Approved Document B has changed, with further amendments scheduled for 2029. But does that mean existing buildings need expensive fire safety upgrades? Before committing to new fire doors, additional staircases or major alterations, here’s what landlords, developers and building owners need to understand.
Imagine you’re responsible for a residential block, office building or commercial development that’s been occupied for twenty years.
The building has a fire risk assessment, its fire protection systems are maintained and, as far as you’re aware, everything is being managed appropriately.
Then somebody tells you that Approved Document B has changed.
Perhaps you’ve heard that residential buildings now need two staircases, that older fire doors won’t meet the new standards or that additional sprinkler systems are becoming compulsory.
Naturally, you’re wondering what this means for your property.
Does the change mean you have to upgrade the building immediately?
Could you be facing thousands of pounds in additional work, or do the new requirements only apply when you undertake alterations?
These are important questions, particularly for freeholders, managing agents, RTM companies and commercial property owners responsible for existing buildings.
The answer is that changes to Approved Document B don’t automatically require every existing building to be upgraded.
However, they can become very relevant when you extend a building, undertake refurbishment work or change how the premises are used.
And with further amendments already scheduled for September 2029, it’s worth understanding the distinction between what’s currently in force and what the Government is still proposing.
What Is Approved Document B, and Is It Law?
Approved Document B is the Government’s statutory guidance on meeting the fire safety requirements of the Building Regulations in England.
It provides practical guidance on matters such as means of escape, fire detection and warning, compartmentation, structural fire protection, external fire spread and access for firefighters.
There are two volumes: Volume 1 covers dwellings, while Volume 2 covers buildings other than dwellings.
However, there’s an important distinction between the Building Regulations themselves and the guidance contained within Approved Document B.
The legal requirements are set out in the Building Regulations 2010, including the functional requirements of Part B.
Approved Document B provides one recognised approach to satisfying those requirements.
Under Section 7 of the Building Act 1984, failing to follow an Approved Document doesn’t automatically create criminal or civil liability. However, compliance or non-compliance with relevant guidance may be relied upon as evidence in proceedings concerning a breach of the Building Regulations.
Alternative design solutions may therefore be appropriate, provided they can be demonstrated to satisfy the relevant legal requirements.
For building owners, the most important point is that Approved Document B primarily concerns building work, rather than imposing an automatic requirement to upgrade every existing building whenever the guidance changes.
Do Existing Buildings Have to Comply With the Latest Approved Document B?
Not automatically.
A building constructed twenty years ago may have been designed and approved in accordance with the standards applicable at the time.
The publication of a newer edition of Approved Document B doesn’t, by itself, mean the building must immediately be brought up to every current recommendation for new construction.
That doesn’t mean older buildings are exempt from fire safety responsibilities.
Under the Regulatory Reform (Fire Safety) Order 2005, the Responsible Person has an ongoing duty to assess fire risks and maintain suitable fire precautions.
The distinction is that these are separate legal frameworks.
The Building Regulations govern relevant building work and material changes of use. The Fire Safety Order places continuing duties on those responsible for premises while they’re occupied and used.
An older building may therefore require improvements because its fire risk assessment identifies inadequate precautions, even where no building work is proposed.
Equally, an existing building doesn’t automatically need a second staircase, new fire doors or a completely redesigned fire alarm merely because current guidance for new buildings has changed.
The question isn’t simply whether your building meets the latest edition of Approved Document B. It’s whether the building remains suitably protected and whether any proposed work triggers current Building Regulations requirements.
What Changes to Approved Document B Are Already in Force?
In September 2024, the Government published three amendment booklets setting out changes scheduled for March 2025, September 2026 and September 2029.
The Government’s official announcement and circular letters explain the changes and their transitional arrangements.
It’s important to distinguish between changes that have already taken effect and those scheduled for the future.
March 2025: Sprinklers in New Care Homes
The first amendments took effect on 2 March 2025.
One of the most significant changes extended the recommendation for sprinklers to all new residential care homes, irrespective of height.
Previously, the guidance didn’t recommend sprinklers in every new care home.
The change recognises the particular fire risks associated with residents who may need assistance to evacuate.
However, this doesn’t mean every existing care home must immediately install a sprinkler system simply because the guidance changed in March 2025.
Existing buildings need to be considered according to their fire risk assessment, current fire precautions and any building work or change of use being undertaken.
The March 2025 amendments also removed references to the national BS 476 classification system for reaction to fire and roofs, moving the guidance towards classifications based on the relevant European standards.
September 2026: Second Staircases in Taller Residential Buildings
The next amendments took effect on 30 September 2026.
