🔥 Fire Compliance Guide
What is the RRO? The Regulatory Reform (Fire Safety) Order 2005 Explained
What is the RRO?
The Regulatory Reform (Fire Safety) Order 2005 — commonly known as the RRO or the Fire Safety Order — is the primary fire safety legislation in England and Wales. It came into force on 1 October 2006 and replaced approximately 70 separate pieces of fire safety legislation with a single, unified, risk-based framework.
Before the RRO, businesses had to navigate a patchwork of Acts and Regulations — including the Fire Precautions Act 1971 and the Fire Precautions (Workplace) Regulations 1997 — and could rely on a fire certificate issued by the fire authority as evidence of compliance. The RRO abolished fire certificates entirely. Compliance is now the ongoing responsibility of the Responsible Person, not the fire service.
The shift matters. Under the old system, a certificate could give a false sense of permanence. Under the RRO, fire safety is a living duty — it must be assessed, maintained, reviewed and documented continuously.
The RRO applies in England and Wales only. Scotland is governed by the Fire (Scotland) Act 2005 and Northern Ireland by the Fire and Rescue Services (Northern Ireland) Order 2006.
What premises does the RRO apply to?
The RRO applies to virtually all non-domestic premises in England and Wales. This is intentionally broad. Covered premises include:
- All workplaces — offices, factories, warehouses, workshops, retail premises
- Hotels, hostels, guesthouses and licensed premises
- Schools, colleges, nurseries and universities
- Hospitals, care homes, GP surgeries and healthcare facilities
- Places of worship, community halls and entertainment venues
- The common parts of residential buildings — corridors, stairwells, lobbies, plant rooms and bin stores in blocks of flats and HMOs
- External and open areas associated with non-domestic premises, including loading bays, car parks and estate roads
The RRO does not apply inside individual private dwellings (single private homes). However, as soon as any part of a building is used for work or provides public access, those areas fall within scope.
Who is the Responsible Person?
This is one of the most important concepts in the RRO. Article 3 defines the Responsible Person as:
- In a workplace: the employer, where the workplace is to any extent under their control
- In other premises: the person who has control of the premises in connection with carrying on a trade, business or other undertaking
- Where no other person has control: the owner of the premises
In practice, the Responsible Person is most commonly the employer, building owner, landlord, or managing agent. In larger or more complex buildings — such as multi-tenanted offices, shopping centres or blocks of flats — there may be more than one Responsible Person, each responsible for the areas under their control. Where this is the case, they must cooperate and coordinate their fire safety measures.
Being the Responsible Person is a legal duty that cannot be fully delegated. You can appoint a fire safety specialist or contractor to carry out risk assessments and maintain equipment on your behalf — but you remain legally accountable for the outcome. If a contractor fails in their duties, enforcement action can still be taken against you as the Responsible Person.
What are the Responsible Person's duties?
The core duties are set out in Articles 8 to 22 of the RRO. They include:
- Carry out a suitable and sufficient fire risk assessment (Article 9) and keep it under review. Since October 2023, all Responsible Persons must record this assessment in full.
- Implement and maintain fire safety arrangements — planning, organisation, control, monitoring and review of all preventive and protective measures.
- Provide appropriate fire-fighting equipment — fire extinguishers, hose reels and automatic suppression systems suitable for the risk.
- Install and maintain fire detection and alarm systems capable of detecting a fire and raising the alarm across the premises.
- Maintain emergency routes and exits — kept clear at all times, clearly signed and opening in the direction of escape.
- Ensure emergency lighting is installed and maintained to illuminate escape routes if normal lighting fails.
- Provide fire safety training to all employees on induction and at regular intervals thereafter.
- Establish emergency procedures including evacuation plans, assembly points and fire drills.
- Appoint a competent person to assist in meeting fire safety duties — someone with sufficient training and experience.
- Keep records of risk assessments, maintenance activities, test results and training.
The fire risk assessment — a closer look
The fire risk assessment sits at the heart of the RRO. It is not a one-off exercise — it is a living document that must be reviewed whenever there is reason to believe it is no longer valid (for example, after a change of use, a structural alteration, or a significant increase in the number of occupants).
