence where it exists.

Practically, the Fire Risk Assessment National Practice Guide is balanced about this. It acknowledges that in a small business, the employer might occupy very small premises for which government publishes guidance enabling them to carry out their own assessment. But it notes that in most premises the responsible person would not have access to persons with sufficient competence within their organisation and is likely to need an external assessor.

Realistic self-assessment territory: small, single-storey, simple layout, no sleeping risk, low occupancy, familiar occupants, no significant process hazards, no complex compartmentation, no vulnerable occupants.

Everything else, get help. In particular, any premises where people sleep, any multi-occupied residential building, anything with a complex escape strategy, anything with dangerous substances and anything where the assessment will face third party scrutiny.

And note the point the Practice Guide makes plainly: appointing an external fire risk assessor does not absolve the responsible person of their first duty, which is ensuring a suitable and sufficient assessment is carried out. You cannot outsource the duty. You can only outsource the work.

The competent assistant, a separate appointment

This is widely missed. Article 18 requires the appointment of one or more competent persons to assist the responsible person in undertaking the preventive and protective measures. That appointment is separate from the appointment of a fire risk assessor.

The Practice Guide describes the competent assistant's role: advising the responsible person on matters such as fire safety policies and the structure of fire safety management. In a large organisation this might be a professional fire safety manager, a director of health and safety or a whole department. The competent assistant will not necessarily carry out the assessments, though they may but will advise on the appropriate arrangements for assessments to be carried out.

If there is someone competent within the organisation, they should be appointed in preference to an external party. In smaller organisations there will be nobody and external consultants will be needed. These may be the same consultants who carry out the assessments, provided they offer that additional service but separate appointments are common.

Most organisations we deal with have a fire risk assessor and have never formally appointed a competent assistant. That is an Article 18 gap.

How to verify an assessor

Ask these, in writing, before you appoint. A competent provider will answer all of them without hesitation.

On the individual:

1. What is your competence level under BS 8674:2025 and why is that level appropriate for this building?
2. What qualifications do you hold, from which awarding organisation and at what RQF level?
3. What professional body memberships do you hold, at what grade? IFE and IFSM grades are meaningful, ordinary membership and fellowship are not the same thing
4. What is your experience with this specific building type? Care homes, HMOs, heritage, industrial and healthcare are all specialisms
5. What CPD have you undertaken in the last twelve months?

On the organisation:

6. Are you third-party certificated, for example to BAFE SP205 and by which UKAS-accredited certification body? Verify it on the BAFE Fire Safety Register rather than taking the logo on trust
7. Will the report be validated or peer reviewed before issue and by whom?
8. What professional indemnity insurance do you carry and to what limit?

On the work:

9. Which standard will you apply, PAS 79-1:2020, BS 9792:2025 or both for mixed use?
10. For a residential block, which type of assessment and why that type?
11. What is excluded from the scope?
12. Will you tell me if something falls outside your competence and what happens then?

Question 12 is the one that separates good providers from confident ones.

Warning signs

• A fee that could not possibly cover the site time the building requires
• No named assessor or an assessor who cannot state their competence level
• A quote that does not identify which standard will be applied
• Claims that Article 9A requires this or that
• Claims that certification prevents an insurer declining a claim
• An assessor offering PAS 9980 external wall appraisals "under" a BAFE SP205 certification. The scheme expressly excludes that
• A generic action plan recommending everything as urgent, which indicates that no judgement was applied
• A report with no risk rating methodology, no scope statement and no review date
• Reluctance to provide references for similar buildings

Risks of an inadequate assessment

• Enforcement. An inspecting officer who finds an inadequate assessment will generally treat it as no assessment, which is a route to an enforcement notice.
• The reversed burden of proof. Under Article 34, where a duty is qualified by reasonable practicability, it is for the accused to prove that it was not practicable to do more. A thin assessment gives you nothing to prove it with.
• The due diligence defence weakened. Article 33 provides a defence of having taken all reasonable precautions and exercised all due diligence. Evidence of a careful appointment decision is part of that defence.
• Insurance. Underwriters increasingly ask how you satisfied yourself that your assessor was competent.
• Wasted money. Generic assessments recommend generic works. Duty holders then spend on the wrong things.

Frequently asked questions

Do I legally need a qualified fire risk assessor? The law requires the assessment to be suitable and sufficient and requires you to appoint competent persons under Article 18. It does not name a qualification. BS 8674:2025 is the recognised benchmark for what competence looks like.

Is BS 8674:2025 mandatory? No. It is a British Standard, not legislation. It is the benchmark against which competence is now judged and BAFE SP205 Version 6 is mapped against it.

What is the difference between BS 8674:2025 and BAFE SP205? BS 8674:2025 addresses the competence of individuals. BAFE SP205 is a third-party certification scheme for organisations. Since Version 6, the SP205 tiers align with the BS 8674 levels.

Can I do my own fire risk assessment? For small, simple, low-risk premises with no sleeping risk, potentially yes, using the government guides. For anything more complex, it is unwise and the duty to ensure suitability and sufficiency remains yours either way.

My assessor is a former firefighter. Is that enough? Operational firefighting experience is valuable but is not itself fire risk assessment competence. Many excellent assessors come from that background, having then obtained qualifications and assessment experience. Ask about the qualifications and the assessment experience, not just the service.

Who is responsible if the assessor gets it wrong? You remain responsible for ensuring the assessment is suitable and sufficient. You may have a contractual or professional negligence claim against the assessor, which is why their professional indemnity insurance matters but the statutory duty stays with the responsible person.