Fire Risk Assessor Competence: What the Standard Says and What Changes on 31 March 2026

From 1 April 2026, BAFE SP205 Version 6 governs all certification audits under the BAFE scheme for fire risk assessors. Audits before 31 March 2026 follow the current scheme. The Version 6 scheme moves to a tiered structure aligned with BS 8674:2025, the British Standard for fire risk assessor competence published last year. The scheme remains voluntary.

The statutory test has not moved. Article 18 of the Regulatory Reform (Fire Safety) Order 2005 still defines a competent person as someone with "sufficient training and experience or knowledge and other qualities." That is the full definition. No qualification is named. No register is referenced. No inspection of the assessor's work is required before the assessment is handed over.

Where the standard sits today

Article 9 of the Fire Safety Order places the duty to make a suitable and sufficient assessment on the responsible person. Article 18 allows that person to appoint others to assist with making or reviewing it, and defines a competent person as someone with "sufficient training and experience or knowledge and other qualities" for the task. The Order does not name a qualification, register, or audit body to evidence that.

BAFE SP205 is a UKAS-accredited certification scheme for individual and organisational fire risk assessors. Registered assessors are audited by a certification body, must carry professional indemnity insurance, and are subject to periodic surveillance of their working practices. Separately, the Institution of Fire Engineers runs a register of fire risk assessors admitted through peer review. PAS 79-1:2020, the BSI code of practice for fire risk assessments of non-housing premises, sets the methodology those schemes work to.

None of this is compulsory under the Order. A publican may conduct their own fire risk assessment under Article 18 for a simple premises. An external assessor may hold no third-party certification and still meet the Article 18 test, provided their training, experience and knowledge are "sufficient" for the premises in question.

What changes from 1 April 2026

BAFE's announcement sets out the Version 6 structure: "the Scheme takes a tiered approach recognising fire risk assessors at foundation, immediate and advanced levels." The tiers align with the structure in BS 8674:2025. BAFE's transition FAQ confirms that audits taking place before 31 March 2026 follow the current scheme, and that "From 1 April 2026 onwards, all certification audits will be conducted in line with the Version 6 scheme requirements." Existing registrants are assessed against the new requirements at their next surveillance audit. The regulated qualifications BAFE references are not mandatory under the scheme until 31 March 2028.

Because the BAFE scheme is voluntary and Article 9A remains uncommenced, an assessor who holds no BAFE registration is not for that reason barred from operating under the Order.

The Article 9A question

Section 156(4) of the Building Safety Act 2022 inserted Article 9A into the Fire Safety Order. Article 9A reads: "The responsible person must not appoint a person to assist them with making or reviewing an assessment under article 9 unless that person is competent." It defines competence as "sufficient training and experience or knowledge and other qualities to enable the person properly to assist in making or reviewing the assessment." The provision is on the statute book. No commencement order has been made, and as of April 2026 it is not in force.

Once Article 9A is commenced, appointing an assessor who is not competent will breach the Order in its own right. While it remains uncommenced, the route for evidencing competence under the Order continues to run through the Article 18 wording.

Where the duty sits

Article 9(1) places the duty to make and review a suitable and sufficient fire risk assessment on the responsible person. Article 18 lets the responsible person bring in external help to make or review it; the appointment does not transfer the Article 9 duty.

MHCLG enforcement data for 2024/25 shows fire risk assessments were the third most common area of non-compliance. Of 51,020 audits, 8,471 cited problems with the assessment itself. The Order's enforcement powers fall on the responsible person, regardless of who drafted the document.

The Huddersfield sports bar fined £160,000 in 2025 was prosecuted for failure to comply with an enforcement notice the fire service had already served. The section 156 briefing sets out what the Order now requires on paper, and the parallel report on fire safety prosecution cases tracks recent FSO prosecutions.