
In January 2023 the Fire Safety (England) Regulations 2022 came into force and gave those who manage blocks of flats a set of fire door duties with fixed schedules attached. Three years on, the duties are well established but still widely misread. Too many blocks under 11 metres assume the rules do not touch them, and too many taller blocks treat the flat entrance door as somebody else's problem. Both assumptions are wrong, and both are now being tested by enforcing authorities.
The regulations attach to the responsible person as defined by the Regulatory Reform (Fire Safety) Order 2005. In a block of flats that is typically the freeholder, a resident management company, a right to manage company, or a managing agent acting on their behalf. Directors of resident-led companies should be under no illusion about where accountability sits: appointing a managing agent delegates the work, not the duty.
The most overlooked part of Regulation 10 has no height threshold at all. In any building containing two or more sets of domestic premises with common parts through which residents would need to evacuate, the responsible person must give residents information about fire doors: that they should be kept shut when not in use, that self-closing devices must not be tampered with, and that faults or damage should be reported immediately. New residents must receive this as soon as reasonably practicable after moving in, and all residents must receive it at least once in every 12-month period.
A converted house with two flats and a shared hallway is in scope. Notice boards, welcome packs and annual letters can all do the job; what counts most is being able to show the information went out, and when.
Where the building is above 11 metres in height, two further duties apply. Fire doors in communal areas must be checked at least every three months. Flat entrance doors must be checked at least every 12 months, on a best endeavours basis, because access depends on the resident behind the door.
The flat entrance door is where leasehold reality meets fire safety law. Under most leases the front door is demised to the leaseholder, who maintains it as their own. The Fire Safety Act 2021 nonetheless put those doors beyond doubt within the scope of the Fire Safety Order, and the 2022 Regulations require the responsible person to check them, whoever owns them. Ownership and the duty to check now run on separate tracks. The Order also expects responsible persons to co-operate with one another, and enforcing authorities have indicated that leaseholders themselves can be treated as responsible persons to the extent of what sits within their control.
Best endeavours is often read as a soft obligation. The regulations read differently. Regulation 10(5) requires the responsible person to keep a record of the steps taken to comply, and, in any case where access to a flat was not granted during a 12-month period, a record of the steps taken to try to gain access. A single unanswered letter is not best endeavours. Varied and repeated attempts, through different channels and at different times, with each attempt logged, is what the duty anticipates.
In practice, blocks that succeed treat access as a relationship rather than a demand. The annual information duty explains why the checks are needed; the access request then lands with residents who already understand what is being asked and why it protects them.
Government guidance describes the routine checks as simple and visual, and expects that, with appropriate instruction, caretakers, managing agents and maintenance staff can carry them out. The person checking confirms that the door closes fully from any position, that the self-closer works, that seals are present and undamaged where the door was designed with them, and that there is no damage or unauthorised alteration. No qualification is required for the routine check. A specialist should be brought in where a door appears to have been replaced with a non-fire-rated door, or where damage could affect how the door would perform in a fire, with repairs going to a competent contractor as soon as reasonably practicable.
Every part of Regulation 10 works on evidence. The information duty is only demonstrable through records of what was sent and when. The checking duties are only demonstrable through records of which doors were checked, on what date, what was found and what was done. The best endeavours duty is only demonstrable through records of attempts. A responsible person who has done everything but written nothing down is, on paper, indistinguishable from one who has done nothing.
Those records should be expected to travel. Residents ask for them, fire and rescue authorities inspect against them, buyers' solicitors request them, and when management of a block changes hands the incoming agent inherits whatever the outgoing agent kept. Blocks where the fire door record is as orderly as the service charge accounts hand over cleanly; blocks where it lives in one person's inbox do not.
Enforcement has moved from theory to practice. In February 2026 a housing association was fined more than £120,000 after admitting fire safety breaches that included a flat entrance door left without a self-closing device, following a fatal fire. The sums involved, and the reputational cost, sit far above the cost of running the checks properly.
Three years in, the duties are not onerous and were never designed to be. A complete list of doors, a routine that runs to schedule, information that goes out on time and a record behind all of it: that is the whole job. The blocks that struggle are rarely the ones short of goodwill. They are the ones that never built the routine.
Kemble Nagan is Managing Director of DoorTRACE, a UK fire door inspection and compliance management platform. This article is provided for general information and does not constitute legal advice.
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