These introduced a recommendation for more than one common staircase in new blocks of flats with a storey at least 18 metres above ground level.
The changes also introduced design guidance supporting evacuation lifts where they are provided.
This is particularly important for developers and those planning substantial residential projects.
However, the introduction of the second staircase recommendation doesn’t automatically require an existing residential block above 18 metres to install another staircase.
Adding a second staircase to an occupied building could involve extensive structural changes, loss of accommodation and very substantial expenditure.
Whether improvements are necessary in an existing building must be considered through the appropriate legal duties, fire risk assessment and any building work proposed.
It’s also important to distinguish the September 2026 guidance from later proposals concerning evacuation lifts.
The current amendment provides guidance for their design where they are included. A separate 2026 consultation proposes additional requirements for new taller residential buildings, but those proposals have not yet been adopted.
September 2029: Changes to Fire Resistance Classifications
A further amendment is scheduled to take effect on 2 September 2029.
This will remove the remaining references to BS 476 fire resistance classifications from Approved Document B, moving towards the relevant European classification framework.
For building owners and contractors, this is particularly relevant when specifying new fire doors, fire-resisting construction and other products.
However, the scheduled change doesn’t mean that every existing door or wall tested to an older BS 476 standard will automatically become unacceptable.
The requirements for newly commissioned work and the suitability of existing fire protection are different questions.
A suitable existing fire door shouldn’t be condemned solely because the guidance for new specifications has changed.
Where replacement products are being specified, however, designers and contractors need to use the appropriate current requirements and supporting technical evidence.
What Are the Transitional Arrangements?
This is where projects can become complicated.
When Approved Document B changes, the Government may provide transitional arrangements allowing certain projects to continue under the previous guidance.
For the September 2026 amendments, the transitional period is particularly important.
Under the 2026 amendment circular, the previous guidance can continue to apply where the relevant building notice, initial notice or building control approval application with full plans was submitted before 30 September 2026 and the building work was sufficiently progressed before that date or within the following eighteen months.
For work to an existing building, sufficiently progressed generally means that the relevant work has started.
For a material change of use, work to effect that change must have started.
The precise application route and transitional conditions need to be checked for the particular project, especially where the higher-risk building regime applies.
The 2025 and scheduled 2029 amendments have different transitional periods, generally six months.
This matters because a project designed under an earlier version of Approved Document B may not automatically retain the right to use that guidance indefinitely.
Before committing to construction work, establish which version of the guidance applies to the project and whether the relevant transitional requirements have been satisfied.
It’s far better to resolve that question before contractors start work than to discover during Building Control approval that the design needs substantial revision.
When Do Changes to Approved Document B Affect an Existing Building?
The most obvious situation is when building work is undertaken.
Under Regulation 3 of the Building Regulations 2010, building work includes the erection or extension of a building, certain controlled services and fittings, material alterations and work necessary because of a material change of use.
But not every refurbishment automatically has the same regulatory implications.
Consider a landlord who wants to redecorate an office, replace floor coverings and install new furniture.
That project is different from one involving new staircases, significant changes to escape routes or alterations to fire-resisting construction.
The second project may have substantial implications for the building’s fire safety design.
Under Regulation 4, building work must satisfy the applicable Building Regulations requirements.
Where an existing building is extended or materially altered, the completed work must meet the applicable requirements, and the building must comply with those requirements or be no more unsatisfactory in the relevant respects than before the work.
This doesn’t mean building owners can carry out new work to outdated standards simply because the original building is old.
The new work must be assessed against the requirements applicable to it, including any transitional provisions.
What About Office Refurbishments and New Partitions?
Imagine a commercial property where the landlord divides a large office into smaller units for separate tenants.
The alterations might affect escape routes, travel distances, fire detection coverage and the fire-resisting separation between occupancies.
New walls, doors, ceilings and service penetrations may also need to satisfy relevant fire safety requirements.
A contractor shouldn’t simply follow the existing fire risk assessment as though it were a complete design specification for the building work.
The Government’s Approved Document B frequently asked questions recognise that guidance used to assess existing premises may be less onerous than the standards applicable when new building work is undertaken.
The fire risk assessment remains important, but it doesn’t replace the Building Regulations design process.
What About Factories, Warehouses and Industrial Premises?
Similar issues arise in industrial buildings.
A factory might install a new mezzanine, alter production areas or introduce additional storage.
A warehouse may be divided into separate units, with new compartment walls and escape routes.
Depending on the work, these alterations can affect means of escape, fire detection, compartmentation and structural fire protection.
They may also introduce significant operational fire risks that need consideration under the Fire Safety Order and, where dangerous substances are involved, DSEAR.
