Recommendation P2-10: Require fire safety strategy from registered fire engineer at Gateway 2
From Grenfell Tower Inquiry: Phase 2 Report, published 4 September 2024.
Recommendation
We therefore recommend that it be made a statutory requirement that a fire safety strategy produced by a registered fire engineer (see below) to be submitted with building control applications (at Gateway 2) for the construction or refurbishment of any higher-risk building and for it to be reviewed and re-submitted at the stage of completion (Gateway 3). Such a strategy must take into account the needs of vulnerable people, including the additional time they may require to leave the building or reach a place of safety within it and any additional facilities necessary to ensure their safety. (113.15)
In brief (written by this site)
In September 2026, the Ministry of Housing, Communities and Local Government reported that it was reviewing whether the existing building safety regime addresses all aspects of the recommendation and working with industry partners to clarify what a fire safety strategy should include (Ministry of Housing, Communities and Local Government, Sep 2026). In the same September 2026 update, the department outlined a timeline targeting a potential consultation in early 2027 and regulations setting out the requirement in 2029, both dependent on discussions with stakeholders (Ministry of Housing, Communities and Local Government, Sep 2026). It also stated in September 2026 that requiring strategies to be produced by fire engineers remains dependent on increasing professional capacity under recommendations 15, 16, and 18 (Ministry of Housing, Communities and Local Government, Sep 2026; Ministry of Housing, Communities and Local Government, Sep 2026).
Sources
AI-generated summary of the record on this page, checked by a second model and automatic checks, 26 Sep 2026. The record below is the sources' own words.
Government response
The government accepts this recommendation. A fire safety strategy is already required with building control applications for the construction of and significant work to higher-risk buildings. The Building Safety Regulator will consider how to make the current guidance about what is required clearer to applicants. The registration of the fire engineering profession is addressed in the response to recommendation 15.
How this response relates to the recommendation
Site note: This is the government's response to the Phase 2 report (CP 1248, published 26 February 2025). It prints each recommendation and then the response to it. Where the recommendation is addressed to a body outside government, the response prints that body's own acceptance (the Architects Registration Board and RIBA, HMICFRS, London Fire Brigade, the National Fire Chiefs Council, the British Standards Institution, the National Police Chiefs' Council), and the row is filed under that body.
Delivery
Ministry of Housing, Communities and Local Government says in progress (10 September 2026)
We are working with industry and regulatory partners to understand what should be included in a fire safety strategy and how this aligns with the current fire safety requirements for higher-risk buildings and the requirements of the Fire Safety Order 2005.
The government is reviewing current requirements and considering whether the current regime addresses all aspects of the recommendation. The government will set up a working group with industry partners to take parts of this work forward.
The government has also committed to reviewing whether other buildings or critical infrastructure require a fire safety strategy. The government will be working with the transitional board on taking this work forward.
Requiring the fire safety strategy to be produced by a fire engineer is dependent on progress on recommendations 15, 16 and 18, which aim to increase fire engineering capacity.
Site note: This is the Ministry of Housing, Communities and Local Government's progress report of September 2026 on the Grenfell Tower Inquiry recommendations. Where the passage describes work by another body, such as the National Fire Chiefs Council, London Fire Brigade, fire and rescue services, the British Standards Institution or the Cabinet Office, it is the Ministry's account of that body's progress, and the row is filed under the Ministry.
Earlier statements on delivery (2)
Ministry of Housing, Communities and Local Government (10 September 2026)
Timeline for delivery
2025
- Activities to ensure the higher risk regime and current fire safety requirements are operating effectively. – Complete
- Initial engagement with stakeholders and the Fire Engineers Advisory Panel to understand scope to build on current fire safety requirements, taking into account system risks and capacity. – Complete
2026
- Activities with regulatory partners and others to clarify the current fire safety requirements and how they support the safe occupation of higher-risk buildings and how they relate to vulnerable people. – (Q4, Oct to Dec)
- Continued engagement with stakeholders to understand scope to build on current fire safety requirements, taking into account system risks and capacity. – (Q4, Oct to Dec)
2027
- Dependent on outcomes of work with stakeholders, potential consultation on revising requirements. – (Q1, Jan to Mar)
2029
- Dependent on the outcomes of work with stakeholders and the consultation - set out the requirement for a fire safety strategy in regulations.
- Further work on requiring fire engineers to produce the fire safety strategy will be dependent on fire engineer capacity and competence, which is dependent on recommendations 15 to 18.
Site note: This is the Ministry of Housing, Communities and Local Government's progress report of September 2026 on the Grenfell Tower Inquiry recommendations. Where the passage describes work by another body, such as the National Fire Chiefs Council, London Fire Brigade, fire and rescue services, the British Standards Institution or the Cabinet Office, it is the Ministry's account of that body's progress, and the row is filed under the Ministry.
Ministry of Housing, Communities and Local Government (25 February 2026)
We have continued with engaging with industry and regulatory partners, to understand how any change would work in practice and building an evidence base to support any potential changes. However, throughout this engagement we have identified different perspectives on how to achieve strengthened fire safety requirements without mandating a fire safety strategy to be submitted to the Building Safety Regulator. We are working on reviewing different options.
Any changes will require consultation and will need to balance safety, proportionality and delivery considerations. There are already extensive requirements on dutyholders for higher-risk buildings in relation to fire safety. Dutyholders must already have a fire and emergency file and a building regulations compliance statement for every higher-risk building. These documents are submitted to the Building Safety Regulator and must be kept updated and reflect any changes made during construction of the higher-risk building. There are also specific requirements regarding the handover of information to the person responsible for a higher-risk building in occupation.
As set out in September, we noted any changes to building control application process for higher-risk buildings, will need to align with progress on recommendations 15 to 18, which aim to increase fire engineering capacity.
Site note: This is the annex of the government's Phase 2 annual report (CP 1512, published 25 February 2026) as GOV.UK publishes it, one page per theme: the Ministry of Housing, Communities and Local Government's account. Where the passage describes work by another body, such as the National Fire Chiefs Council, London Fire Brigade, the British Standards Institution, the Health and Safety Executive or the Cabinet Office, it is the report's account of that body's progress, and the row is filed under the Ministry. The status is what the passage says: completed only where it says the recommendation is complete or closed.
Responsible bodies
Themes and tags
Who has spoken
- UK Government
Response - Ministry of Housing, Communities and Local Government
Delivery statement