Fire safety duties under the Regulatory Reform (Fire Safety) Order 2005 apply to all residential blocks, regardless of height. The Building Safety Regulator's expanded oversight of 11-18m blocks is a separate development — but your obligations as Responsible Person exist today, at every height.
Quick Answers: What You Need to Know Fast
Does building safety law already apply to my mid-rise block?
Yes. Fire safety duties under the 2005 Order apply now, at all heights. The BSR's higher-risk regime (18m+) is a separate, additional layer — but mid-rise is coming into expanded scope.
Who is legally responsible for safety in an RTM-managed block?
The RTM company is typically the Accountable Person and Responsible Person for communal areas. The directors of that company carry personal liability for compliance failures.
What is the single most urgent action for RTM directors?
Ensure you have a current, competent Fire Risk Assessment. Without one, you cannot demonstrate compliance with your most basic legal duty — and the BSR can prosecute.
The short answer: RTM directors are Responsible Persons and Accountable Persons under building safety law. This means you personally carry duties around fire safety, building records, resident communication, and structural risk — not just day-to-day management. For mid-rise blocks between 11 and 18 metres, the regulatory environment is tightening significantly in 2026.
What matters practically right now: get your Fire Risk Assessment current, start building your golden thread records, and understand that the gap between best practice and legal minimum is narrowing fast for blocks in this height range.
Key Takeaways
Fire safety duties apply to all blocks right now
The Regulatory Reform (Fire Safety) Order 2005 does not have a minimum height threshold. Every residential block has a Responsible Person with active duties.
The BSR is explicitly targeting 11-18m blocks next
This is not speculation — the Building Safety Regulator has published its intention to extend formal oversight to mid-rise blocks as a second phase of the regime.
RTM directors carry personal legal liability
As directors of the RTM company — which is the Accountable Person — you are not just administrators. You are personally responsible for compliance failures in certain circumstances.
The golden thread is best practice today, law tomorrow
Maintaining comprehensive digital records of your building is not yet mandatory for mid-rise blocks — but it is the standard the BSR expects as it expands oversight.
Competitors are not covering this
Most block management advice focuses on 18m+ buildings. The gap in awareness for mid-rise RTM directors is exactly where compliance failures will occur.
The FRA is the foundation for everything else
Every other building safety obligation — resident engagement, records, remediation planning — flows from a current, competent Fire Risk Assessment.
Why Mid-Rise Blocks Are Now in the Frame
The Building Safety Act 2022 was born from the Grenfell Tower tragedy and the Hackitt Review that followed it. Its initial focus was — understandably — on the highest-risk buildings: residential blocks of 18 metres or more in height, or seven or more storeys. These are formally classified as Higher-Risk Buildings (HRBs) and are subject to mandatory registration with the Building Safety Regulator, a detailed safety case regime, and ongoing scrutiny.
But the Building Safety Regulator has been explicit that 18 metres is not the end of the story. Mid-rise blocks — broadly defined as those between 11 and 18 metres — sit in a compliance grey zone that is narrowing. The Government's response to the Grenfell Inquiry Phase 2 report, published in 2025, included a commitment to review the scope of the higher-risk regime and consult on bringing mid-rise blocks into a more structured oversight framework.
For RTM directors, this creates an uncomfortable reality: the compliance standards being developed for tall buildings are the direction of travel for your block too, even if the formal legal deadlines have not yet arrived.
There is also a more immediate concern. The existing fire safety regime already applies to your block in full. The Regulatory Reform (Fire Safety) Order 2005 — as amended by the Fire Safety Act 2021 and Fire Safety (England) Regulations 2022 — imposes duties on the Responsible Person of every multi-occupied residential building, regardless of height. Many RTM directors are unaware of the full extent of these duties, or are operating under outdated Fire Risk Assessments that predate the 2021 and 2022 amendments.
