Person-Centred Fire Risk Assessments and the New Competence Framework: Preparing for April 2026

Person-Centred Fire Risk Assessments and the New Competence Framework: Preparing for April 2026

Two major developments sit alongside BS 9792 and demand urgent attention from responsible persons, property managers, and fire risk assessors. The first is the introduction of person-centred fire risk assessments under the Fire Safety (Relevant Persons) (England) Regulations. The second is the publication of BS 8674, a new British Standard establishing a formal competence framework for fire risk assessors.

Both represent a fundamental shift in how the UK fire safety sector operates, and both have immediate practical implications for anyone managing residential buildings.

Person-Centred Fire Risk Assessments: What They Are and Why They Matter

The Grenfell Tower Inquiry made a stark finding: the previous guidance effectively dismissed the idea that it was practical to identify and provide for vulnerable persons in fire risk assessments. This was a critical failing. A significant number of those who died in the Grenfell Tower fire were vulnerable residents whose specific needs had not been addressed.

The Fire Safety (Relevant Persons) (England) Regulations address this directly by requiring person-centred fire risk assessments (PCFRAs) for relevant residents. This obligation comes into force on 6 April 2026.

Who Is a "Relevant Resident"?

A relevant resident is defined as a permanent resident of a specified building whose ability to evacuate without assistance is impaired due to a cognitive or physical impairment or condition. The definition is deliberately broad and includes:

- Mobility impairment -- residents who use wheelchairs, walking aids, or have conditions affecting their movement
- Sensory and neurological conditions -- including visual impairment, hearing loss, and neurological disorders
- Morbid obesity -- where weight significantly affects the ability to self-evacuate
- Temporary impairment -- residents recovering from surgery, injury, or illness
- Pregnancy -- also recognised as a condition that may impair evacuation ability

Which Buildings Are Affected?

PCFRAs apply to buildings that are 11 metres or above in height and that operate under a simultaneous evacuation strategy. However, even if your building does not fall within this specific scope, the principles of identifying and providing for vulnerable residents are increasingly regarded as best practice across all residential building types.

What Does a Person-Centred Fire Risk Assessment Involve?

A PCFRA assesses fire safety risks at the individual level, considering the specific circumstances of the vulnerable resident. It typically involves:

1. Assessing fire hazards within the resident's domestic premises. This goes inside the individual dwelling to examine cooking arrangements, electrical appliances, smoking materials, mobility equipment charging, hoarding risks, and any other fire hazards specific to that home.

2. Assessing fire safety within the common parts. How do the conditions in corridors, stairwells, and escape routes affect this particular resident's ability to evacuate? Are there obstacles, distances, or design features that present specific barriers?

3. Evaluating the resident's ability to evacuate. Can the resident hear a fire alarm? Can they physically reach and use the means of escape? Do they require assistance, and if so, what form should that assistance take?

4. Producing a Personal Emergency Egress Plan (PEEP). The PCFRA ultimately leads to a personalised evacuation plan that addresses the resident's specific needs and sets out the arrangements for getting them to safety in the event of a fire.

BS 9792 provides a complete suggested approach for conducting PCFRAs, which means responsible persons can begin planning and preparing now -- well ahead of the April 2026 enforcement date.

Who Can Conduct a PCFRA?

This is a common question, and the answer is more nuanced than many expect. The legislation and supporting guidance make clear that the person conducting a PCFRA must be competent to do so. However, this does not necessarily mean that a fully qualified fire risk assessor must conduct every PCFRA.

The competence requirement is based on having the appropriate skills, knowledge, experience, and behaviours. In practice, this means:

- External fire risk assessors can conduct PCFRAs, and this approach provides the advantage of using a person whose competence you have already verified through your procurement process.
- In-house staff may also be competent to conduct PCFRAs, provided they have sufficient understanding of fire safety systems, the building's specific arrangements, and the principles underpinning person-centred assessment.
- Managing agents and landlords should carefully assess whether they have the in-house capability before deciding who will carry out this work.

Where PCFRAs are conducted alongside a Type 3 fire risk assessment (which already involves entering a sample of dwellings), the findings can support and complement each other -- though the PCFRA must always consider the outcomes in the context of the wider building fire risk assessment.

Who Can Request a PCFRA?

