In short: Fire-safety competence in England and Wales is not governed by one new workforce-wide standard. The Fire Safety Order requires adequate safety training for employees and competence for people appointed or nominated to specified functions, while newer standards and proposals apply to narrower professional or specialist roles (Great Britain, 2005). Organisations therefore need evidence that is proportionate to the function performed, the setting involved and the authority the person is expected to exercise.
Fire Safety Competence Expectations in England and Wales: Can Your Organisation Evidence the Right Capability?
A current training record does not necessarily establish that someone has the capability or authority required for every fire-safety function attached to their role. The stronger test is whether the evidence behind the person matches what they are actually expected to recognise, carry out, interpret, approve or escalate.
Responsibilities can also change without the training matrix changing. When a role moves from following or reporting to interpreting, approving or specifying, the competence decision may need to change with it.
The Fire Safety Order applies in England and Wales, while some of the professional standards, policy developments and proposals considered here apply only in England. The scope includes employees and externally engaged specialists on whom the organisation relies; Scotland and Northern Ireland have separate legal regimes.
What Has Changed in Fire Safety Competence Expectations?
Recent developments around fire-safety competence include stronger record-keeping duties, a British Standard for individual fire risk assessor competence and proposals for statutory regulation of specialist professions. Existing law continues to distinguish employee training from competence required for specified functions.
Established law already treats employee fire-safety training separately from the appointment of competent people to assist with specified fire-safety duties. Article 21 requires adequate employee training at the start of employment and when new or increased risks arise (Great Britain, 2005). Training must be repeated periodically where appropriate and adapted to new or changed risks.
What Does the Fire Safety Order Already Require?
Where their provisions apply, Articles 13, 15 and 18 require competent people for specific functions, including implementing firefighting measures, implementing evacuation procedures and assisting with preventive and protective measures (Great Britain, 2005).
Articles 13(4), 15(3) and 18(5) each define competence by reference to sufficient training and experience, or knowledge and other qualities, to perform the relevant function properly. These competence tests are function-specific; they are not a blanket competence standard for every employee.
The table separates current law, an uncommenced provision, a British Standard, a closed consultation and future policy.
| Development | Current Status | Scope | What It Means Now |
|---|---|---|---|
| Fire Safety Order duties | Current law | England and Wales | Employee training and competence for specified functions are separate requirements. |
| Section 156 changes from 1 October 2023 | Current law | Responsible Persons under the Fire Safety Order in England and Wales | Full fire risk assessments and arrangements must be recorded, together with the identity of anyone engaged to make or review the assessment. |
| Section 156(4), which would insert Article 9A | Enacted but not commenced | Responsible Persons appointing someone to make or review an assessment in England and Wales | As of 10 September 2026, the competence duty is not in force. The 2023 commencement instruments expressly excluded section 156(4), while government guidance recommends ensuring assessors are competent in the meantime. |
| BS 8674:2025 (British Standards Institution, 2025) | British Standard | Individual fire risk assessors | It describes skills, knowledge, experience and behaviours for the profession. It is not legislation or a workforce-wide standard. |
| Fire risk assessor profession consultation | Closed consultation | England | The 2026 proposals cover competence requirements, verification, certification and regulation. |
| Government-accepted principles | Regulation not yet implemented | Fire engineers | Government has accepted principles for regulating the title and function, but whether the framework will be UK-wide or England-only, the primary legislation and detailed implementation remain future work. |
What Is the Current Position on Article 9A?
Section 156(4) of the Building Safety Act 2022, which would insert Article 9A into the Fire Safety Order, remains uncommenced in England and Wales.
The 2023 commencement instruments for both jurisdictions expressly excluded subsection (4), while Home Office and Welsh Government guidance state that the competence requirement is to be brought into force at a later date (Home Office, 2023b; Welsh Government, 2023). The 2023 recording changes improve traceability but do not themselves prescribe a qualification for fire risk assessors.
What Is Proposed for Fire Risk Assessors and Fire Engineers?
The 2026 fire risk assessor consultation proposed consistent competence requirements and verification within a regulated profession in England (Ministry of Housing, Communities and Local Government, 2026). It closed on 18 June 2026.
As of 10 September 2026, the government response had not been published. Government said it was analysing the consultation responses ahead of a formal response in autumn 2026. The May 2026 implementation timetable places primary legislation to implement Recommendation 26 in the 2027 to 2029 period, when Parliamentary time allows (HM Government, 2026).
For fire engineers, the government has accepted principles for future regulation (Ministry of Housing, Communities and Local Government, 2025). The Fire Engineers Advisory Panel statement says expressly that it is not a detailed competence framework (Fire Engineers Advisory Panel, 2025).
