The short answer is almost certainly yes. The Regulatory Reform (Fire Safety) Order 2005 applies to virtually every non-domestic premises in England and since 1 October 2023 the assessment must be recorded in writing regardless of how many people you employ.
The more useful question is what your particular type of premises needs and where the risk actually sits. That is what this guide covers.
First, the threshold questions
"I only have two staff." Irrelevant. The old exemption for employers with fewer than five employees related to recording the assessment, not to carrying it out and it was removed on 1 October 2023 by section 156 of the Building Safety Act 2022. Every employer must now record the assessment and must record all findings, not only the significant ones.
"I work from home." A single private dwelling is outside the Order. But if you have employees attending, customers visiting or you have converted part of the building to business use with separate access, take advice. The exclusion is narrower than people assume.
"I rent so it is the landlord's job." Partly. The landlord is normally the responsible person for the common parts. You, as employer, are the responsible person for your demise. Article 5(3) imposes duties on everyone with control, to the extent of that control and Article 5(4) converts your repairing obligations under the lease into control. See our guide on landlord versus tenant duties.
"The unit is empty at the moment." Vacant premises still require assessment. PAS 79-1:2020 applies expressly to them and empty buildings are a well-established arson target.
"We are a charity / village hall / church." The definition of responsible person covers control in connection with a trade, business or other undertaking, for profit or not. You are in scope.
Offices
Assessment complexity: Low to moderate. Higher where multi-storey, multi-tenanted or with a single staircase.
Where the risk actually sits:
- Electrical: extension leads daisy-chained, personal heaters under desks, unmanaged phone and laptop charging, server and comms rooms
- Storage in corridors, under stairs and in electrical intake cupboards
- Final exits wedged, blocked by deliveries or locked outside core hours
- Fire doors on hold-open wedges, usually the kitchen and print room doors
- Nobody trained, no fire warden, no drill in living memory
- Hot desking and flexible working, meaning nobody knows who is in the building
- Contractors and cleaners working outside normal hours
When professional assessment becomes essential: more than one storey, more than one tenant, single staircase, basement accommodation or occupancy above roughly 60 people. BS 8674:2025 places small offices in the low fire risk band that a Foundation-level assessor can handle. Larger and more complex offices move up.
Shops and retail
Assessment complexity: Low for a single small unit. High for anything with stock rooms, basements or residential accommodation above.
Where the risk actually sits:
- Stock obstructing escape routes and rear exits. The single most common finding and the cause of countless prohibition notices
- Storage piled to ceiling height, touching light fittings
- Rear fire exits secured with bolts, padlocks or roller shutters because of theft concerns
- Stock rooms with no detection
- Combustible stock quantities out of proportion to the space
- Basements used for storage with a single stair
- Accommodation above the shop, which changes the risk profile completely and is frequently ignored
- Seasonal stock surges, particularly before Christmas
Security and fire safety pull in opposite directions on rear exits and this is where a competent assessor earns their fee. There are compliant solutions: panic hardware, alarmed final exits, access control that fails safe. Bolting the door is not one of them.
Restaurants, cafés, pubs and takeaways
Assessment complexity: Moderate to high. Always higher where there is accommodation above.
Where the risk actually sits:
- Kitchen extraction ductwork, which accumulates grease and is rarely cleaned to the ceiling void. This is the leading cause of serious fires in the sector
- Deep fat fryers and cooking oil and whether suppression is provided
- Gas installations, isolation valves and interlocks
- LPG cylinders and where they are stored
- Escape routes through kitchens
- Customers unfamiliar with the layout, in low lighting, sometimes intoxicated
- Cellars and basements with a single stair
- Staff or family sleeping above, which introduces sleeping risk and materially changes everything
- Waste and cardboard accumulation at the rear
- Late-night working and lone closing staff
If anyone sleeps on the premises, treat professional assessment as non-negotiable. Fatalities in this sector cluster in flats above commercial kitchens.
Warehouses, logistics and storage
Assessment complexity: Moderate. High where high-bay racking, ATEX-relevant goods or automated systems are involved.
Where the risk actually sits:
- Long travel distances to exits, particularly from the back of a racking aisle
- Racking configuration and its effect on fire spread and sprinkler performance
- Battery charging for forklifts and MHE. Lead-acid charging generates hydrogen, which is a DSEAR trigger. Lithium-ion charging and storage is an emerging and serious risk requiring separation and detection
- Shrink-wrap machines, hot work and maintenance
- Storage against or over sprinkler heads, which defeats the system entirely
- Aerosols, flammable liquids and hazardous goods stored without segregation
- Loading bay doors treated as fire exits when they are not
- Idle pallets stored inside
- Solar panels and inverters on the roof
- Compartmentation breached for conveyor and services penetrations
Industrial units, workshops and manufacturing
Assessment complexity: High and frequently requires a DSEAR assessment alongside.
Where the risk actually sits:
- Processes generating combustible dust: wood, metal, plastics, flour
- Extraction systems, ductwork and filter units
- Spray booths and paint application
- Solvent and flammable liquid storage
- Hot work, welding, cutting and grinding and whether a permit system exists and is enforced
- Compressed gas cylinders
- Machinery, hydraulics and heat sources
- Mezzanines added without building control involvement, which is extremely common and usually invalidates the escape strategy
- Ancillary offices within the production space
- Waste and swarf accumulation
If any dangerous substance is present, Article 9(2) requires your fire risk assessment to consider it and DSEAR 2002 imposes separate duties. See our DSEAR guide.
