Why Your Current Fire Risk Assessment Might Now Be a Liability

If you manage an education estate, the push for stricter competency standards probably isn't news to you. You likely already know that BS 8674:2025 introduced a strict framework for fire risk assessors. What is new, however, is the mechanism the government has just activated to enforce it—and how easily it could catch out highly organised schools and trusts alike.

Possessing the right compliance document written by the wrong person is rapidly becoming a board-level liability.

Here is what just happened, and why it changes the immediate landscape for your estate.

The Digital Trap Closes

If you’ve been following the Smarter Estate Management newsletter over the last few weeks, you’ll have already read about the launch of the DfE’s new Manage Your Education Estate digital service in February 2026. This isn't just a new portal; it represents a major shift from the DfE acting as a guidance provider to a data-driven regulator.

Because of this launch, mandatory Estate Management Self-Assessment (EMSA) returns will begin this Autumn. These returns require you, as the Responsible Body, to declare that you have up-to-date risk assessments conducted by "competent persons".

This is where the older guidance meets the new enforcement reality.

The Competency Gap

For decades, the definition of a "competent person" under the Regulatory Reform (Fire Safety) Order 2005 was highly subjective. The BS 8674 framework ended that ambiguity by establishing a three-tier model: Foundation, Intermediate, and Advanced.

The standard requires the complexity of a building to be matched by the competency of the assessor. A Foundation-level assessor is fine for a stand-alone nursery, but using them for a multi-story secondary school is a dangerous practice. The government has confirmed that mandatory competence will be independently verified by UKAS-accredited bodies, fulfilling a core recommendation of the Grenfell Tower Inquiry Phase 2 report.

Here is the tension for this Autumn: if you declare your fire risk assessment is "suitable and sufficient" on your EMSA return, but the FRA in your filing cabinet was completed by an unaccredited assessor for a complex block, you may be making a false declaration. For trusts, the Academy Trust Handbook now explicitly links these exact estate management failings to formal "Notices to Improve" (NtIs), while maintained schools face equally strict regulatory interventions.

The Insurance Void

The ultimate consequence of failing to align your older documentation with these new reporting mechanisms isn't just a regulatory intervention; it is severe financial exposure.

Insurers are increasingly scrutinising the quality of fire risk assessments when evaluating claims. If a fire occurs and the insurer discovers the FRA was conducted by an assessor without the correct UKAS accreditation for that building's risk profile, they have the right to void the claim entirely. In that scenario, the MAT or local authority could be personally liable for tens of millions of pounds in rebuilding costs.

The defensible position for an estate manager in 2026 is built on verified professional competency and transparent digital accountability. The standards might not be brand new, but the mechanisms tracking them are officially live.

Statlog... More than just compliance and premises software