Two Overlapping Regimes: What Each Requires
Understanding the difference between the two regimes — and where they overlap for your block — is the starting point for any compliance review.
| Requirement | All Residential Blocks Now | 18m+ Higher-Risk Buildings Now |
|---|---|---|
| Fire Risk Assessment | Required — must be suitable and sufficient, reviewed regularly, carried out by a competent person | Required — with enhanced scope covering structure and external wall systems |
| BSR registration | Not required | Mandatory — blocks must be registered and receive a Building Assessment Certificate |
| Safety case report | Not required (but advisable for 11-18m) | Mandatory — must be submitted to BSR and updated following significant change |
| Golden thread records | Best practice — not yet legally mandated | Legally required — digital record of all building information |
| Accountable Person duties | Responsible Person duties under the 2005 Order apply | Formal Accountable Person role with statutory duties and BSR oversight |
| Resident Engagement Strategy | Not mandated — but Fire Safety Regs 2022 require certain information to be shared | Mandatory — must be documented and maintained |
| Mandatory reporting | Fire and building incidents must be reported to relevant authorities | Mandatory occurrence reporting to BSR on a defined list of safety events |
For mid-rise RTM directors, the practical implication is that the left-hand column is your immediate legal reality, and the right-hand column is the standards framework you should be benchmarking against now — because the BSR's extension of oversight will close the gap between them.
The Accountable Person: What the Role Means for RTM Directors
In an RTM-managed block, the RTM company is almost always the Accountable Person — which means its directors are personally in the frame for compliance failures.
Under the Building Safety Act 2022, the Accountable Person is defined as the entity that holds a legal obligation in relation to the common parts of a building — whether through a lease, licence, or statute. For RTM companies, this is typically established by the Right to Manage itself, which transfers management obligations (and their associated duties) from the freeholder to the RTM company.
The Accountable Person has a duty to:
- Assess building safety risks in the common parts
- Take reasonable steps to reduce those risks
- Record safety information and maintain it accurately
- Prepare and implement a Resident Engagement Strategy
- Notify residents of safety risks and the steps being taken
- Cooperate with the Building Safety Regulator
For buildings currently outside the formal HRB regime, these duties are not yet enforced by the BSR on the same basis as 18m+ blocks. But the Responsible Person duties under the 2005 Order are enforced by the Fire and Rescue Service — and the penalties for failures are serious. Enforcement notices, prohibition orders, and criminal prosecution are all available remedies.
The most common gap we see in RTM-managed blocks is not deliberate non-compliance — it is RTM directors who genuinely did not know the full scope of their personal obligations when they took on the role. Understanding that you are not just making management decisions but carrying statutory duties is the first and most important shift.
The Golden Thread: Building Records as a Legal Asset
The golden thread is not just a filing system — it is the evidence base that demonstrates your block is being managed safely, and it will be the first thing a regulator asks for.
The concept of a golden thread comes directly from Dame Judith Hackitt's 2018 review of building regulations. The principle is simple: everyone responsible for a building's safety should have access to accurate, current information about how the building was constructed, what changes have been made, and how it behaves in an emergency.
For formally registered higher-risk buildings, maintaining a digital golden thread is a legal requirement. For mid-rise blocks, it is not yet mandated — but the Building Safety Regulator has made clear that the absence of basic building records is itself a risk indicator when it assesses compliance culture.
A basic golden thread for a mid-rise residential block should contain:
As-built information
Original construction drawings, structural calculations, and specifications — particularly for external wall systems and fire compartmentation.
Change records
Documentation of all significant alterations since construction, including works to walls, floors, balconies, and communal systems.
Fire safety documents
All Fire Risk Assessments (current and historic), action plans, completion evidence, and certificates for fire doors and suppression systems.
Maintenance and inspection records
Planned maintenance schedules, inspection reports for communal systems, and contractor sign-offs for remediation works.
Resident information
Records of safety information provided to residents, including fire evacuation instructions and building safety communications.
External wall assessment
For any block with potentially non-compliant cladding or insulation — EWS1 form or equivalent assessment evidence.