Requests can come from multiple sources:

- The residents themselves
- Carers acting on a resident's behalf
- Family members who are concerned about a resident's safety
- The responsible person (landlord or managing agent) who identifies a vulnerable resident through their engagement activities

The obligation on the responsible person is to offer the assessment in the first place. Proactive identification of vulnerable residents through your resident engagement processes is both a legal requirement and a practical necessity.

Preparing for April 2026: A Practical Checklist

The enforcement date will arrive quickly. Responsible persons should be taking the following steps now:

- Review your resident engagement processes. Are you actively asking residents about their needs and vulnerabilities? If your building is 11 metres or above, this should already be part of your management arrangements.
- Identify residents who may qualify. Begin building a picture of which residents may need a PCFRA. This does not require medical assessments -- it requires conversations and a willingness to ask the right questions.
- Decide who will conduct the assessments. Will you use external assessors, in-house staff, or a combination? Whichever route you choose, ensure the person is demonstrably competent.
- Familiarise yourself with the approach set out in BS 9792. The standard provides detailed guidance on how PCFRAs should be structured and conducted.
- Establish a process for producing and maintaining PEEPs. A PCFRA that does not lead to a workable evacuation plan for the individual has not achieved its purpose.

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The New Competence Framework: BS 8674

Alongside BS 9792, the publication of BS 8674 introduces a formal framework for assessing the competence of fire risk assessors. This is not optional guidance -- it reflects the direction of travel signalled by both the Building Safety Act and the Fire Safety Order, and it is expected that government will set out further requirements on assessor competence in the coming months.

What BS 8674 Covers

The standard provides:

- A framework for assessing competence of both individual fire risk assessors and the organisations they work for
- Performance-based criteria that can be used to evaluate whether an assessor has the requisite skills, knowledge, experience, and behaviours
- Guidance on records and documentation that assessors should maintain to evidence their competence
- A three-tier competence structure that matches assessor capability to building complexity

The Three-Tier Competence Structure

BS 8674 introduces three levels of assessor competence:

#### Foundation Level
Suitable for simple, low-risk buildings with minimal occupancy. Assessors at this level should have a solid grounding in fire risk assessment principles but may not have the depth of experience needed for complex buildings.

#### Intermediate Level
Suitable for buildings of moderate complexity and broader usage types. This level requires a wider range of experience and a deeper understanding of fire safety systems and building construction.

#### Advanced Level
Required for high-risk buildings, complex environments, very large residential blocks, care facilities, and public entertainment venues. Assessors at this level must demonstrate extensive experience, advanced technical knowledge, and the ability to exercise professional judgement in challenging situations.

What This Means for Responsible Persons

When commissioning a fire risk assessment, you should now be asking not only "Is this assessment being conducted to BS 9792?" but also "Is this assessor competent to assess this specific building?"

Practical steps to verify competence include:

Ask about qualifications and experience. A qualified assessor is not automatically a competent one. Ask specifically about their experience with buildings similar to yours in terms of type, size, complexity, and occupancy.

Look for third-party certification. Organisations certified to schemes such as BAS SP 205 undergo annual third-party audits to verify that their systems, processes, and personnel meet required standards. This provides an additional layer of assurance.

Check membership of professional schemes. Individual assessors may be registered with recognised professional bodies that maintain registers of competent fire risk assessors. Ask which scheme they belong to and what level of assessor they are registered as.

Ask for evidence of organisational capability. Does the assessor's organisation have the systems in place to manage competence -- including ongoing training, supervision, peer review, and quality assurance? This "organisational capability" is specifically addressed in BS 8674.

Document your due diligence. Whatever checks you carry out, keep a record. If your choice of assessor is ever questioned, being able to demonstrate that you asked the right questions and received satisfactory answers is a significant defence.

The Bigger Picture

The introduction of BS 8674 alongside BS 9792 signals a clear direction for the fire safety sector: competence will be regulated, not assumed. The government has indicated that further guidance on competence requirements for fire risk assessors is forthcoming, and the framework set out in BS 8674 is expected to form the basis of that regulatory approach.

For responsible persons, the message is straightforward. The quality of your fire risk assessment depends entirely on the competence of the person who conducts it. Investing time in verifying that competence is not bureaucracy -- it is a core part of your fire safety management obligations and a critical factor in ensuring that your building and its residents are properly protected.