How many FRAs for a commercial building with flats above

[Ron]

Hello, I hope someone can assist.  Is there a definitive answer of how many FRA's are required for a building comprising:

• Building is owned by one person.
• Large RENTAL retail unit on the ground floor with independent escape routes.  Rented out by the building owner.
• 10 flats on the upper floors with independent escape routes.  Rented out by the building owner.

Is it three FRA's? 

1. One for the flats communal areas
2. One for the commercial
3. One for the entire building

Or is it two?

1. One for the flats communal areas
2. One for the commercial

Or is it something else??

Thanks for reading this far!

[AnthonyB]

It's all determined by who is a Responsible Person as per the definitions in the law:

- For the commercial unit it would be the tenant as they are both:
a) An employer having a degree of control over a workplace; &
b) A person having control of part of a premises for the carrying on of an undertaking (because they have a lease)

- For the flats it would be the person having control of the areas in common which would usually be the freeholder (although depending of the extent of their control the managing agent may be part of the mix in addition, but still 1 FRA either instructed by the agent or the freeholder direct)

So TWO FRAs with a legal duty to share relevant fire safety information and to account for all relevant persons

If the retail unit was vacant and thus back under the control of the freeholder then it could in theory be one building wide FRA, but as soon as a tenant moves into the unit there will be both changes to the premises and Responsible Person so you are back to TWO again 

 

 

[Ron]

Dear Anthony B thanks for your detailed reply. 👍

[Guest Guest]

Hello, I have a situation similar to Ron above but with less flats.  With regards to a FRA for the building itself, would this mean that the assesor would need to go into each individual flat or just the outside of each flat and outside of the shop? Each property has their own external escape route and no communal interior shared space, just exterior. 
 

I am about to start minor structural building work to the shop. The shop is rented out. Would it be my responsibility to do a FRA after the work has finished or the tenant? So far the tenant has done their own FRA. Would that be acceptable or would it need a new FRA by a professional assessor? 
 

Thank you. 

[AnthonyB]

On 30/11/2025 at 10:22, Guest Guest said:

Hello, I have a situation similar to Ron above but with less flats.  With regards to a FRA for the building itself, would this mean that the assessor would need to go into each individual flat or just the outside of each flat and outside of the shop? Each property has their own external escape route and no communal interior shared space, just exterior. 
 

I am about to start minor structural building work to the shop. The shop is rented out. Would it be my responsibility to do a FRA after the work has finished or the tenant? So far the tenant has done their own FRA. Would that be acceptable or would it need a new FRA by a professional assessor? 
 

Thank you. 

Are there internal common areas for the flats? If not then a building owner FRA would be of the exterior of the building primarily.
Where there are internal common areas as a minimum a sample of flats would need access to their hallways to inspect the front fire door properly from both sides and to check if any common fire alarm system devices are  present.
If the tenant is still in occupancy through & after the works then it is for them to review their FRA not you - it is up to them whether they do this in house or via an external accredited person.