Visited a three storey 7 bed air b n b this morning, the only detection in place were smokes to the landings and heat in the kitchen all interlinked. He had also assessed it using the making your small paying guest accommodation guidance, he obviously didn't read  "single premises of ground floor, or ground and first floor, providing sleeping accommodation for a maximum of 10 persons, with no more than four bedrooms on the first floor" The owner was a little dismayed that I pointed out that he needed linked detection in all of the rooms. The unit will only be let out to groups, max 20 people with one lead person. Owing to the size of the property over three floors would mains wired detection interlinked fire alarm system require a dedicated panel?

If complying with the guidance to establish a defence against an allegation of non compliance then yes - if willing to chance it in court (along with the assessor) then they need to ensure the FRA gives a reasoned argument as to why a lesser standard than the guide still provides an adequate level of safety and keep the status quo.