A suitable and sufficient fire risk assessment must:
- Identify all fire hazards in the premises — ignition sources, fuel sources and oxygen sources
- Identify all people at risk, giving particular attention to those who may be especially vulnerable
- Evaluate the risk and decide whether existing fire precautions are adequate
- Record the findings (mandatory for all Responsible Persons since October 2023)
- Prepare an emergency plan and make it available to employees and relevant persons
- Review and update the assessment regularly and whenever circumstances change
For straightforward, lower-risk premises — such as a small office — the Responsible Person can carry out the assessment themselves using the government's published guidance. For larger, more complex or higher-risk premises, a competent fire risk assessor should be engaged.
How has the law changed since 2006?
The RRO has been strengthened significantly since it came into force, primarily in response to the Grenfell Tower fire in 2017.
How is the RRO enforced?
The RRO is enforced by local Fire and Rescue Authorities. In certain specialist premises (such as nuclear sites, construction sites and ships), the Health and Safety Executive (HSE) takes on the enforcement role.
Fire safety inspectors have the power to enter premises at any reasonable time, inspect fire risk assessments, require the production of records, and take enforcement action. Inspections are risk-based — higher-risk premises such as care homes, hotels, HMOs and high-rise residential buildings receive more frequent scrutiny.
Enforcement action can take several forms, in escalating order of seriousness:
- Informal advice — guidance on improvements, with no legal obligation attached
- Enforcement notice — requiring specific improvements within a set timeframe
- Alterations notice — requiring notification to the authority before certain changes are made to high-risk premises
- Prohibition notice — immediate restriction or prohibition of use where there is serious risk to life
- Prosecution — criminal proceedings under Article 32 of the RRO
Penalties for non-compliance
The penalties for breaching the RRO are serious. Company directors, senior managers and individuals can all be prosecuted personally — not just the organisation.
| Offence Level | Maximum Penalty | Examples |
|---|---|---|
| Minor | Fine up to £5,000 | Failure to provide information to employees; obstructing an inspector |
| Serious | Unlimited fine on conviction on indictment |
Failure to carry out a fire risk assessment; failing to maintain equipment |
| Most Serious | Unlimited fine and/or up to 2 years imprisonment |
Failure to comply with a prohibition notice; placing persons at serious risk |
Beyond criminal penalties, non-compliance can also void insurance coverage, expose the organisation to civil claims for damages following a fire, and result in the details of enforcement notices and prosecutions being published on the Fire and Rescue Authority's public enforcement register.
High-profile prosecutions under the RRO have resulted in fines including a £400,000 fine against New Look following a fire at their Oxford Street store, and numerous prosecutions of hotel operators, care home providers and landlords across England and Wales. Ignorance of the law is not a defence.
The duty to maintain — what does it cover?
Article 17 of the RRO requires the Responsible Person to ensure that all fire safety equipment, facilities and devices are subject to a suitable system of maintenance and are kept in an efficient state, in efficient working order and in good repair.
In practical terms, this means keeping records of all inspections and service visits for key fire safety assets, including:
- Fire extinguishers — monthly visual checks and annual service under BS 5306-3; 5-year extended service for most types; 10-year overhaul for CO2
- Fire doors — professional inspection at least every 6 months under BS 9999; quarterly checks for communal doors in higher-risk residential buildings
- Emergency lighting — monthly functional flick test and annual 3-hour duration test under BS 5266 / BS EN 50172
- Fire alarm systems — weekly manual call point test; quarterly and annual service by a competent engineer under BS 5839-1
- Fire suppression systems and sprinklers — annual inspection and service under BS EN 12845
- Dry and wet risers — annual inspection and wet test under BS 9990
All maintenance activities must be documented. A fire safety logbook — whether paper or digital — is the standard means of recording this. Records must be available on request from the enforcing authority.
Summary — key RRO facts at a glance
- Full name: The Regulatory Reform (Fire Safety) Order 2005
- In force: 1 October 2006
- Applies to: England and Wales — virtually all non-domestic premises and common parts of residential buildings
- Replaced: Approximately 70 separate pieces of fire safety legislation, including the Fire Precautions Act 1971
- Core duty: The Responsible Person must carry out a fire risk assessment, implement fire precautions, maintain all equipment and keep records
- Enforced by: Local Fire and Rescue Authorities (and HSE in certain premises)
- Penalties: Up to unlimited fines and 2 years imprisonment for serious offences
- Strengthened by: Fire Safety Act 2021, Fire Safety (England) Regulations 2022, Building Safety Act 2022
🔥 Fire Compliance Guide
What is the RRO? The Regulatory Reform (Fire Safety) Order 2005 Explained
What is the RRO?
