Most failures of fire safety in supported accommodation are not failures of equipment. The alarms are fitted, the doors are rated and the certificate is in the file. What fails is the assumption about who is responsible and what the people living in the house can actually do when the alarm sounds. The Regulatory Reform (Fire Safety) Order 2005 requires the responsible person to make a suitable and sufficient assessment of the risks, recorded with any group of persons identified as especially at risk. In a house where residents are placed because they need support, that phrase does a great deal of work.
This article covers the assessment, the evacuation plan and the split of responsibility between the property owner and the provider. It does not repeat the certificate and room-size checklist, which is in our guide to the standards a property must meet in supported accommodation.
Fire safety in supported accommodation: the short answer
Two assessments, one plan, and usually more than one responsible person. The premises need a fire risk assessment under the Fire Safety Order, recorded and kept under review. Each resident who may be at greater risk needs a person-centred fire risk assessment that feeds into it. The evacuation strategy has to work for the actual residents at night. And the owner and provider must agree in writing who controls what.
Which law applies to a shared supported house
The Fire Safety Order covers non-domestic premises. Government guidance treats the common areas of multi-occupied residential buildings as non-domestic premises, and its guide on fire risk assessment for sleeping accommodation expressly covers the common areas of houses in multiple occupation. Since 16 May 2022 in England, the Fire Safety Act 2021 has also made clear that where a building contains two or more sets of domestic premises, the Order applies to the structure, the external walls, the common parts and the doors between each dwelling and the common parts.
Supported accommodation adds a further layer. Where support staff work at the property, parts of it are also a workplace, and the Order treats the employer as the responsible person for a workplace to the extent it is under their control. Alongside all of this, the local housing authority keeps its own powers over fire hazards in rented housing and over HMO licence conditions under the Housing Act 2004. The two regimes overlap. Neither replaces the other.
Who the responsible person is, and why there is usually more than one
Article 3 of the Order defines the responsible person. For a workplace, it is the employer, if the workplace is to any extent under their control. For other premises, it is the person who has control of the premises in connection with carrying on a trade, business or other undertaking, whether for profit or not, or otherwise the owner.
Article 5 then widens the net. Anyone who has control of the premises to any extent carries the duties so far as the matters are within their control. And a person who has an obligation, under a contract or tenancy, for the maintenance or repair of the premises or for their safety is treated as having control to the extent of that obligation.
That last point matters for anyone letting a property to a supported housing provider. A lease can allocate who does what. It cannot make the owner’s duties disappear if the owner has kept repairing obligations for the structure, the roof or the fire alarm system. In most supported housing arrangements, the realistic position is that the provider is a responsible person for the day-to-day running of the house and the owner is a responsible person for whatever the lease leaves with them. How that split usually works across the rest of the lease is set out in our landlord guide on what landlords take on when leasing to a supported housing provider.
The duty to co-operate, and what it now requires in writing
Where there is more than one responsible person, article 22 of the Order requires them to co-operate and co-ordinate. Since 1 October 2023, amendments made by the Building Safety Act 2022 go further. Each responsible person must take reasonably practicable steps to find out whether anyone else shares duties for the premises. Each must tell the others their name and a UK address for notices, and which part of the premises they consider themselves responsible for, and must keep a record of that.
In practice this is a short document, and it should exist before the first resident moves in. It names the owner and the provider, states which elements each controls (structure, alarm maintenance, emergency lighting, fire doors, common-parts management, resident briefings, evacuation), and says how each will tell the other about a new risk or a defect.
The premises fire risk assessment
Article 9 sets out what the assessment must do. It must be suitable and sufficient to identify the general fire precautions needed. It must be reviewed regularly and in particular when there is reason to suspect it is no longer valid or there has been a significant change. Since 1 October 2023, the responsible person must record the assessment or review as soon as practicable afterwards, including its findings, the measures taken or to be taken, and any group of persons identified as especially at risk.
The Order does not require the assessment to be carried out by an outside consultant. It requires it to be suitable and sufficient. For a shared house accommodating people with support needs, that bar is higher than for an ordinary let, and most providers commission a competent assessor who is familiar with specialised housing. What matters is that the assessor is told how the property is actually used, including the resident group in general terms and the staffing pattern by day and night.
A significant change in supported accommodation is not only building work. A change of client group, a move from 24-hour staffing to visiting support, or a new resident whose needs change the risk profile should all prompt a review.
