Residential Block Fire Safety: What Managing Agents and Freeholders Must Do in 2026
If you are a managing agent or freeholder responsible for a residential block in Manchester, your fire safety obligations have expanded considerably over the past few years. The Fire Safety Act 2021, the Building Safety Act 2022 and updates to the fire safety order have collectively shifted more responsibility onto those who manage residential buildings — and enforcement is increasing.
The common areas of your block — stairwells, corridors, lobbies, bin stores, plant rooms, car parks — are your responsibility. The fire alarm system, emergency lighting, fire doors, dry risers, ventilation systems and the fire risk assessment all fall to you. Getting any of these wrong exposes residents to danger and exposes you to enforcement action, prosecution and civil liability.
Quick answer: In 2026, managing agents and freeholders of residential blocks must maintain a current fire risk assessment, a functioning fire alarm system appropriate to the building, compliant emergency lighting on all escape routes, fire doors in good working order, clear and unobstructed escape routes, and proper documentation of all testing and maintenance. If you manage residential blocks across Greater Manchester and need to review your fire safety compliance position, call 0161 706 1360 for a multi-block assessment.
The Legal Framework in 2026
Three pieces of legislation create the framework that managing agents and freeholders must work within:
The Regulatory Reform (Fire Safety) Order 2005 (FSO). This is the primary fire safety legislation for the common areas of residential buildings. It places duties on the responsible person — typically the managing agent, freeholder, or management company — to assess fire risk and take reasonable steps to reduce it. The FSO covers everything from fire detection and alarm systems to emergency lighting, escape routes, fire doors and staff training.
The Fire Safety Act 2021. This clarified that the FSO applies to the structure, external walls and individual flat entrance doors of multi-occupancy residential buildings, not just the common areas. This was a direct response to the Grenfell Tower inquiry findings. It means the fire risk assessment must now consider the external wall system and the flat entrance doors as part of the overall fire safety strategy.
The Building Safety Act 2022. This created the Building Safety Regulator and introduced the higher-risk building regime for residential buildings over 18 metres or seven storeys. It also introduced requirements for building safety cases, mandatory occurrence reporting, and a residents' engagement strategy. While the full regime applies to higher-risk buildings, the principles of accountability and resident safety apply to all residential blocks.
Together, these laws mean that managing agents and freeholders cannot treat fire safety as a tick-box exercise. The expectation is proactive management, proper investment and documented compliance.
Fire Risk Assessment: The Foundation
Every residential block must have a fire risk assessment, and it must be current. "Current" means it has been reviewed within the last twelve months, or sooner if significant changes have occurred — building work, change of use, fire incidents, new hazards identified.
The FRA must be carried out by a competent person. For most residential blocks, this means a qualified fire risk assessor — not the managing agent filling in a generic template. The FRA should be specific to the building, considering its layout, construction, occupancy, escape strategy and existing fire safety measures.
What the FRA covers in a residential block:
- Escape routes: corridors, stairwells, lobbies, final exits
- Fire detection and alarm systems
- Emergency lighting
- Fire doors: condition, self-closing devices, gaps, seals, glazing
- Compartmentation: fire-stopping between flats, between flats and common areas, around service penetrations
- External wall systems and cladding (post-Fire Safety Act 2021)
- Flat entrance doors (post-Fire Safety Act 2021)
- Electrical intake rooms, plant rooms, bin stores
- Signage and wayfinding
- Management arrangements: evacuation strategy, information to residents, maintenance contracts
- Any specific hazards: commercial units at ground floor, EV charging, communal laundry, roof terrace
- Fire doors that do not self-close properly or have damaged intumescent strips
- Missing or inadequate emergency lighting on escape routes and stairwells
- Fire alarm system not appropriate for the building's evacuation strategy
- Compromised compartmentation where services have been routed through fire barriers
- Bin stores with no fire separation from the building
- Obstructed escape routes: bicycles, pushchairs, furniture in corridors and stairwells
Emergency Lighting Requirements
Every escape route in a residential block requires emergency lighting that meets BS 5266-1. This means:
Stairwells — every landing, every change of direction, every level. Stairwells are the primary escape route in most residential blocks and they must be illuminated to at least 1 lux at floor level during a power failure.
Corridors — the full length of every corridor that forms part of an escape route. Changes of direction, junctions and intersections need particular attention.
Lobbies and entrance halls — any space that occupants pass through on their way to a final exit.
Plant rooms and electrical intake rooms — these are high-risk areas that may need to be accessed during an emergency.
