Building Safety Act and Fire Doors: What Managing Agents Need to Know

The Building Safety Act 2022 didn't create fire door inspection duties — those come from regulation 10 of the Fire Safety (England) Regulations 2022. But it fundamentally changed the enforcement landscape around them. If you're a managing agent acting as the Responsible Person for residential buildings in England, the Building Safety Act matters because it determines who enforces fire door compliance, what powers they have, and how far back liability extends.

This guide covers the specific ways the Building Safety Act affects fire door obligations — and what managing agents should do about it.

What the Building Safety Act Changed

Before the Building Safety Act, fire safety enforcement was handled almost entirely by local fire and rescue authorities under the Regulatory Reform (Fire Safety) Order 2005. That framework still exists, but the Building Safety Act added three significant changes:

1. The Building Safety Regulator (BSR)

The Act created the BSR within the Health and Safety Executive. For higher-risk buildings (over 18 metres or 7+ storeys), the BSR is now the primary regulator. It works alongside fire and rescue authorities, not in place of them. The BSR's Joint Inspection Team conducts multi-disciplinary assessments — these aren't just fire safety visits, but building-wide safety evaluations where fire doors are one element of a broader assessment.

2. Extended liability periods

Section 39 of the Building Safety Act extended the time limit for enforcement action against non-compliant building work from 12 months to 10 years. For managing agents, this means fire door installations, replacements, and remedial works done years ago can still be challenged if they weren't compliant. A fire door replacement carried out in 2018 without proper certification is enforceable until 2028 under this extension.

3. Strengthened penalties

The Act increased maximum penalties for building regulation offences to unlimited fines and up to 2 years' imprisonment on conviction on indictment, with additional daily fines for ongoing violations.

Which Buildings Are Affected?

The Building Safety Act creates different tiers of obligation:

Higher-risk buildings (over 18m / 7+ storeys with at least 2 residential units):

• Subject to direct BSR oversight
• Must have a registered Building Safety Manager and an Accountable Person
• Require a Building Safety Case (a comprehensive safety management file)
• Fire door records form part of the Building Safety Case

Buildings over 11m (but under 18m):

• Not under direct BSR oversight
• Still subject to regulation 10 fire door inspection duties
• Still enforced by local fire and rescue authorities
• Still subject to the extended liability periods

Buildings under 11m:

• Regulation 10 fire door duties do not apply
• General fire safety duties under the Fire Safety Order still apply
• Fire doors must still be maintained under Article 17 if they form part of the fire precautions

Most small managing agents manage a mix of building heights. The practical approach: apply regulation 10 standards to all buildings over 11m, and be aware that your 18m+ buildings carry the additional BSR layer.

The Building Safety Case and Fire Doors

For higher-risk buildings, the Accountable Person must prepare and maintain a Building Safety Case. This is a comprehensive file demonstrating how fire and structural safety risks are managed. Fire door records are a core component.

A Building Safety Case that covers fire doors properly includes:

• Door inventory — location, type (FD30/FD60), installation date where known, manufacturer where known
• Inspection records — quarterly communal, annual flat entrance, with findings per door
• Remediation records — every defect tracked from discovery through repair to sign-off
• Maintenance system description — how ongoing fire door maintenance is managed (not just reactive repairs)
• Contractor records — who performed remedial works, their qualifications, certificates of completion

The BSR can request this file at any time. If your records are scattered across emails, spreadsheets, and shared drives, assembling a coherent Building Safety Case under time pressure is where things break down.

Check your current regulation 10 obligations with our requirements checker →

How the BSR Assesses Fire Door Compliance

The BSR's Joint Inspection Team doesn't just check whether fire doors close. They evaluate whether you have a system for managing fire door compliance. Based on the Grenfell Tower Inquiry annual report, the Joint Inspection Team has supported over 110 building assessments, leading to 15 enforcement actions where risks remained unresolved.

