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Field guide 07By Avoice7 min read

Fire strategy reports explained

What a fire strategy report is, who writes it, when it is needed from the planning Fire Statement through Gateway 2 to regulation 38, and how architects keep drawings and specifications aligned with it.

01

What is a fire strategy report?

A fire strategy report explains how a building will meet the fire safety requirements of the Building Regulations, covering means of escape, fire spread, structural fire resistance, detection and alarm, and fire service access. It is usually written by a fire engineer, and the architect is responsible for making sure the drawings and specification deliver what it says.

The phrase "fire strategy report" does not appear in legislation, but the information it contains is required at several statutory points: the planning Fire Statement for tall residential buildings, the building control or Gateway 2 application, and the fire safety information handed over under regulation 38.

The fire engineer writes the strategy. The drawings and specification are where it either happens or does not.

02

Who writes a fire strategy report?

On most projects beyond simple dwellings, a fire engineer prepares it. Smaller schemes that follow Approved Document B closely may have a strategy prepared by the architect or a fire consultant as a compliance statement against the guidance.

Where a scheme departs from Approved Document B, uses a performance-based approach or follows a fire engineering standard such as BS 7974, it needs a qualified fire engineer. A house extension usually does not need a separate report: building control checks Part B from the drawings and specification. Larger or more complex projects, buildings with multiple occupancies and anything departing from Approved Document B normally do.

The fire engineer sets out the strategy. The architect, structural engineer and building services engineers each design elements that deliver it. That split is where most of the problems happen.

03

When is a fire strategy needed?

Fire strategy information is needed at four points: planning, building control or Gateway 2, any design change that affects fire safety, and completion. The strategy should be updated at each major design stage, before the building control or Gateway 2 application, and at completion.

FIRE STRATEGY · STATUTORY TOUCHPOINTSOne strategy, four places it has to hold up
  1. PLANNING

    Fire Statement

    Relevant buildings of 18m or 7 storeys; all major schemes in London (Policy D12).

  2. BEFORE WORK

    Building control or Gateway 2

    Supports Part B compliance; the backbone of the HRB fire and emergency file.

  3. ONGOING

    Revisions

    Updated when design changes affect fire safety; controlled changes on HRBs.

  4. COMPLETION

    Regulation 38

    As-built strategy handed to the responsible person.

FIG. 02
The planning statement and the later strategy must agree

The Fire Statement is a planning document. The fire strategy is the more detailed technical document behind Building Regulations compliance, and the two should be consistent.

At planning: Fire Statements and Planning Gateway One

Since 1 August 2021, full planning applications in England involving a "relevant building" must include a Fire Statement on the prescribed form. A relevant building contains two or more dwellings or educational accommodation and is 18 metres or more in height or has 7 or more storeys. The Fire Statement covers fire safety principles, site layout, emergency vehicle access and water supplies for firefighting. Outline applications, some changes of use and section 73 applications are among the exemptions.

The statutory consultee used to be the Health and Safety Executive. Since the Building Safety Regulator became a standalone body on 27 January 2026, sponsored by the Ministry of Housing, Communities and Local Government, the Planning Portal names the BSR as the Planning Gateway One consultee.

In London: Policy D12

Policy D12(B) of the London Plan 2021 says all major development proposals should be submitted with a Fire Statement, described as an independent fire strategy produced by a third party, suitably qualified assessor. It should cover construction methods and materials, means of escape for all occupants including step-free evacuation, active and passive fire safety measures, firefighting access and equipment, fire appliance access within the site, and how future alterations will not compromise fire safety. The London Plan 2021 remains the adopted plan; a draft replacement was out for consultation from 16 July to 15 October 2026, so check the current position on live schemes.

At building control and Gateway 2

For ordinary projects, the fire strategy supports the full plans application or the registered building control approver's assessment of Part B compliance.

For higher-risk buildings (at least 18 metres or 7 storeys with at least two residential units, or a hospital or care home meeting the height test), the Building (Higher-Risk Buildings Procedures) (England) Regulations 2023 require a building control approval application to the BSR before work starts. Under regulation 4 and Schedule 1, it must include a fire and emergency file, alongside a compliance statement, construction control plan, change control plan and other documents. The file sets out the fire risk assessment, the design measures relied on for compliance, management measures for evacuation, fire and rescue service access and water supply. The BSR must decide a valid application within 12 weeks unless a longer period is agreed.