External routes — if the escape route continues outside the building to a place of safety, external emergency lighting may be required where there is no adequate ambient light.
Car parks — underground or enclosed car parks almost always require emergency lighting. Open-sided car parks may not, depending on the FRA.
The emergency lighting must be tested monthly (brief functional test) and annually (full three-hour duration test). Results must be recorded in a log book and made available for inspection. Managing agents should ensure their maintenance contract includes both testing regimes and that the contractor provides proper documentation after each visit.
Fire Alarm and Detection Requirements
The fire alarm and detection requirements for a residential block depend on the building's evacuation strategy:
Simultaneous evacuation — all residents evacuate when the alarm sounds. This requires a fire alarm system that can be heard in every flat. Common in smaller blocks, blocks without adequate compartmentation, and blocks where the FRA has determined that a stay-put strategy is not safe.
Stay-put strategy — residents remain in their flats unless directly affected by fire. The building relies on compartmentation to contain the fire. The fire alarm may be limited to common areas, with activation by manual call points or common-area detectors. Individual flats may have standalone smoke alarms rather than being connected to the communal system.
Defend-in-place / phased evacuation — more complex strategies used in larger or higher-risk buildings, sometimes involving voice alarm systems and floor-by-floor evacuation.
The FRA determines which strategy is appropriate, and the fire alarm system must match. A common compliance failure we find is a building that has moved from stay-put to simultaneous evacuation (because compartmentation has been compromised or the FRA assessor has determined that stay-put is no longer safe) but the fire alarm system has not been upgraded to provide audibility in every flat.
BS 5839-6 is the code of practice for fire detection and alarm systems in residential premises. It defines grades and categories specific to residential buildings. Most purpose-built blocks require at least a Grade A (commercial-grade panel with mains-powered detectors and manual call points) Category LD2 system in common areas.
Fire Doors
Fire doors are one of the most contentious and frequently non-compliant elements of residential block fire safety. The Fire Safety Act 2021 brought flat entrance doors within the scope of the FSO, meaning the responsible person must now ensure they are adequate.
What to check:
- Self-closing devices fitted and working — the door must close fully into its frame from any angle without manual assistance
- Intumescent strips and smoke seals present and in good condition
- No damage to the door leaf, frame or glazing
- Gaps no greater than 3 mm between the door and frame (when closed)
- Correct fire resistance rating for the location — typically FD30 (30-minute) for flat entrance doors and FD60 for doors protecting stairwells
- No alterations that compromise fire performance: letterboxes, cat flaps, spy holes without fire-rated inserts
Documentation and Record Keeping
Managing agents must maintain comprehensive fire safety records:
- Fire risk assessment — current document plus all previous versions
- Emergency lighting test records — monthly and annual test results
- Fire alarm test records — weekly, monthly, quarterly and annual test results
- Fire door inspection records — quarterly checks as recommended by the FRA
- Maintenance and servicing records — for all fire safety systems
- Remedial action tracking — actions arising from FRAs, tests and inspections, with evidence of completion
- Resident communication — evidence of fire safety information provided to residents
- Contractor competence — evidence that maintenance contractors are suitably qualified
What Managing Agents Should Do Now
1. Audit your portfolio. List every residential block you manage. Check when each FRA was last reviewed. Check when emergency lighting and fire alarm testing was last carried out. Identify blocks where documentation is incomplete.
2. Prioritise the gaps. Blocks with overdue FRAs, untested emergency lighting or known fire door deficiencies go to the top of the list.
3. Appoint competent contractors. Ensure your fire safety maintenance contractors are appropriately qualified — BAFE registered for fire alarm and detection work, competent in BS 5266 for emergency lighting.
4. Establish a rolling programme. Fire safety is not a one-off project. It requires monthly testing, quarterly checks, six-monthly servicing, annual testing and annual FRA reviews, every year, for every building.
5. Communicate with residents. Provide fire safety information to every resident. Explain the evacuation strategy. Ask residents to report fire door damage, obstructed escape routes and faulty fire safety equipment.
Multi-Block Fire Safety Programmes Across Greater Manchester
Manchester Compliance works with managing agents, freeholders and management companies across Manchester, Salford, Stockport, Oldham, Tameside and Rochdale to deliver fire safety compliance programmes across residential block portfolios. We provide:
- Fire risk assessments and annual reviews
- Emergency lighting installation, testing and maintenance
- Fire alarm installation, testing and servicing
- Fire door surveys and remedial programmes
- Combined compliance packages with single-point reporting
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