Yes. Every care home in England and Wales is legally required to have a fire risk assessment, and to keep it under regular review. This isn't a recommendation or good practice — it's a statutory duty under the Regulatory Reform (Fire Safety) Order 2005 (the FSO), and it sits alongside the fire safety expectations the Care Quality Commission checks for separately.
The legal basis
Article 9 of the FSO requires the "Responsible Person" for any non-domestic premises to make a suitable and sufficient assessment of the fire risks to which anyone on the premises is exposed. In a care home, that's usually the registered provider or registered manager — Article 3 of the Order defines the Responsible Person as whoever has control of the premises, or the employer where the premises is a workplace.
"Suitable and sufficient" is a legal standard, not a form-filling exercise. It has to reflect the premises in front of the assessor: this building, this occupancy, these residents — not a generic template applied to every care home on the round.
Where CQC fits in
The FSO and CQC regulation are two separate systems that both land on the same document. CQC doesn't carry out fire risk assessments itself, but fire safety sits under Regulation 12 (Safe care and treatment) of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 — assessed under the "Safe" key question in CQC's inspection framework. In practice, an inspector will ask whether a fire risk assessment exists, whether it's current, and whether its findings have actually been acted on.
That means a care home's FRA gets read by two different audiences for two different reasons: a fire and rescue authority officer checking FSO compliance, and a CQC inspector checking evidence of safe care. An assessment that satisfies one but not the other hasn't done its job.
Why care homes are a distinct case
Care homes carry risks that a standard office or retail FRA framework doesn't fully account for: round-the-clock occupancy, residents with mobility or cognitive impairments, and the reality that a full evacuation of a care home isn't always the safest option in a fire. Most care homes rely on progressive horizontal evacuation — moving people to safety within the building, compartment by compartment, rather than out of it — which we cover in detail in a separate guide. Personal Emergency Evacuation Plans (PEEPs) for individual residents are part of the same picture.
A fire risk assessor who hasn't worked with this occupancy type before can miss what actually matters here. Sleeping risk, staffing ratios overnight, and compartmentation between resident rooms all need to be assessed with the specific building and its residents in mind — not lifted from a checklist written for a different sector.
What happens if the assessment is inadequate
Fire and rescue services audit care homes at a higher rate than most other premises types — in the year to March 2025, care homes were the second most-audited category nationally, behind only shops. An inadequate or out-of-date FRA is one of the most common findings when that audit happens, and the consequences sit with the Responsible Person, not with whoever was hired to write the report. Enforcement action under the FSO can include an Enforcement Notice requiring specific remedial steps, or — where the risk is judged serious enough — a Prohibition Notice restricting use of the premises with immediate effect.
Commissioning the assessment doesn't transfer that liability. It only helps if the person doing the work has the sector knowledge and the credibility to produce something that holds up if it's ever examined closely.
Getting it right the first time
A fire risk assessment for a care home should be proportionate to the actual risk in front of the assessor — not overstated to cover the assessor's own liability, and not softened to keep the client happy. It should name what was found, explain why it matters for this building and these residents, and set out what to do about it.
SimplyNeat Fire Solutions carries out every care home assessment personally — no sub-contracted assessors, no junior staff — with a fixed fee agreed in writing before any work is instructed.