The person-centred fire risk assessment
The National Fire Chiefs Council’s specialised housing guidance, published in 2017, covers sheltered, extra-care and supported housing. It is intended to help responsible persons comply with the Order and the Housing Act 2004, and it goes beyond the minimum in legislation by addressing the protection of vulnerable residents within their own private accommodation.
The research report prepared for the Building Safety Regulator in September 2025, Fire Safety: Specialised Housing and Care Homes, summarises the key distinction. The premises fire risk assessment is the Order’s requirement; person-centred fire risk assessments should be carried out in addition to it, and the two should interface.
A person-centred assessment looks at one resident. It considers the characteristics, behaviours and capabilities that could make a fire more likely or harder to escape. Depending on the person, that might include smoking or cooking habits, reliance on mobility aids or medical equipment, the ability to hear or respond to an alarm, and whether they can leave the building without help. It should result in specific measures, which might be as simple as a vibrating alarm pad or a change of bedroom, and it should be reviewed when the person’s circumstances change.
Where a resident is identified as especially at risk, that finding belongs in the premises assessment as well. That is exactly what article 9(7)(b) asks the record to include.
The evacuation strategy has to match the residents
General needs flats commonly work on a “stay put” basis. The September 2025 report records that the Scottish government and NFCC guidance both consider simultaneous evacuation appropriate for supported housing, and stay put appropriate for retirement housing and housing with care. In a shared house, that means everyone leaves when the alarm sounds.
The plan therefore has to answer three practical questions. Can every resident leave unaided, by day and at night? If not, who helps them, and are those people actually on site at the times it matters? And how is the plan kept current as residents move in and out?
Here is our view. An evacuation plan that relies on staff who are only present during the day is not a plan for the night. Where the person-centred assessments show someone cannot leave without help, the answer is to change the staffing, the accommodation offered or the placement, not to hope the fire service arrives in time. Commissioners should ask to see how night-time evacuation has been tested against the current residents, not the residents who lived there when the plan was written.
What owners, providers and commissioners should check
For a property owner:
- The lease states who maintains the alarm, emergency lighting and fire doors, and who holds the fire risk assessment.
- A written note of responsible persons exists, as article 22 now expects.
- You receive a copy of each premises assessment and its action plan.
For a provider:
- The premises assessment is recorded, current and reflects the actual resident group and staffing.
- Every resident who may be at greater risk has a person-centred assessment, and its findings feed the premises assessment.
- The evacuation plan has been tested at the times of day when staffing is lowest.
For a commissioner placing someone: ask for the date of the last premises assessment review, whether it records the groups especially at risk, and how a new resident’s person-centred assessment is completed before or at move-in.
Insurance is a separate conversation, but a related one. Insurers will want to know how the property is used and who manages fire safety, which we cover in our note on insurance and lender consent for supported housing landlords.
How Haven handles it
Our property compliance service covers the fire risk assessment, the person-centred assessments for residents, the evacuation plan and the maintenance records, and we set out in writing which elements we control and which stay with the owner before a lease starts. If you are an owner considering a lease, our page for landlord partners explains the arrangement, and you can contact the team with a specific property in mind.
Frequently asked questions
Who is the responsible person for fire safety in supported accommodation?
Usually more than one party. The provider is typically a responsible person as the employer and the party controlling day-to-day running. The owner remains one to the extent they keep control or repairing obligations under the lease. Each must co-operate, share contact details and record which part of the premises they are responsible for.
Does supported accommodation need a fire risk assessment?
Yes. The common parts of shared and multi-occupied housing fall under the Regulatory Reform (Fire Safety) Order 2005, which requires a suitable and sufficient assessment, reviewed regularly and recorded, including any group of people identified as especially at risk.
What is a person-centred fire risk assessment?
An assessment of one resident’s fire risk, looking at their characteristics, behaviours and ability to respond to an alarm and escape. NFCC specialised housing guidance recommends it in addition to the premises assessment, with the two linked so individual findings shape the building’s fire precautions.
Is stay put appropriate in supported housing?
Generally not for shared supported housing. The 2025 report for the Building Safety Regulator records that existing guidance considers simultaneous evacuation appropriate for supported housing types, so the evacuation plan must show every resident can get out, with help where needed, at any time of day.
Reviewed and signed off by Haven Living Group. Published 1 October 2026. Last updated 1 October 2026.
This article is general information about fire safety duties in supported accommodation, not legal or fire engineering advice. Your fire risk assessor and local fire and rescue service can advise on a specific property.