Together, these developments make role boundaries and expectations around evidencing competence more explicit, particularly for fire risk assessors. For fire engineers, the detailed competence and regulatory framework remains under development.
What Is the Difference Between Fire Safety Training and Competence?
A fire-safety training record can show the content delivered, the completion date and, where an assessment was used, the learner’s result, while a competence decision asks whether the person can perform an authorised function properly in the relevant setting.
What Can Fire Safety Training Evidence?
Suitable fire-safety training remains a required part of the arrangement for employees and can build relevant understanding and a common basis for action. Training must remain suitable for the risks and responsibilities involved. Our guide to mandatory safety training covers the wider question of which subjects may be required.
Training is one part of competence. It can build and evidence relevant knowledge, but it does not by itself establish practical capability for every related task, suitability for every type of premises or authority to make technical decisions.
Where Does Competence Go Further?
Competent performance includes recognising where personal capability ends. Home Office guidance for England identifies recognition of personal limitations and willingness to obtain external advice as an indicator of competence (Home Office, 2023a).
The organisation should define what the person may decide and when they must refer a matter to a specialist. Independent certification or ongoing professional learning, commonly called continuing professional development (CPD), may be relevant to some specialist functions, depending on the role, applicable scheme and commissioned scope.
How Do Fire Safety Competence Requirements Change by Function?
Fire-safety competence requirements change when a function moves from following or reporting to interpreting, approving or specifying.
Where one person carries several functions, each still requires its own competence decision because a job title alone does not establish capability for every task.
| Function | Required Activity | Evidence That May Be Proportionate | Limit or Escalation Point |
|---|---|---|---|
| Employee response and local awareness | Recognise the alarm, follow local procedures and report concerns | Site-specific information, suitable training and confirmation of understanding | Within this employee-response function, no authority to inspect systems, redesign procedures or assess the building unless separately authorised and competent |
| Emergency implementation | Carry out an assigned action such as communication, assistance, a sweep or initial firefighting where the plan requires it | Role instruction, local familiarisation, rehearsal and adequate cover | Implement the agreed plan and refer questions about its adequacy |
| Routine observation or defined check | Confirm an observable condition against a clear check, then record and report | Task instruction, demonstration, a defined checklist and a clear defect route | Stop at recognition unless separately authorised and competent to diagnose or approve |
| Technical inspection, servicing or maintenance | Interpret condition or test results, diagnose defects and carry out or specify work | Relevant technical learning, practical assessment, experience and system knowledge | Work only within the system, premises and authorisation covered by that evidence |
| Management, review and assurance | Coordinate arrangements, commission work, track actions and decide when specialist input is needed | Legal and operational understanding, defined authority, reliable information and access to specialists | Management responsibility does not itself confer technical competence to inspect, design or repair |
| Fire risk assessment or fire engineering | Assess overall fire risk or provide specialist engineering analysis and strategy | Specialist capability matched to the building, task and complexity, supported by relevant experience and, where applicable, third-party certification or professional registration relevant to the commissioned scope | Keep the scope explicit and refer work outside the person's demonstrated field |
Where Do Routine Checks Become Technical Work?
An extinguisher presence check can confirm that equipment is present and report visible damage; servicing or interpreting test results is a separate technical function. Our fire extinguisher inspection checklist explains the task detail.
A routine visual fire-door check can record visible damage and use a clear reporting route; detailed inspection, diagnosis and repair require different capability. The practical requirements are covered in our guide to fire-door safety after installation.
How Should Emergency and Specialist Functions Be Treated?
Emergency roles should also be described by function. The label fire warden does not determine the legal category or capability required. The organisation’s procedures should establish what the person is expected to do and the conditions in which the function is performed. Home Office guidance for England states that procedures vary with the premises and that a sufficient number of competent people must be available to implement them where required (Home Office, 2023a).
Specialist fire risk assessment and fire engineering may be commissioned externally. Record the commissioned scope and the basis for selecting the specialist instead of treating this work as another entry in the employee course matrix. Our detailed guide to who can carry out a fire risk assessment in England and Wales covers qualifications, registers, certification and assessor selection.
What Evidence Can Demonstrate Fire Safety Competence?
Evidence of fire-safety competence should be proportionate to the function, setting, risk and authority and may combine training with practical demonstration, experience, supervised or observed performance and relevant certification or professional registration.
Five factors shape the evidence required.
- Consider the complexity of the premises, occupants, system and task. Capability established in one setting may not transfer to a materially different one.
- Examine what could follow if the person misses a condition, misunderstands it or accepts it when further action is needed.