In practice the fire strategy is the backbone of the fire and emergency file. If the strategy is vague or out of date, the Gateway 2 application will struggle.

At completion: regulation 38

Regulation 38 of the Building Regulations 2010 requires the person carrying out the work to give fire safety information to the responsible person under the Regulatory Reform (Fire Safety) Order 2005, no later than completion or occupation if earlier. In England, since 1 October 2023, the responsible person must acknowledge receipt in writing, and the person carrying out the work must notify building control that the information has been given. The final fire strategy, updated to reflect what was built, is the core of that package. For higher-risk buildings, the equivalent handover duties sit in regulation 38 of the 2023 HRB procedures regulations.

04

What should a fire strategy report contain?

Content follows the structure of Part B, adjusted for building type and design approach. It starts with the building and the design basis, works through B1 to B5, then covers active systems and management assumptions.

TYPICAL REPORT STRUCTURE Building description Use, height, storeys, occupancy, purpose group, risk Design basis ADB, BS 9991, BS 9999 or fire engineered; departures listed B1 Means of escape Evacuation strategy, travel distances, stairs, lifts, refuges B2 Internal linings Classification of wall and ceiling linings B3 Internal structure Fire resistance, compartments, cavity barriers, stopping, sprinklers B4 External spread External wall construction and materials, boundaries, unprotected areas B5 Fire service Vehicle access, firefighting shafts, dry or wet risers, hydrants Active systems Detection, smoke control, suppression Management Maintenance, the responsible person
FIG. 03
The report mirrors Part B

The design basis matters most: any departure from Approved Document B should be listed there, because it changes what the drawings and specification have to prove.

The amended Approved Document B published in March 2024 introduced a second staircase for new blocks of flats with a storey at 18 metres or more, with a transition period that ended on 30 September 2026. Projects that had not started and sufficiently progressed under the earlier guidance need a strategy that reflects the new provisions, so confirm which edition a scheme is being assessed against.

05

What is the architect responsible for?

The fire engineer writes the strategy, but the architect usually leads the information that delivers it. Under regulation 11J of the Building Regulations 2010, in force in England since 1 October 2023, anyone carrying out design work must take all reasonable steps to ensure a building built to that design would comply with all relevant requirements.

Fire strategy REVISION C Drawings Compartment lines · fire door ratings Protected routes · travel distances Cavity barrier locations COORDINATED TO REV C ✓ Specification Fire door sets · lining classes External wall materials · fire stopping "Or equivalent" needs a performance standard COORDINATED TO REV B ✕
FIG. 04
Record which revision each issue was coordinated against

An illustrative example: the drawings follow the current strategy revision but the specification was coordinated to the previous one. Recording the revision on each issue makes this kind of gap visible before it reaches site.

Coordinate drawings
Compartment lines, fire door ratings, protected routes, travel distances and cavity barrier locations should match the strategy exactly. Mark up fire plans from the strategy, not the other way round.
Coordinate the specification
Fire door sets, lining classifications, external wall materials, fire stopping products and cavity barriers must meet the performance the strategy requires. "Or equivalent" clauses need a clear performance standard behind them.
Manage revisions
When the strategy changes, the drawings and specification follow, and vice versa. Record which strategy revision each drawing and specification issue was coordinated against.
Flag conflicts early
A strategy that relies on sprinklers while the services design omits them, or an external wall specification that conflicts with the boundary condition, should be raised immediately.
Feed the record
For higher-risk buildings, design changes may be controlled changes that need recording or approval under the change control regime.
06

Where Avoice fits

Most fire strategy problems are coordination problems: a rating, material or route that says one thing in the strategy and another in the drawings or specification.

Avoice's QA/QC review checks drawings and specifications against each other and against the regulations, flagging conflicts such as fire ratings or external wall materials that do not match across documents. The Building Regs Tracker in the Compliance module records Part B items and their evidence, and the Avoice Regulations library lets the team check the current Approved Document B text with cited answers.

Software can retrieve, compare and flag. The fire engineer, the architect and building control still decide what the strategy requires and whether the design delivers it.

AVOICE QA/QC

Check drawings and specs against the fire strategy

Flag fire ratings, external wall materials and other Part B items that do not match across documents, before they reach building control or the BSR.

This guide is for general education and is not professional advice. Check the current Approved Document B, the planning requirements and the regulations that apply to your project before relying on any provision.