· Property Assessments for Landlords Services Ltd (PALS)
It is one of the questions we are asked most often, and the honest answer is not the one you might expect from a firm that carries out fire risk assessments for a living: yes, you can legally do it yourself.
What matters far more is the question underneath it — whether the assessment you produce is any good, and what happens if it isn't. This article sets out what the law actually says in England, where the Government's own guidance says you can go it alone, and the one common layout that takes your property outside that guidance altogether.
What the law actually requires
Fire safety in holiday accommodation is governed by the Regulatory Reform (Fire Safety) Order 2005. Article 9 requires the “responsible person” — usually the owner or operator — to make a suitable and sufficient assessment of the risks to which people are exposed.
Notice what that article does not say. It does not say who must carry out the assessment. It sets no qualification, no licence and no requirement to use anyone on a register. In England, as things stand, there is no legal barrier to a competent owner assessing their own premises.
That surprises people, partly because a good deal of published advice states the opposite. You may have read that since October 2023 the law requires you to appoint a competent person. Parliament did pass such a provision — article 9A, inserted by section 156(4) of the Building Safety Act 2022 — but that particular subsection has not been brought into force in England, and remains uncommenced. It is worth knowing that the rule people cite is not yet the rule.
One further point on scope: the Fire Safety Order applies to holiday lets, guest houses, B&Bs and business premises. It does not apply to an ordinary home let to a single household, where a landlord's obligations sit instead under the Housing Act 2004 and the HHSRS, alarm regulations and related rules.
The Government says you may be able to do it yourself
The Home Office publishes a guide specifically for small paying-guest accommodation, and it is refreshingly direct about self-assessment:
“It may be possible for you to assess the risk yourself, if you feel able to do so.” And later: “For small premises, preparation of a fire risk assessment can be completed, in most cases, without specialist knowledge, by following the simple steps set out in this ‘entry level’ Guide.”
So if you own a straightforward cottage and you are willing to read the guidance carefully and apply it honestly, the Government's position is that you may well be able to do this yourself. We would not argue with that.
But the guide is explicit about the premises it covers. It is limited to single premises of ground floor, or ground and first floor, sleeping a maximum of 10 people, with no more than four bedrooms on the first floor — plus individual flats, other than unusually large ones.
Where that guidance stops — and why it matters in Cornwall
Read a little further and the guide draws a hard line. It states that it is not appropriate if your premises fall outside that scope, or if:
“the design of fire safety measures in your premises differs materially from those discussed and recommended in this Guide (e.g. a 2 storey property with an open plan ground floor or a flat with a bedroom accessed only through another room).”
Read that example again, because it describes a very large share of Cornish holiday accommodation. The barn conversion with the kitchen, dining and living space knocked into one. The fisherman's cottage where the wall came down years ago. The modern build with an open-plan ground floor and bedrooms above. These are the layouts people actively want to stay in — and they are precisely the layouts the entry-level guide excludes.
The reason is not bureaucratic. In a two-storey property with an open-plan ground floor, a fire starting in the kitchen can fill the only staircase with smoke long before anyone upstairs wakes. The escape route and the fire risk occupy the same space. We wrote about exactly this after an assessment at a beautifully renovated holiday cottage — why the layout of a building can be the greatest fire risk you can't see.
If your property has that layout, self-assessment using the entry-level guide is not the right route. The guide itself directs you to the more detailed Government guidance for sleeping accommodation, which is a considerably harder document to apply without experience.
A myth worth correcting: the “annual” assessment
You will often read that an annual fire risk assessment is a legal requirement. It isn't. The Fire Safety Order requires the assessment to be reviewed regularly so that it stays up to date, and reviewed in particular where there is reason to think it is no longer valid or where there has been a significant change.
The Home Office guide puts it as: “An annual review is usually appropriate, but you must also conduct a review following any significant change to the premises, or an incident such as a fire.” Annual review is sound practice, and we recommend it. It simply isn't a statutory deadline, and you should be wary of anyone who tells you it is.
What you are taking on if you do it yourself
The duty sits with the responsible person, and it stays there. If you appoint someone to help, you are still the person the law looks to — and equally, if you write the assessment yourself and it turns out not to be suitable and sufficient, that is your exposure, not somebody else's.
Where a failure places people at risk of death or serious injury in the event of fire, the penalties are serious: an unlimited fine in the magistrates' court, or on indictment an unlimited fine and up to two years' imprisonment. In Cornwall, enforcement sits with Cornwall Fire, Rescue and Community Safety Service.
There is also a practical dimension. Since October 2023 the requirement to record your fire risk assessment applies to all premises covered by the Order — the old threshold based on employee numbers is gone — and all of your findings must be recorded, not merely the significant ones. If you are ever asked to demonstrate compliance, by a fire officer, an insurer or a booking platform, the record is what you have.
Where the rules are heading
Following the Grenfell Tower Inquiry's phase 2 report, the Government has accepted the recommendation to introduce mandatory accreditation for fire risk assessors, and has said it will legislate. Nothing is in force yet, and we would not pretend otherwise. But the direction is clear, and third-party accreditation is likely to move from a mark of quality to a requirement.
So should you do it yourself?
A reasonable rule of thumb, based on the Government's own boundaries:
- Self-assessment may well be reasonable if your property is a single ground-and-first-floor cottage, sleeps ten or fewer, has four or fewer bedrooms upstairs, has a conventional layout with an enclosed staircase and hallway, and you are willing to work carefully through the entry-level guide.
- Get a professional assessment if the ground floor is open plan, if any bedroom is reached through another room, if the property is larger or has three storeys, if it is an HMO or a block of flats, or if you simply do not feel confident interpreting the guidance — which the guide itself acknowledges as a perfectly good reason.
The honest position is that plenty of small, simple holiday lets can be assessed by their owners. The trouble is that the properties guests love most in Cornwall — open, characterful, converted — are often the ones the simple guidance was never written for.
About Property Assessments for Landlords Services Ltd (PALS)
We carry out accredited fire risk assessments for holiday lets, HMOs, blocks of flats and small businesses across Cornwall, including Truro, Newquay, St Austell, Bodmin and Liskeard.
Both our assessors are Third-Party Accredited Intermediate Fire Risk Assessors on the National Fire Risk Assessors Register (NFRAR), with over 20 years' combined experience as former Local Authority Housing Enforcement Officers. If you are unsure whether your property falls inside or outside the entry-level guidance, get in touch and we will tell you honestly — including if we think you can manage it yourself.