Salons, gyms, clinics and personal services
Assessment complexity: Low to moderate.
Where the risk actually sits:
- Flammable products: acetone, nail products, hair products, aerosols and where they are stored
- Heat: dryers, styling equipment, wax pots, laundry
- Treatment rooms with clients who cannot immediately evacuate, for example mid-treatment, in a gown or under sedation at a clinic
- Gym members with headphones who do not hear an alarm
- 24-hour unstaffed gyms, which raise real questions about who calls the fire service and who checks the building is clear
- Single staircase premises above ground floor
Schools, colleges and nurseries
Assessment complexity: Moderate to high.
Where the risk actually sits:
- Evacuation of large numbers of children, including very young children who cannot self-evacuate
- Pupils with additional needs and personal emergency evacuation plans
- Practical areas: science labs, design technology, catering, art
- Corridor displays and combustible wall linings, a recurring finding
- Arson, which accounts for a substantial share of school fires and usually starts externally
- Out-of-hours community lettings, where the hirer's understanding of the evacuation strategy is often nil
- Temporary and modular buildings
Care homes, supported living and healthcare
Assessment complexity: High. Advanced-level competence territory under BS 8674:2025.
Progressive horizontal evacuation, dependent residents, staffing ratios that vary overnight, medical gases, emollient creams as an ignition-accelerating factor, bed and mattress fire performance and personal emergency evacuation planning for every resident. Approved Document B recommends sprinklers throughout care homes and an L1 detection standard.
Do not attempt this in-house and do not appoint an assessor without demonstrable experience in the sector.
Hotels, guest houses and holiday accommodation
Assessment complexity: High because of sleeping risk and unfamiliar occupants.
Guests are asleep, unfamiliar with the layout and may be impaired. Protected escape routes, room door integrity, detection coverage, staff response at night and management of guests needing assistance are all critical. Small B&Bs are caught by the Order in the same way large hotels are and are prosecuted regularly.
Short-term lets of whole flats and holiday accommodation are within the scope of PAS 79-1:2020 where letting periods range from one day to six months.
Places of worship, village halls and community buildings
Assessment complexity: Low to moderate but with a significant heritage overlay in older buildings.
Variable occupancy, volunteers rather than trained staff, candles and open flame, heating systems, historic fabric that cannot be altered, high-value contents and hirers who have never been briefed. BS 8674:2025 places small public venues such as village halls in the low fire risk band, a listed church with a large congregation is a different proposition.
Construction sites and buildings undergoing works
The Order applies and so do the Construction (Design and Management) Regulations 2015. PAS 79-1:2020 expressly does not apply to premises during the construction phase because many of the fire safety management matters it addresses do not apply to a site.
BS 8674:2025 identifies buildings under construction as high fire risk premises requiring Advanced-level competence.
Fire safety on live sites is a specialist discipline: temporary escape routes changing weekly, hot works, temporary electrics, combustible temporary structures and the interface between the works and any occupied part of the building.
When can you realistically do it yourself?
The government publishes guides intended to enable a responsible person to carry out their own assessment in very small, simple premises. The Fire Risk Assessment National Practice Guide acknowledges this, while noting that in most premises the responsible person will not have access to sufficient competence in-house.
Self-assessment may be realistic where all of the following apply:
- Single storey or ground floor only with independent access
- Simple layout with short travel distances and clear sight of exits
- No sleeping risk
- Low occupancy, with occupants familiar with the layout
- No significant process hazards or dangerous substances
- No vulnerable occupants
- No complex compartmentation you would need to assess
- No enforcement history and no third party asking questions
If any one of those fails, get help. And remember that the duty to ensure the assessment is suitable and sufficient stays with you either way.
What every premises needs, whatever the sector
- A recorded fire risk assessment covering all findings
- Recorded fire safety arrangements under Article 11(2)
- An emergency plan appropriate to the premises
- Adequate detection and warning
- Adequate, unobstructed means of escape
- Emergency lighting where needed
- Appropriate firefighting equipment
- Signage where needed
- Staff training and drills where appropriate
- Testing and maintenance regimes, with records
- Arrangements for anyone who needs assistance to evacuate
- A review date and a review when things change
Frequently asked questions
Does a small business with two employees need a fire risk assessment? Yes and since 1 October 2023 it must be recorded, with all findings included. There is no longer a small-employer exemption from recording.
Do I need one if I rent a unit in a business centre? Yes, for your own demise. The landlord will hold one for the common parts. Ask for the relevant findings of theirs and provide yours.
Is a fire risk assessment needed for a self-storage or lock-up unit? The operator is the responsible person for the building. Individual unit hirers are not usually responsible persons but their storage practices affect the risk, which is why operator terms restrict what can be stored.
We only open seasonally. Does that change anything? No, though it affects what the assessment says. Seasonal occupancy, out-of-season vacancy and arson risk all need to be addressed.
How long does an assessment take for a small shop? Usually a couple of hours on site and a similar time producing the report. Anything materially quicker is not a nine-step assessment.
