Fire Safety Record Keeping: Why Your Audit Trail Matters
Since October 2023, every fire risk assessment must be recorded in full. What you must document, how long to keep records, and why the trail protects you.
Do you have to keep records of a fire risk assessment?
Yes. Since 1 October 2023, every responsible person in England must record their fire risk assessment in full, regardless of the size or type of premises. This is a change from the previous position, where only the significant findings had to be recorded and only where the responsible person employed five or more people, held a licence, or was subject to an alterations notice.
That threshold is gone. Section 156 of the Building Safety Act 2022 amended the Regulatory Reform (Fire Safety) Order 2005 so that the full assessment and the fire safety arrangements must now be recorded in every case. A sole trader running a small shop has the same recording duty as a large employer. If you carry out a fire risk assessment, you record it, and you record all of it.
This matters because the record is no longer an administrative afterthought. It is the legal evidence that the assessment was done, what it found, and what was done about it. A fire risk assessment that exists only in the assessor’s head, or as a verbal summary to the client, no longer meets the standard the law expects.
What must you record under the Fire Safety Order?
Under the Fire Safety Order as amended, the responsible person must record:
- The fire risk assessment in full. Not just the significant findings, but the complete assessment, including the hazards identified, the people at risk, and the evaluation of existing precautions.
- The fire safety arrangements. The planning, organisation, control, monitoring, and review of the preventive and protective measures, as required by Article 11.
- The name of the responsible person and a UK address at which they can be contacted.
- The name of any person engaged to carry out or review the assessment, and their organisation where applicable. This gives the enforcing authority a clear record of who completed the work and allows the information to be passed to any incoming responsible person.
There is a further duty for residential premises. Where a building contains two or more sets of domestic premises, the responsible person must provide residents with relevant fire safety information in a form they can readily understand. The record of what was provided, and when, forms part of the same audit trail.
Why does the audit trail matter legally?
Because in fire safety, the record is the proof. When a fire and rescue authority inspects, or when something goes wrong and an investigation follows, the first thing they ask for is the fire risk assessment and the evidence behind it. If the documentation is missing, incomplete, or cannot show that findings were acted on, the responsible person is exposed regardless of what was actually done on the ground.
The principle is simple: if it is not written down, it is treated as if it did not happen. A well-maintained trail demonstrates that a competent assessment was carried out, that risks were identified honestly, that an action plan was produced, and that remedial work was completed within sensible timescales. That is the difference between demonstrating due diligence and hoping an enforcing authority takes your word for it.
The consequences of getting this wrong are serious. Offences under the Fire Safety Order can result in unlimited fines and, for the most serious breaches, imprisonment for up to two years. Failing to keep the records the law now requires is itself a breach, separate from any failing in the building’s physical fire precautions.
What is the golden thread, and does it apply to you?
The golden thread is a secure, digital record of a building’s safety information, created and maintained throughout the building’s lifecycle and accessible to those who need it. It was introduced by the Building Safety Act 2022 and the requirement came into force on 1 October 2023.
The golden thread does not apply to every building. It is a specific duty for higher-risk buildings, defined as those at least 18 metres in height or with at least seven storeys, containing two or more residential units. Responsibility sits with the accountable person, and where there is more than one, the principal accountable person. The information must be kept in a digital format, kept up to date, and handed over intact when responsibility for the building changes. Failing to transfer the golden thread on handover is an offence carrying a fine and up to two years’ imprisonment.
Even if your premises fall outside the higher-risk category, the direction of travel is clear. Fire safety regulation is moving decisively towards documented, version-controlled, accessible records. The habits the golden thread demands, a single source of truth, a clear history, and information that survives a change of ownership, are good practice for any building.
How long should you keep fire safety records?
The Fire Safety Order requires records to be kept but does not set a fixed retention period. That leaves the timescale to professional judgment and industry practice.
The widely used benchmark is to keep the current assessment plus all superseded versions for at least six years after each one is replaced. For higher-risk buildings, the golden thread is maintained for the life of the building, and many organisations apply the same approach more broadly because fire safety liabilities can surface long after an assessment was carried out.
The more important point is what you keep, not just how long. A fire risk assessment is a living document. The value of the trail comes from being able to show every version, who carried out each one, what the action plan said, and when each remedial item was completed. A single current assessment with no history cannot demonstrate that the building has been kept under proper review. The history is the evidence that the duty has been met continuously, not just on one date.
What records support the fire risk assessment?
The assessment sits at the centre of a wider set of fire safety records. A complete trail usually includes:
- The action plan, with evidence that each item was completed and the date it was closed out
- Review dates and the reasons for each review
- Fire door inspection records. In residential buildings where the top storey is more than 11 metres above ground level, the Fire Safety (England) Regulations 2022 require quarterly checks of communal fire doors and annual checks of flat entrance doors
- Servicing and test logs for fire alarms, emergency lighting, and firefighting equipment
- Staff fire safety training records
- Records of information provided to residents, where applicable
Each of these supports the assessment. An action plan that recommends repairs to a fire door means little without the record showing the repair was carried out and verified.
Frequently Asked Questions
Is record keeping a legal requirement for fire risk assessments?
Yes. Since 1 October 2023, Section 156 of the Building Safety Act 2022 has required every responsible person to record their fire risk assessment in full, along with the fire safety arrangements, in all circumstances. The previous exemption for premises with fewer than five employees has been removed, so the duty now applies whatever the size of the business. It sits under the Regulatory Reform (Fire Safety) Order 2005.
Does a fire risk assessment have to be recorded digitally?
No. The Fire Safety Order does not require any particular format, so the record can be kept on paper or electronically, provided it is complete and can be produced when an enforcing authority asks for it. The exception is the golden thread for higher-risk buildings, which must be held as a secure digital record.
How long must I keep fire risk assessment records?
The Fire Safety Order does not set a fixed period, but best practice is to retain the current assessment and all superseded versions. A common benchmark is to keep superseded versions for at least six years, while the golden thread for higher-risk buildings is maintained for the life of the building.
What is the golden thread of information?
The golden thread is a secure, digital record of building safety information maintained throughout the life of a higher-risk building, which is one at least 18 metres tall or with seven or more storeys and at least two residential units. It must be kept current, accessible, and handed over when responsibility for the building changes.
What happens if I cannot produce fire safety records?
If you cannot provide an adequate record when an enforcing authority inspects, you may face enforcement action. Failing to keep the records the law requires is a breach of the Fire Safety Order in its own right, and offences can lead to unlimited fines or imprisonment for up to two years.
FireRecord is built around the record-keeping duties at the heart of modern fire safety. It captures findings and evidence on site, keeps a clear version history of every assessment and action plan, and produces structured reports aligned with PAS 79-1 and BS 9792. Find out more at firerecord.co.uk.