The changes, item by item.
| Duty | Pre-October 2023 | Now |
|---|---|---|
| Recording the assessment | Significant findings only; only if 5+ employees, licensed premises or alterations notice | Full assessment recorded, all premises, no thresholds |
| Assessor identity | Not required | Name of assessor (and organisation) recorded |
| Fire safety arrangements | Recorded only above thresholds | Recorded in all cases |
| Assessor competence | Implicit expectation | Article 9A: must not appoint an incompetent assessor (in force alongside the wider competence framework) |
| Cooperation | General duty | Identify other responsible persons, exchange names, UK addresses and the parts of the building each controls; hand over records on departure |
| Residents' information | Limited | Relevant fire safety information provided to residents of multi-occupied residential buildings in a comprehensible form |
What "recorded in full" means
The old practice of noting only significant findings no longer discharges the duty. The recorded document must show the assessment itself — hazards considered, persons at risk, the evaluation of existing measures and the conclusions — not just the deficiency list. Established methodologies such as PAS 79 already produce this; informal or verbal assessments are now non-compliant everywhere, including the smallest premises with no employees. See what a compliant report contains.
The departing responsible person
On ceasing to be the responsible person — selling a building, ending a management contract — the outgoing duty-holder must give the incoming responsible person all relevant fire safety information, including the assessment and its history. Buyers and incoming agents should demand this pack as a condition of completion.
Why it matters in practice.
- Audit exposure widened. Micro-businesses and small landlords who previously had nothing in writing are now in breach if they cannot produce a full recorded assessment. Enforcement officers ask for the document first.
- The assessor's name is on the record. Instructing an unqualified assessor is now visible on the face of the compliance document — and Article 9A makes that appointment itself a breach. See choosing a competent assessor.
- Multi-occupancy buildings must coordinate. Shops-below-flats, serviced offices and mixed-use blocks need documented information exchange between responsible persons — a gap the responsible person guide covers in detail.
"The responsible person must record the prescribed information... and must not appoint a person to make or review an assessment unless that person is competent."Fire Safety Order Articles 9(6) and 9A, as amended by s.156 Building Safety Act 2022