Since 23 January 2023, blocks of flats in England above a certain height have had a specific, recurring legal duty to check their fire doors. It is one of the most commonly missed obligations we come across, partly because it sits in the Fire Safety (England) Regulations 2022 rather than in the older fire safety order most people know about.
This article sets out who the duty applies to, exactly what it requires, and what a check should actually involve.
The short version
If your building contains two or more sets of domestic premises and the top storey is more than 11 metres above ground level — in practice, more than four storeys — then as the responsible person you must:
- carry out quarterly checks of all fire doors in the common parts, including their self-closing devices; and
- carry out annual checks of all flat entrance doors that open onto common parts, on a best endeavours basis.
Below 11 metres, those specific frequencies do not apply. That is not the same as the doors being exempt. They remain part of the fire risk assessment you must carry out under the Regulatory Reform (Fire Safety) Order 2005, and a competent assessor will still expect to see them maintained.
The duty that applies to every block, at any height
There is a second, separate duty that catches far more buildings. Under Regulation 11, the responsible person for any building with two or more sets of domestic premises — regardless of height — must give residents information about fire doors.
In practice that means telling residents that fire doors should be kept shut when not in use, that they should not be tampered with or altered, and that residents should report any fault or damage to the responsible person. This information must be given to new residents when they move in, and repeated to all residents at least every twelve months.
If you manage a two-storey converted house with three flats, Regulation 10 does not apply to you but Regulation 11 does.
What a check actually involves
A good deal of confusion here comes from the word "check". This is not third-party certification and it is not a destructive inspection. It is a structured visual and functional check, and it covers:
- Closing action. Does the door close fully onto the latch from any open angle, under the power of its own self-closing device? A door that stops an inch short is a failed door.
- Seals. Are the intumescent strips and cold smoke seals present, continuous, and undamaged? Painted-over or missing sections are a common finding.
- Gaps. Is the gap between the leaf and the frame consistent, and within the tolerance given by the door's documentation? Excessive gaps at the head or sides let smoke pass long before flame does.
- Hardware. Hinges secure and not worn, no missing screws, glazing intact and correctly beaded, signage present and correct.
- Abuse. Has the door been propped, wedged, damaged, or had a letterbox, cat flap or additional lock fitted after installation? Alterations are one of the most frequent causes of failure in occupied blocks.
Anything found defective should be recorded, prioritised and remedied. A check that produces no written output is very difficult to rely on later.
Who is allowed to do the checks
The regulations do not name a qualification for the routine checks themselves. They place the duty on the responsible person to make sure the checks are done, and it follows that whoever carries them out needs to be competent for that task.
That is a different question from who assesses whether the doors are adequate. That judgement belongs in the fire risk assessment, which under Article 18 of the Fire Safety Order must be carried out by a competent person — someone with sufficient training, experience or knowledge to do it properly.
Record keeping, and why it matters more than it used to
There is no prescribed template. What you need is the ability to demonstrate, after the fact, that the checks happened. For each round of checks, record the date, who did it, which doors were covered, what was found and what was done about it.
This has become more important since section 156 of the Building Safety Act 2022 came into force, which requires responsible persons to record their fire risk assessment and their fire safety arrangements in full. Enforcement increasingly turns on documentation rather than on the condition of the building on the day of the visit.
The access problem, and how "best endeavours" works
The annual check of flat entrance doors is where most managing agents get stuck, because leaseholders and tenants do not always let you in.
The phrase "best endeavours" is doing real work here. You are not required to force entry. You are required to make a genuine, documented effort: written requests, offered appointment slots, follow-ups after non-response, and a record of each attempt. A file showing three ignored letters and two missed appointments is a defensible position. A file showing nothing is not.
Where this sits in your wider duties
Fire doors are one element of a much larger picture. They only do their job if the compartmentation around them is intact, the escape routes they protect are usable, and the management arrangements behind them are real. That is what the fire risk assessment is for, and the door checks flow from it rather than replacing it.
If you are unsure whether Regulation 10 applies to a building you are responsible for, the measurement that matters is the height of the floor surface of the top storey above ground level — not the ridge of the roof, and not the number of floors on the plan.