What triggers scrutiny:

• Missing inspection records — no evidence that quarterly or annual checks happened
• Long remediation gaps — defects found but not fixed for months
• No system description — inability to explain how fire door maintenance is managed across the portfolio
• Reactive-only approach — only fixing doors when something visibly fails, rather than proactive scheduled inspection

What satisfies assessors:

• Consistent, dated inspection records showing the quarterly/annual cycle is being maintained
• A clear remediation trail for every defect — discovery, priority, commission, completion
• Evidence of a documented maintenance system (not just "we inspect when we remember")
• Records of resident communication about fire doors (required by regulation 10)

The Overlap Between the Fire Safety Order and the Building Safety Act

This is where managing agents get confused. Two separate pieces of legislation create overlapping duties:

The Fire Safety Order 2005 (enforced by fire and rescue authorities):

• Requires a fire risk assessment that covers fire doors
• Article 17 requires maintenance of fire safety measures including fire doors
• Applies to all non-domestic premises and common parts of residential buildings

The Fire Safety (England) Regulations 2022 (regulation 10, also enforced by fire and rescue authorities):

• Requires specific quarterly and annual fire door inspections
• Applies only to buildings over 11m with multiple residential units
• More prescriptive than the general Fire Safety Order duties

The Building Safety Act 2022 (BSR enforcement for 18m+ buildings):

• Creates the BSR and its enforcement powers
• Requires Building Safety Cases for higher-risk buildings
• Extended liability and penalty provisions apply to building regulation breaches

For a managing agent with a portfolio spanning different building heights, the practical position is: regulation 10 sets your inspection duties, the Fire Safety Order sets your maintenance duties, and the Building Safety Act determines who enforces them (and how far back they can look).

For the full detail on regulation 10 inspection duties, see our complete requirements guide.

What Managing Agents Should Do

1. Know which tier each building falls into

Map your portfolio by height. Buildings over 18m carry BSR obligations that buildings between 11m and 18m do not. Both tiers carry regulation 10 duties. Buildings under 11m still need fire doors maintained under Article 17 but don't have the specific inspection cycle requirements.

Calculate your inspection schedule across buildings →

2. Build inspection records that would survive a BSR assessment

Even for buildings that aren't under direct BSR oversight, the standard the BSR applies is a useful benchmark. Can you produce, for any building in your portfolio:

• Inspection records for the last 12 months showing quarterly communal and annual flat entrance checks?
• A remediation trail for every defect found?
• Evidence of your maintenance system?

If the answer is no for any building, that's where to focus.

3. Don't wait for a BSR assessment to find gaps

The BSR's Joint Inspection Team has conducted over 110 assessments. If your building is over 18m, an assessment is not hypothetical — it's a question of when. Use the self-assessment approach: could you hand over a complete compliance file today if asked?

Generate a per-building inspection checklist →

4. Treat the 10-year liability window seriously

Review fire door installations and replacements carried out over the past 10 years. Were they done by qualified installers? Is there certification? If a fire door was replaced without proper third-party certification (such as through an FIRAS-registered installer), that replacement is potentially non-compliant and enforceable under the extended liability window.

Common Questions

Does the Building Safety Act apply to Scotland, Wales, or Northern Ireland?

The building safety regime (BSR, Building Safety Cases, Accountable Persons) applies to England only. Scotland, Wales, and Northern Ireland have separate building safety legislation. However, the extended limitation period for building regulation enforcement in section 39 applies to England and Wales.

I manage buildings between 11m and 18m. Does the BSR affect me?

Not directly — the BSR's primary oversight covers buildings over 18m (or 7+ storeys). But your buildings still fall under regulation 10 fire door duties enforced by fire and rescue authorities, and the extended liability period applies to all buildings.

What if I'm the managing agent but not the freeholder?

If you're acting as the Responsible Person (which managing agents typically are for the common parts), the fire door duties under regulation 10 and the Fire Safety Order fall on you. The Building Safety Act's Accountable Person duties for higher-risk buildings fall on the person with the building repairing obligation — usually the freeholder. In practice, managing agents often handle compliance on behalf of the freeholder, but the legal responsibility sits with whoever holds the relevant role.

FireDoorReady is being built to help managing agents maintain the kind of inspection, remediation, and evidence records that satisfy both fire and rescue authority enforcement and BSR assessments — across every building in your portfolio. Join the waitlist →

This guidance applies to England. Scotland, Wales, and Northern Ireland have separate fire safety and building safety legislation.

This article is general guidance, not legal advice. Consult a fire safety professional or legal adviser for advice specific to your buildings.

Sources

• Building Safety Act 2022 — legislation.gov.uk
• Building Safety Act 2022, section 39 — legislation.gov.uk
• Fire Safety (England) Regulations 2022, regulation 10 — legislation.gov.uk
• Regulatory Reform (Fire Safety) Order 2005 — legislation.gov.uk
• Regulatory Reform (Fire Safety) Order 2005, Article 17 — legislation.gov.uk
• Grenfell Tower Inquiry Phase 2: Annual Report February 2026 — GOV.UK