Do Churches Legally Need a Fire Risk Assessment?

Yes. Every church and place of worship in England and Wales must have a suitable and sufficient Fire Risk Assessment. This is not optional, and it applies regardless of whether you have paid employees, how old the building is, or how infrequently it is used.

What the Law Says

The Regulatory Reform (Fire Safety) Order 2005 — usually called "the Fire Safety Order" or "the RRO" — is the primary fire safety legislation for non-domestic premises in England and Wales. It replaced over 70 pieces of previous fire safety legislation and came into force in October 2006.

Under Article 9 of the Order, the responsible person for any non-domestic premises must carry out — or arrange for a competent person to carry out — a suitable and sufficient assessment of the fire risks to people on or near the premises. Churches and places of worship are explicitly non-domestic premises, and there are no exemptions based on size, frequency of use, or charitable status.

Three Common Misconceptions

1. "We don't employ anyone, so the law doesn't apply to us"

This is probably the most widespread misunderstanding. The Fire Safety Order applies to the premises, not to whether you are an employer. If members of the public — including your congregation — use the building, you have legal duties. The presence or absence of paid employees is irrelevant to your fire safety obligations.

2. "We've never had a problem, so we must be fine"

A Fire Risk Assessment is a proactive requirement, not a reactive one. You cannot wait until a fire occurs to discover whether your arrangements are adequate. The law requires you to identify and manage risks in advance. A building that has "never had a problem" may simply have been lucky — and luck is not a defence in an enforcement notice or prosecution.

3. "Our old certificate still covers us"

Before the 2006 changeover, many churches held a Fire Certificate issued under the old Fire Precautions Act. These certificates no longer have any legal effect. They were abolished when the RRO came into force. If your church is relying on a document that pre-dates October 2006, you do not have a current Fire Risk Assessment.

Why Churches Carry Particular Risk

Churches are not straightforward buildings to assess. They carry specific fire safety challenges that a generic or tick-box assessment will miss:

• Historic fabric — older buildings often have structural timber, open roof voids, and materials that burn rapidly and are difficult to replace
• Congregation age and mobility — many congregations include elderly members, people with disabilities, or those who may be unfamiliar with the building's layout
• Multiple concurrent uses — a typical church week might involve a Sunday service, a toddler group, a choir rehearsal, an evening event, and a hall hired to an outside group; each needs to be considered separately
• Candles and open flames — an ignition source found in few other non-domestic premises
• Volunteers rather than trained staff — evacuation depends on volunteers who may not have received fire safety training
• Personal Emergency Evacuation Plans (PEEPs) — many churches have regular attenders with mobility impairments who need an individual evacuation plan

What Enforcement Looks Like

Fire safety in places of worship is enforced by your local Fire and Rescue Service. Inspectors have the right to enter your premises at any reasonable time without notice. Where they find inadequate arrangements, they can issue:

• An Alterations Notice — requiring you to notify the fire authority before making changes
• an Enforcement Notice — requiring specific improvements within a set timescale
• A Prohibition Notice — preventing use of part or all of the building until fire safety is addressed

In serious cases, the responsible person can face prosecution and an unlimited fine. It is also worth noting that many church insurers now require an up-to-date Fire Risk Assessment as a condition of cover — failure to have one could invalidate your policy.

How Often Does It Need Reviewing?

A Fire Risk Assessment is not a one-off exercise. The law requires it to be reviewed whenever there is reason to believe it is no longer valid — for example, after a change to the building, a change in use, a change in the people who use it, or simply the passage of time. As a practical guide, most assessors recommend a full review every one to three years for a typical church, with an annual check of the key findings.

What a Good Church Fire Risk Assessment Covers

A competent Fire Risk Assessment for a church will go well beyond a checklist. It will examine the specific activities that take place in the building, the characteristics of the people who use it, the condition of the fabric, and the arrangements in place for detecting, warning and evacuating. It will produce a written report with clearly prioritised actions — and it should be understandable by a non-specialist.

Common questions

Does fire safety law actually apply to a church?

Yes. The Regulatory Reform (Fire Safety) Order 2005 applies to virtually all non-domestic premises in England and Wales, and places of worship are not exempt. The responsible person, usually the incumbent, the churchwardens or the PCC, must make sure a suitable and sufficient fire risk assessment is carried out and kept up to date.

We have no employees, only volunteers. Do we still need one?

Yes. The Order applies wherever people other than the responsible person may be present, so volunteers, the congregation and visitors all count. Since the amendments made by the Building Safety Act 2022 took effect in October 2023, the assessment must also be recorded in full, whatever the number of employees.

We still hold an old fire certificate. Is that enough?

No. Fire certificates were abolished when the Fire Precautions Act 1971 was repealed by the 2005 Order, so any certificate you still hold has no legal standing. A current fire risk assessment is what is required in its place.

How often should the assessment be reviewed?

The Order requires the assessment to be kept up to date rather than setting a fixed interval. In practice, review it at least annually, and redo it whenever something changes: building or reordering work, a new heating system, a change of use, larger congregations, or after a fire or near miss.

Who enforces this, and what happens if we have not done one?

Your local fire and rescue authority. Inspectors can give informal advice, serve an enforcement notice, or serve a prohibition notice closing all or part of the building. Serious breaches can carry unlimited fines and, in the worst cases, imprisonment.