The critical discipline is not just collecting these documents but keeping them current and accessible. A golden thread that sits in a filing cabinet and has not been updated since the last managing agent left is not a golden thread — it is a liability.
For a practical overview of your Fire Risk Assessment obligations specifically — including what competence means and how to commission one — see our guide to Fire Risk Assessments for residential blocks in 2026.
Fire Risk Assessments: What Mid-Rise Blocks Must Get Right
The Fire Risk Assessment is not an administrative checkbox — it is the live document that defines your legal duty of care and tells you exactly what remediation is required.
The Regulatory Reform (Fire Safety) Order 2005 requires the Responsible Person to ensure a suitable and sufficient Fire Risk Assessment is in place and acted upon. The Fire Safety Act 2021 and Fire Safety (England) Regulations 2022 extended this explicitly to cover the structure of the building and individual flat entrance doors — not just communal areas.
For mid-rise residential blocks, a current FRA must:
- Be carried out by a competent person — meaning someone with adequate training, knowledge, and experience for the specific type of building. Since 1 October 2023, those assessing higher-risk buildings must be registered with a third-party accreditation scheme. For mid-rise blocks, this standard is not yet mandatory — but commissioning an unqualified assessor is an enforceable failure
- Cover the structure of the building, including floors, walls, and roof, as well as communal areas
- Cover flat entrance doors — their condition, self-closing mechanisms, and compliance with fire resistance standards
- Include an action plan with prioritised remediation and target timescales
- Be reviewed and updated following any significant change to the building, occupancy, or risk profile
Stay Put vs Simultaneous Evacuation
One of the most consequential outputs of a Fire Risk Assessment for a residential block is the evacuation strategy. The default strategy for most blocks has historically been Stay Put — residents in unaffected flats remain in place while the fire brigade deals with a contained fire. This strategy relies on fire compartmentation functioning correctly.
Following Grenfell, the acceptability of Stay Put strategies has come under intense scrutiny. For mid-rise blocks where compartmentation integrity is uncertain, the FRA may recommend a Simultaneous Evacuation strategy — requiring all residents to evacuate — which has significant practical implications for fire alarm systems, signage, and resident communication.
RTM directors must understand their block's current evacuation strategy, whether it is supported by the FRA findings, and what investment would be needed to maintain or change it.
Resident Engagement: Your Duty to Communicate
Residents in your block are not passive beneficiaries of your management — under building safety law, they have rights to information and a formal route to raise concerns.
The Fire Safety (England) Regulations 2022, which came into force in January 2023, introduced specific information-sharing requirements for all multi-occupied residential buildings with two or more sets of domestic premises. The Responsible Person must:
- Provide residents with information about the risks identified in the FRA and the preventive measures in place
- Provide instructions on what to do in case of fire — including the evacuation strategy
- Notify residents of any changes to fire safety arrangements
- For blocks over 11 metres: display floor plans in entrance lobbies and provide information to the fire service about the building's layout
For buildings within the formal higher-risk regime, a Resident Engagement Strategy is a legally mandated document. For mid-rise blocks, it is not yet required — but the BSR expects to see evidence that residents are being kept informed, and the absence of any documented engagement approach is a clear red flag in any compliance review.
A practical Resident Engagement Strategy for an RTM-managed mid-rise block should cover how the RTM company communicates fire safety information, how residents can raise safety concerns, and what the response process looks like. It does not need to be complex — but it needs to exist and be followed.
Under the Building Safety Act 2022, residents can escalate safety complaints to the Building Safety Regulator if they believe the Accountable Person is not responding adequately. For blocks currently outside the HRB regime this route is more limited, but Fire and Rescue Services have their own enforcement powers — and resident complaints to the FRS are increasing. An undocumented response process leaves RTM directors exposed.
What RTM Directors Must Do Now: A Practical Checklist
The gap between where most mid-rise RTM-managed blocks are today and where they need to be is often not enormous — but it requires deliberate action, not passive assumption of compliance.
