Fire Safety Law Guide 2026: Section 156 Recording Duties Explained

### Overview of October 2023 & 2026 Statutory Fire Duties Under Section 156 of the Building Safety Act 2022 amending the Regulatory Reform (Fire Safety) Order 2005, **all Responsible Persons within scope must record their fire risk assessment and fire safety arrangements in full**. It is a common misconception that written fire risk assessments are only required when an employer has five or more employees. While the **Health and Safety at Work etc. Act 1974** retains a five-employee threshold for written *general health and safety policies*, fire safety law has evolved. ### Who is the Responsible Person? Under Article 3 of the Fire Safety Order, the Responsible Person is defined by legal control of non-domestic premises or common parts of residential buildings. This includes: * Employers with control over workplace premises * Building owners, landlords, or managing agents for multi-occupied residential blocks * Facilities managers or duty holders with operational control ### Mandatory Recording Requirements The Responsible Person must systematically record: 1. **The Fire Risk Assessment in full**: Identifying all fire hazards, persons at risk, compartmentation observations, and existing controls. 2. **Fire Safety Arrangements**: Documenting the organisation, planning, control, monitoring, and review of fire safety measures. 3. **Identity of Assessors**: Recording the full name and organisation of any person appointed to assist with the fire risk assessment. ### Fire Risk Assessor Competence Reform Position (2026 Update) Government has committed to mandatory competence requirements for fire risk assessors. Following public consultation, government continues to analyze responses regarding statutory assessor certification frameworks. Currently, competence is demonstrated through professional registration on recognised independent registers such as the **National Fire Risk Assessor Register (NFRAR)** and individual membership in bodies such as the **Institution of Fire Engineers (IFE)** and **Institution of Fire Safety Managers (IFSM)**.