- Identify whether the task follows a procedure or requires interpretation of standards, incomplete information or interacting risks.
- Account for changes across buildings, systems and operating conditions.
- Establish whether the person can only report or can also approve work, alter arrangements or accept a condition on behalf of the organisation.
Relevant certification or registration can provide third-party assurance for specialist services, but it must match the building, task and commissioned scope. Credentials do not replace evidence of the person’s actual function and authorised decisions.
Human Focus has set out an Awareness, Intermediate and Advanced framework for planning training. That framework can inform the depth of learning. The organisation must also consider how the person applies the learning, their experience, supervision and authority.
For built-environment work in England, the Industry Competence Committee defines competence by reference to both individual capability and the organisational systems that support it (Industry Competence Committee, 2026). It describes competence as the consistent delivery of safe and compliant outcomes through skills, knowledge, experience and behaviours, supported by organisational systems for decisions and oversight. This matters because organisational information, decision-making and oversight can affect how reliably individuals perform.
Improving assurance may require a narrower authorised task, supervised practice, better access to building information or a clearer point for specialist referral. Additional training is appropriate where it addresses the identified capability need.
When Should Fire Safety Competence Be Reviewed?
Fire-safety competence should be reviewed when assigned activities, decision-making authority, premises, systems or risks change.
When the Function Outgrows the Training Record
A training matrix that lists only a job title, course and renewal date may not reveal that change.
Consider a facilities coordinator who was originally asked to record visible fire-door damage and send it to a specialist. Over time, the role starts deciding whether defects are acceptable and signing off repairs. The work now involves technical judgement and approval rather than observation and reporting, even though the training entry remains unchanged.
What Else Should Trigger a Competence Review?
Vacancies, contractor availability, new systems or local workarounds can change a function gradually. Review the revised function before assuming that the existing course record still supports it.
A useful review asks:
- Does the matrix identify the function or only a title and course?
- What is the person expected to recognise, carry out, interpret, approve and escalate?
- Has responsibility expanded since training was first assigned?
- Have the premises, occupants, documented fire-safety strategy, systems or risks changed?
- What experience, supervision or observed application supports the record?
- Are the limits of authority and the route to specialist advice understood?
Article 21 separately links employee training to new or increased risks arising from changed responsibilities, new equipment or technology and new systems of work. It also requires periodic repetition where appropriate and adaptation to new or changed risks (Great Britain, 2005).
How Can Organisations Review Fire Safety Competence?
Organisations can review fire-safety competence in six steps by defining functions, clarifying decisions, separating requirements, matching evidence, setting boundaries and specifying review triggers.
- List the fire-safety activities assigned to employees and contractors at each site, including emergency actions, routine checks, maintenance, management, fire risk assessment and specialist work.
- Replace role-title shorthand with clear verbs that state what the person is expected to recognise, do, record, interpret, approve and escalate.
- Identify which requirements apply and separate current law from government guidance, technical standards, contractual requirements, professional schemes and future proposals. Do not manage an item in a consultation as a current statutory duty.
- Match the evidence identified in the previous section to each function and add any role-specific certification, registration or CPD requirement.
- Record the premises, systems and decisions within the person’s remit. Make the limit of authority and the trigger for referral clear to the person, their manager and anyone who depends on their work.
- Revisit the decision when responsibility, risk, premises, systems, technology, guidance or professional expectations change. Where no law or scheme sets an interval, choose one that reflects the function and its consequences.
The record may be concise where that is proportionate, but it should be detailed enough to show the basis for the competence decision and the limits of authority. Keep the underlying evidence available and follow any role-specific legal, contractual, scheme or professional requirements.
- Record the function owner, premises or system covered and permitted decisions.
- Record the competence evidence, supervision or verification, escalation route and review trigger.
No single statutory review interval applies to every function. Follow any role-specific legal, scheme or CPD requirements. Article 21 separately requires employee training to be repeated periodically where appropriate and adapted to new or changed risks (Great Britain, 2005).
How Can Organisations Keep Fire Safety Competence Aligned With Work?
A useful first step is to confirm and document who performs each fire-safety function, what the work demands, what evidence supports the appointment and where the person’s authority ends.
The training matrix should then be tested against the work people actually perform, because a change in judgement, authority or setting can require a new competence decision even when the course record remains current.
The important question is whether the evidence of each person’s capability and authority still matches the fire-safety function the organisation relies on them to perform.
If your organisation needs fire-safety learning matched to the competence gaps identified in this article, Human Focus fire safety courses provide general awareness and role-specific learning that can form part of a wider competence assessment.