If your FRA predates the Fire Safety Act 2021 or the Fire Safety (England) Regulations 2022, it does not cover the full current scope. Commission an updated assessment from a competent, ideally accredited, assessor. This is your most urgent action.
Identify what you have, what is missing, and what is out of date. Prioritise: as-built drawings, external wall documentation, fire door inspection records, and any previous FRA action plans and their completion evidence.
Set up a document management system — even a structured shared folder — that holds all safety-critical records in one accessible location. Assign a named person responsible for keeping it current. This does not need to be expensive; it needs to be disciplined.
Know whether your block operates Stay Put or Simultaneous Evacuation. Ensure this is reflected in signage, communal notices, and any welcome pack or move-in information provided to residents.
Create a simple written record of how fire safety information is communicated to residents, how often, and what the process is for responding to safety concerns. Review it annually.
Measure your building's height from ground level to the floor of the highest residential storey. If this is 11 metres or above, you are in the BSR's stated expansion zone. If it is 18 metres or above, you are already in the formal higher-risk regime and must be registered with the BSR.
We manage blocks in this height range and the most common pattern we see when taking over from a previous agent is: an FRA that is three or four years old, action points that were never closed out, no documentation of what was communicated to residents, and building records scattered across emails and filing cabinets. None of this is unusual — but all of it is fixable, and the time to fix it is before a BSR inspection or a fire incident, not after.
Compliance Timeline: Key Dates and Milestones
The window between now and formal extension of the HRB regime to mid-rise blocks is the preparation window. RTM directors who use it to build their records, complete outstanding FRA actions, and establish resident engagement processes will be in a fundamentally different position to those who wait for mandatory deadlines.
Frequently Asked Questions
The Building Safety Act's higher-risk buildings regime currently applies to residential blocks of 18 metres or seven or more storeys. However, the BSR has signalled an intention to extend formal oversight to 11-18 metre blocks.
Crucially, fire safety duties under the Regulatory Reform (Fire Safety) Order 2005 already apply to all residential blocks regardless of height. RTM directors of mid-rise blocks must comply with these duties now and prepare for expanded building safety regulation.
Where a Right to Manage company has taken over management of a block, the RTM company is typically the Accountable Person for the common parts. Individual leaseholders are Accountable Persons for their own units.
The RTM company's directors therefore carry personal responsibility for ensuring building safety obligations are met for the communal areas of the block.
The golden thread is a digital record of all information about a building's design, construction, and any subsequent changes — maintained so that anyone responsible for the building's safety can understand what has been built and how it behaves in an emergency.
For higher-risk buildings it is a formal legal requirement. For mid-rise blocks it represents best practice today and is likely to become mandatory as the regime expands.
There is no fixed legal interval, but the 2005 Order requires the Responsible Person to ensure the FRA remains suitable and sufficient. In practice, for most residential blocks this means a full review every one to three years, or sooner following any significant change to the building's structure, use, or occupancy.
An FRA that predates the Fire Safety Act 2021 should be treated as out of scope regardless of when it was completed, as it will not cover flat entrance doors and structural elements as required.
A Resident Engagement Strategy is a documented plan for how the Accountable Person will communicate building safety information to residents and involve them in safety decisions. It is currently a formal requirement for higher-risk buildings only.
For mid-rise blocks it is not yet mandatory — but the Building Safety Regulator has indicated that resident engagement will be a key criterion as oversight expands. Documenting your approach now costs very little and protects you considerably.
Commission a current, competent Fire Risk Assessment if one does not exist or has not been reviewed since the Fire Safety Act 2021 came into force.
The FRA is the foundational compliance document from which all other building safety work flows. Without a current FRA, an RTM company cannot demonstrate it is meeting its basic legal duties as Responsible Person — and enforcement action by Fire and Rescue Services is a real, not theoretical, risk.
Get a building safety compliance audit for your block
Neon works with RTM directors across London and Essex to assess where their block stands against current and incoming building safety requirements — and to build a clear action plan without the jargon.
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