The Building Safety Act 2022 and Fire Doors: Duties for Higher-Risk Buildings

How does the Building Safety Act 2022 affect fire doors?

The Building Safety Act 2022 is the most significant reform of building safety law in England for a generation. Passed in response to the Grenfell Tower fire, it created the Building Safety Regulator (BSR), a new dutyholder regime for higher-risk buildings, a three-stage gateway process for building work, the golden thread of building information and the requirement for safety case reports. Fire doors run through all of it: they are safety-critical products, part of the compartmentation that contains fire and smoke, and one of the datasets the new regime most clearly expects dutyholders to know, keep and evidence.

The Act does not replace existing fire safety law. The Regulatory Reform (Fire Safety) Order 2005 still requires a responsible person to assess fire risk and to keep fire doors maintained in an efficient state, in efficient working order and in good repair (Article 17), and the Fire Safety (England) Regulations 2022 still require quarterly checks of communal fire doors and annual best-endeavours checks of flat entrance doors in residential buildings over 11 metres. The Building Safety Act adds a further layer on top for the tallest residential buildings — one built around accountability, record-keeping and evidence.

What counts as a higher-risk building?

Under the Building Safety Act 2022 and the Higher-Risk Buildings (Descriptions and Supplementary Provisions) Regulations 2023, a higher-risk building in England is one that is at least 18 metres in height or has at least 7 storeys, and contains at least 2 residential units. During the design and construction phase, care homes and hospitals that meet the height threshold are also treated as higher-risk buildings, although they are not regulated as occupied higher-risk buildings once in use. The 2023 Regulations set out the detailed rules for measuring height and counting storeys.

The occupation regime applies to existing buildings as well as new ones. Every occupied higher-risk building must be registered with the Building Safety Regulator, and its accountable persons carry the duties described below regardless of when the building was constructed.

Accountable person, principal accountable person or responsible person — who does what?

Three roles matter for fire doors in a higher-risk building, and they come from two different pieces of legislation. Confusing them is one of the most common compliance errors.

The same organisation frequently holds more than one role — a local authority or housing association may be responsible person, accountable person and principal accountable person for the same block. Where the roles sit with different organisations, GOV.UK guidance for accountable persons is clear that building safety information must be shared between them. Fire door records are a prime example: Regulation 10 check outcomes gathered by the responsible person feed directly into the golden thread and safety case kept by the accountable persons.

Accountable persons cannot delegate their legal obligations. They can appoint managing agents, inspection contractors or consultants to carry out the work, but the statutory duty — and the liability — stays with them.

Where do fire doors sit in Gateways 1 to 3?

For new higher-risk buildings, and certain works to existing ones, the Act introduced three regulatory gateways — hard stops at which a project cannot proceed until the regulator is satisfied. Fire doors appear at every stage, but Gateway 2 is where doorset specifications face the most scrutiny.

Two practical consequences follow. First, a vague door specification invites questions at Gateway 2, while a specification supported by test evidence, a defined classification and third-party certification is far easier to assess. Second, substituting a different doorset mid-project is a controlled change that must be documented and may need approval — so the cheaper alternative sourced during construction can cost a project far more than it saves.

What fire door data must the golden thread hold?

The golden thread is the accurate, up-to-date body of information about a higher-risk building that dutyholders must create during design and construction and maintain throughout occupation. GOV.UK guidance requires it to be kept digitally, kept secure and kept accessible — presented in a format people can actually understand and use. For fire doors, that translates into a live door register rather than a drawer of paper certificates.

The fire door dataset

Form matters as much as content. The information should be a single, version-controlled source of truth that survives changes of ownership, management and personnel — the specific failure the golden thread was designed to prevent. BS 8644-1:2022, the code of practice for digital management of fire safety information, offers a framework for structuring it. A well-organised spreadsheet is an acceptable starting point; a folder of unsorted PDFs is not.

How do fire doors feature in the safety case report?

The principal accountable person must prepare a safety case report for an occupied higher-risk building: a document that identifies the building safety risks — defined as the spread of fire or smoke, and structural failure — and explains how they are being managed. GOV.UK guidance on preparing a safety case report expressly lists fire doors, alongside compartmentation, smoke control, detection and suppression systems, among the fire protection measures the report must describe.

The report must be given to the Building Safety Regulator when it directs the principal accountable person to apply for a building assessment certificate, or whenever it asks for it, and it must be revised as new risks or new control measures emerge — a major fire door replacement programme, for example, belongs in the next revision.

For fire doors, a credible safety case typically evidences:

• A complete, current fire door register drawn from the golden thread
• The checking regime in place — Regulation 10 quarterly and annual checks, plus any periodic detailed inspections — and its recent results
• How defects are triaged and remediated, with target timescales
• The reasoning behind any upgrade or replacement programme, including the specification chosen

What did the Grenfell Tower Inquiry say about fire doors?

The Grenfell Tower Inquiry's Phase 1 report (2019) found that fire doors at Grenfell Tower did not perform as they should have: flat entrance doors failed to hold back smoke as intended, and self-closing devices on many doors were missing or not working, which allowed smoke to spread through the building. Those findings led directly to the fire door check duties now found in Regulation 10 of the Fire Safety (England) Regulations 2022.

The Phase 2 report, published on 4 September 2024 in seven volumes, examined how the building came to be in a condition that allowed the fire to spread, and made 58 recommendations covering the regulation of construction products, the competence of those who design, build and manage buildings, and the machinery of government oversight. In its February 2025 response, the government accepted 49 recommendations in full and the remaining 9 in principle.

The lesson for anyone managing fire doors in a higher-risk building is sober and specific. Safety-critical information was lost, fragmented or never gathered, and no one could say with confidence what had been installed or how it was performing. The golden thread, the safety case and the gateway regime exist to make that state of affairs impossible to repeat. Maintaining an accurate fire door record is not paperwork for its own sake — it is the direct, practical application of the Inquiry's findings.

What should accountable persons do about fire doors now?

The following steps translate the Act's duties into a workable fire door programme for an occupied higher-risk building.

1. Confirm the building's status and roles. Establish whether the building meets the higher-risk threshold (at least 18m or 7 storeys, with 2 or more residential units), identify every accountable person and the principal accountable person, and confirm the building is registered with the Building Safety Regulator.
2. Map the roles against the responsible person. Identify who holds the Fire Safety Order duties and agree in writing how fire door information will flow between the responsible person and the accountable persons.
3. Build a complete fire door register. Survey every fire door — communal and flat entrance — and give each one a unique reference, location, type and rating.
4. Gather certification evidence door by door. Record certificate or label references and scheme details; where a door has no traceable certification, flag it for competent assessment rather than assuming compliance.
5. Confirm the Regulation 10 regime is running. Communal fire doors checked at least every 3 months, flat entrance doors at least every 12 months on a best-endeavours basis, with outcomes and access attempts recorded.
6. Digitise the records. Move door data into a secure, accessible, version-controlled digital system that satisfies the golden thread requirements and can be handed over intact.
7. Write fire doors into the safety case report. Describe the door stock, the checking regime, defect handling and any replacement programme — and update the report when the position changes.
8. Set up change control for door works. Specify any replacement or upgrade against test or certification evidence, use competent installers, and document the work back into the register.
9. Demand complete information on new work. For any building work, require Regulation 38 fire safety information and a digital door schedule as a condition of handover.
10. Review annually against the safety case. Treat the fire door dataset as living evidence: reconcile check results, defects and completed works at least once a year and after any significant event.