The Regulatory Reform (Fire Safety) Order 2005 — commonly known as the RRO or the Fire Safety Order — is the primary fire safety legislation in England and Wales. It came into force on 1 October 2006 and replaced approximately 70 separate pieces of fire safety legislation with a single, unified, risk-based framework.
Before the RRO, businesses had to navigate a patchwork of Acts and Regulations — including the Fire Precautions Act 1971 and the Fire Precautions (Workplace) Regulations 1997 — and could rely on a fire certificate issued by the fire authority as evidence of compliance. The RRO abolished fire certificates entirely. Compliance is now the ongoing responsibility of the Responsible Person, not the fire service.
The shift matters. Under the old system, a certificate could give a false sense of permanence. Under the RRO, fire safety is a living duty — it must be assessed, maintained, reviewed and documented continuously.
The RRO applies in England and Wales only. Scotland is governed by the Fire (Scotland) Act 2005 and Northern Ireland by the Fire and Rescue Services (Northern Ireland) Order 2006.
What premises does the RRO apply to?
The RRO applies to virtually all non-domestic premises in England and Wales. This is intentionally broad. Covered premises include:
- All workplaces — offices, factories, warehouses, workshops, retail premises
- Hotels, hostels, guesthouses and licensed premises
- Schools, colleges, nurseries and universities
- Hospitals, care homes, GP surgeries and healthcare facilities
- Places of worship, community halls and entertainment venues
- The common parts of residential buildings — corridors, stairwells, lobbies, plant rooms and bin stores in blocks of flats and HMOs
- External and open areas associated with non-domestic premises, including loading bays, car parks and estate roads
The RRO does not apply inside individual private dwellings (single private homes). However, as soon as any part of a building is used for work or provides public access, those areas fall within scope.
Who is the Responsible Person?
This is one of the most important concepts in the RRO. Article 3 defines the Responsible Person as:
- In a workplace: the employer, where the workplace is to any extent under their control
- In other premises: the person who has control of the premises in connection with carrying on a trade, business or other undertaking
- Where no other person has control: the owner of the premises
In practice, the Responsible Person is most commonly the employer, building owner, landlord, or managing agent. In larger or more complex buildings — such as multi-tenanted offices, shopping centres or blocks of flats — there may be more than one Responsible Person, each responsible for the areas under their control. Where this is the case, they must cooperate and coordinate their fire safety measures.
Being the Responsible Person is a legal duty that cannot be fully delegated. You can appoint a fire safety specialist or contractor to carry out risk assessments and maintain equipment on your behalf — but you remain legally accountable for the outcome. If a contractor fails in their duties, enforcement action can still be taken against you as the Responsible Person.
What are the Responsible Person's duties?
The core duties are set out in Articles 8 to 22 of the RRO. They include:
- Carry out a suitable and sufficient fire risk assessment (Article 9) and keep it under review. Since October 2023, all Responsible Persons must record this assessment in full.
- Implement and maintain fire safety arrangements — planning, organisation, control, monitoring and review of all preventive and protective measures.
- Provide appropriate fire-fighting equipment — fire extinguishers, hose reels and automatic suppression systems suitable for the risk.
- Install and maintain fire detection and alarm systems capable of detecting a fire and raising the alarm across the premises.
- Maintain emergency routes and exits — kept clear at all times, clearly signed and opening in the direction of escape.
- Ensure emergency lighting is installed and maintained to illuminate escape routes if normal lighting fails.
- Provide fire safety training to all employees on induction and at regular intervals thereafter.
- Establish emergency procedures including evacuation plans, assembly points and fire drills.
- Appoint a competent person to assist in meeting fire safety duties — someone with sufficient training and experience.
- Keep records of risk assessments, maintenance activities, test results and training.
The fire risk assessment — a closer look
The fire risk assessment sits at the heart of the RRO. It is not a one-off exercise — it is a living document that must be reviewed whenever there is reason to believe it is no longer valid (for example, after a change of use, a structural alteration, or a significant increase in the number of occupants).
