4-5 minute read.
In supported housing, having a fire risk assessment doesn’t automatically mean you’re fully covered. It’s not a tickbox exercise to say “I have now done my FRA, I’ll review in 12 months”. A fire risk assessment is not a pass or fail, and you don’t receive a certificate. It’s a snapshot, at a particular moment in time, which should then be monitored in a live environment against any new or changing hazards.
Another common misconception is around the different types of assessment. It depends entirely on which type you have and which spaces it actually covers. Under BS 9792:2025, the current British Standard code of practice for fire risk assessments in housing, there are four defined types of assessment. For supported housing providers, two are most relevant, and understanding the difference between them could determine whether your residents are genuinely protected.
First, a word on what “supported housing” actually means
There is often significant confusion about what supported housing actually means in the context of fire safety, and that confusion has real consequences. The sector is far broader than most people assume, and applying the wrong standard to the wrong building type is a risk in itself. This is precisely why you need a specialist who understands both the sector and the relevant regulations and standards, not a generalist assessor applying a one-size-fits-all approach.
Supported housing is not a single building type or a single resident profile. It covers a single person in a one-bed flat receiving floating support, a small four to six bed HMO for adults recovering from addiction or mental ill health, a larger 20-bed scheme for people with learning disabilities, and everything in between. At the higher end of the spectrum, where residents require round-the-clock care at ratios such as four to one, the building may be a registered care home rather than a housing scheme.
That distinction matters. BS 9792:2025 explicitly excludes residential care homes from its scope. For registered care homes, fire safety obligations sit directly under the Regulatory Reform (Fire Safety) Order 2005 alongside care-specific regulation, and specialist guidance applies. If you are unsure whether your property is a supported housing scheme or a registered care home for the purposes of fire safety regulation, that question is worth resolving before you commission an assessment.
For the majority of supported housing providers operating HMOs, cluster flats, shared houses, and specialist tenancy schemes, BS 9792:2025 is the applicable standard, and that is what the rest of this article addresses.
Not all fire risk assessments are equal
The newly introduced BS 9792:2025 code of practice on the BSI Knowledge Shop applies specifically across diverse residential settings, including blocks of flats, HMOs, sheltered, extra-care schemes, and supported housing. Within that framework, assessments are categorised by scope. The two types most relevant to supported housing are Type 1 and Type 3. For landlords and supported housing providers, understanding the distinction between a Type 1 and a Type 3 assessment is critical to ensuring both legal compliance and resident safety
Type 1 Fire Risk Assessment: communal areas only (non-intrusive)
A Type 1 assessment covers shared spaces such as hallways, stairwells, communal lounges, kitchens, and escape routes. It assesses whether those areas meet fire safety requirements without opening up any part of the building fabric.
It is appropriate for:
- buildings where all usable space is fully communal and no residents occupy private rooms or self-contained flats
- vacant properties awaiting occupation, and
- lower-complexity structures where there is good documented evidence of building integrity.
For a supported housing scheme where residents have their own rooms or flats, a Type 1 assessment covers only the areas they pass through, not the areas where they actually live.
Type 3 Fire Risk Assessment: communal areas plus private dwellings (non-intrusive)
A Type 3 assessment covers everything in a Type 1 but extends to include inspections inside a sample of individual flats and rooms, assessing internal alarms, escape routes, and fire stopping within private living spaces.
In supported housing, private rooms and self-contained flats are where residents spend most of their time, where they sleep, and where a fire is statistically most likely to start or go undetected. A Type 1 assessment that stops at the communal hallway has missed the most significant part of the risk picture.
This is especially important given the nature of the people your service supports. Residents may have mobility difficulties, cognitive impairments, sensory loss, or conditions affecting their response to a fire alarm. BS 9792:2025 introduces a specific focus on person-centred fire risk assessments, recognising that certain residents have characteristics or vulnerabilities that affect their ability to respond to a fire, respond to an alarm, or evacuate without assistance. For supported housing schemes, particularly those serving residents with higher support needs, a person-centred element to the assessment is not optional. It is the point.
Which type does your property need?
The right answer depends on your building and your residents, not a blanket rule. As a starting point, ask yourself three questions.
- Do residents sleep or live in private rooms or self-contained flats?
- Are those residents living with care or support needs that affect their ability to self-evacuate?
- Does your building contain a mix of communal and private areas?
If the answer to any of these is yes, a Type 3 assessment is almost certainly what is required. The smaller the scheme and the more independent your residents, the closer you may sit to a Type 1 being defensible, but that assessment still needs to be made against the actual building and the actual people in it, not assumed.
The legal position
The Regulatory Reform (Fire Safety) Order 2005 requires the responsible person to make a suitable and sufficient assessment of the risks to which relevant persons are exposed, for the purpose of identifying the general fire precautions needed. The word “suitable” is doing important work there. It is proportionate to the building and the people in it. For a supported housing scheme with vulnerable residents in private spaces, a Type 1 assessment is unlikely to satisfy that standard, and the Fire and Rescue Authority has enforcement powers where it does not.
The consequences of getting this wrong are not hypothetical. They include:
- enforcement action from the Fire and Rescue Authority
- disputed insurance claims following an incident in an area the assessment did not cover
- fire safety findings in a CQC inspection affecting your Safe domain rating, and
- personal liability for the responsible person or nominated individual.
Since October 2023, amendments enforced under Section 156 of the Building Safety Act 2022 on GOV.UK also make it a strict legal requirement for the responsible person to document their fire risk assessment, fire safety action plan, and all relevant fire safety information regardless of the size of the organisation. If your documentation is not in order, that is now a legal exposure in its own right.
What a Type 3 assessment looks like with The Supported Housing Compliance Company
A Type 3 assessment from The Supported Housing Compliance Company covers your full building, communal areas and private spaces, carried out by a qualified assessor who understands the specific context of supported housing. That means understanding resident vulnerability, your obligations as a provider, and the overlap between fire safety legislation and regulatory expectations from bodies including the CQC and the Regulator of Social Housing.
You receive a clear, actionable report setting out exactly where you stand and what needs to change. Not a generic document that ticks a box and sits in a drawer.
The bottom line
A fire risk assessment is only as valuable as its scope. In supported housing, that scope must reflect the building you actually have, the residents who actually live there, and the support needs they actually carry. If you are unsure whether your current assessment covers what it should, we can help you find out.
Frequently Asked Questions
Do I legally need a Type 3 fire risk assessment for supported housing?
There is no legislation that mandates a specific assessment type by number. However, the Regulatory Reform (Fire Safety) Order 2005 requires the responsible person to ensure a suitable and sufficient assessment. For supported housing with residents in private rooms or self-contained flats, a Type 1 covering only communal areas is unlikely to satisfy that standard. A Type 3 is the appropriate choice for most supported housing properties.
Does BS 9792:2025 apply to my care home?
No. BS 9792:2025 explicitly excludes residential care homes from its scope. If your property is a registered care home, your fire risk assessment obligations sit directly under the Regulatory Reform (Fire Safety) Order 2005 alongside care-specific regulation. You need an assessor with specific experience in care settings.
How often should a fire risk assessment be reviewed in supported housing?
There is no fixed legal interval, but the assessment must be reviewed whenever there is reason to suspect it is no longer valid, such as following significant changes to the building, occupancy, or use of the premises. For supported housing, given the vulnerability of residents and the dynamic nature of care environments, annual reviews are best practice.