A suitable and sufficient fire risk assessment must:
- Identify all fire hazards in the premises — ignition sources, fuel sources and oxygen sources
- Identify all people at risk, giving particular attention to those who may be especially vulnerable
- Evaluate the risk and decide whether existing fire precautions are adequate
- Record the findings (mandatory for all Responsible Persons since October 2023)
- Prepare an emergency plan and make it available to employees and relevant persons
- Review and update the assessment regularly and whenever circumstances change
For straightforward, lower-risk premises — such as a small office — the Responsible Person can carry out the assessment themselves using the government's published guidance. For larger, more complex or higher-risk premises, a competent fire risk assessor should be engaged.
How has the law changed since 2006?
The RRO has been strengthened significantly since it came into force, primarily in response to the Grenfell Tower fire in 2017.
How is the RRO enforced?
The RRO is enforced by local Fire and Rescue Authorities. In certain specialist premises (such as nuclear sites, construction sites and ships), the Health and Safety Executive (HSE) takes on the enforcement role.
Fire safety inspectors have the power to enter premises at any reasonable time, inspect fire risk assessments, require the production of records, and take enforcement action. Inspections are risk-based — higher-risk premises such as care homes, hotels, HMOs and high-rise residential buildings receive more frequent scrutiny.
Enforcement action can take several forms, in escalating order of seriousness:
- Informal advice — guidance on improvements, with no legal obligation attached
- Enforcement notice — requiring specific improvements within a set timeframe
- Alterations notice — requiring notification to the authority before certain changes are made to high-risk premises
- Prohibition notice — immediate restriction or prohibition of use where there is serious risk to life
- Prosecution — criminal proceedings under Article 32 of the RRO
Penalties for non-compliance
The penalties for breaching the RRO are serious. Company directors, senior managers and individuals can all be prosecuted personally — not just the organisation.
| Offence Level | Maximum Penalty | Examples |
|---|---|---|
| Minor | Fine up to £5,000 | Failure to provide information to employees; obstructing an inspector |
| Serious | Unlimited fine on conviction on indictment |
Failure to carry out a fire risk assessment; failing to maintain equipment |
| Most Serious | Unlimited fine and/or up to 2 years imprisonment |
Failure to comply with a prohibition notice; placing persons at serious risk |
Beyond criminal penalties, non-compliance can also void insurance coverage, expose the organisation to civil claims for damages following a fire, and result in the details of enforcement notices and prosecutions being published on the Fire and Rescue Authority's public enforcement register.
High-profile prosecutions under the RRO have resulted in fines including a £400,000 fine against New Look following a fire at their Oxford Street store, and numerous prosecutions of hotel operators, care home providers and landlords across England and Wales. Ignorance of the law is not a defence.
The duty to maintain — what does it cover?
Article 17 of the RRO requires the Responsible Person to ensure that all fire safety equipment, facilities and devices are subject to a suitable system of maintenance and are kept in an efficient state, in efficient working order and in good repair.
In practical terms, this means keeping records of all inspections and service visits for key fire safety assets, including:
- Fire extinguishers — monthly visual checks and annual service under BS 5306-3; 5-year extended service for most types; 10-year overhaul for CO2
- Fire doors — professional inspection at least every 6 months under BS 9999; quarterly checks for communal doors in higher-risk residential buildings
- Emergency lighting — monthly functional flick test and annual 3-hour duration test under BS 5266 / BS EN 50172
- Fire alarm systems — weekly manual call point test; quarterly and annual service by a competent engineer under BS 5839-1
- Fire suppression systems and sprinklers — annual inspection and service under BS EN 12845
- Dry and wet risers — annual inspection and wet test under BS 9990
All maintenance activities must be documented. A fire safety logbook — whether paper or digital — is the standard means of recording this. Records must be available on request from the enforcing authority.
Summary — key RRO facts at a glance
- Full name: The Regulatory Reform (Fire Safety) Order 2005
- In force: 1 October 2006
- Applies to: England and Wales — virtually all non-domestic premises and common parts of residential buildings
- Replaced: Approximately 70 separate pieces of fire safety legislation, including the Fire Precautions Act 1971
- Core duty: The Responsible Person must carry out a fire risk assessment, implement fire precautions, maintain all equipment and keep records
- Enforced by: Local Fire and Rescue Authorities (and HSE in certain premises)
- Penalties: Up to unlimited fines and 2 years imprisonment for serious offences
- Strengthened by: Fire Safety Act 2021, Fire Safety (England) Regulations 2022, Building Safety Act 2022