The sensible approach is to consider the implications before the work is designed and commissioned.
Otherwise, owners may discover that an apparently straightforward refurbishment has created expensive fire safety problems elsewhere in the building.
What if You’re Converting an Existing Building to a Different Use?
A material change of use can have particularly significant implications.
Imagine purchasing an older office building and planning to convert the upper floors into flats.
The building may have been perfectly suitable for its previous commercial use.
But residential accommodation introduces different occupancy patterns, sleeping risks and requirements for fire separation and escape.
Under Regulation 6 of the Building Regulations 2010, a material change of use can trigger requirements to bring the building, or the affected parts, into compliance with specified Building Regulations provisions.
These include relevant fire safety requirements such as means of warning and escape, internal fire spread and firefighter access.
The work needed depends on the particular change and the building’s existing arrangements.
For example, converting offices into flats may require new compartmentation, protected escape routes, fire doors, detection systems and other fire safety improvements.
A similar issue can arise where a former shop is converted into a restaurant with commercial cooking equipment beneath residential accommodation.
The building’s original fire strategy may no longer be suitable.
These are circumstances where early fire safety consultancy can save substantial expense.
Identifying the requirements before purchasing equipment or constructing partitions is generally much easier than making expensive changes after the fit-out has been completed.
What Changes Are the Government Still Proposing?
Alongside the amendments already scheduled, the Building Safety Regulator and the Ministry of Housing, Communities and Local Government launched a further consultation on Approved Document B on 25 March 2026.
The consultation closed on 1 July 2026.
As of November 2026, these proposals have not been adopted as final guidance. The Government’s published programme anticipates further work on recommendations during 2027, with the consultation identifying 2 September 2029 as the target implementation date for its proposed changes.
That target isn’t the same as a confirmed commencement date for every proposal.
Several of the proposals could be particularly relevant to existing building owners and future refurbishment projects.
Clearer Guidance for Work to Existing Buildings
One proposal would consolidate guidance explaining how Approved Document B should be applied when undertaking building work in existing premises.
The proposed wording emphasises that alterations shouldn’t reduce the existing building’s level of fire safety.
It also encourages designers and dutyholders to consider the existing fire risk assessment when planning the scope of building work.
This is a useful principle.
Imagine a refurbishment involving the opening up of compartment walls and ceilings.
If the existing fire risk assessment has already identified concerns about compartmentation, it may be sensible to address those issues while the construction is accessible.
That doesn’t mean every refurbishment must automatically become a complete fire safety upgrade.
But it does mean considering whether reasonably practicable improvements can be incorporated into the planned work.
The proposal encourages the building’s fire strategy, fire risk assessment and management arrangements to work together.
Changes to Sheltered and Specialised Housing
The consultation also proposes replacing the term sheltered housing with specialised housing.
It would distinguish between specialised housing with personal care and accommodation where personal care isn’t provided.
The preferred approach proposes extending fire detection within specialised housing with care, including Grade D1, Category LD1 detection within the accommodation under BS 5839-6.
This could have implications for future specialised housing developments.
However, the proposed detection arrangements aren’t yet a blanket legal requirement for every existing sheltered housing scheme.
The appropriate protection for an existing building should still be determined by its current fire risks, occupancy, evacuation arrangements and applicable legal requirements.
Evacuation Lifts in Taller Residential Buildings
The consultation also proposes additional requirements for evacuation lifts in new taller residential buildings.
Its preferred approach would provide at least two staircases and two evacuation lifts in new residential buildings over 18 metres, with appropriate provisions for lifts serving a dual firefighting and evacuation function.
This would build on the second staircase guidance that took effect in September 2026.
Again, the proposal concerns the design of new buildings. It hasn’t created a universal obligation for existing residential blocks above 18 metres to install two evacuation lifts.
Existing owners should distinguish between the Government’s proposed direction for new developments and the arrangements necessary to manage the fire risks in buildings they already own.
Other proposals cover external walls, balconies, combustible structural elements, solar photovoltaic installations on roofs and open-sided car parks.
These may be particularly relevant to owners planning major refurbishment or redevelopment projects.
Why Should Your Fire Risk Assessment and Fire Strategy Be Considered Before Building Work?
This is where problems can become expensive.
A building owner commissions alterations, the architect prepares drawings and the contractor begins work.
Only later does somebody ask how the changes affect the building’s fire safety strategy.
Perhaps the new layout has increased travel distances, compromised compartmentation or altered the fire detection requirements.
The resulting work may require redesign, additional equipment or alterations to construction that’s already been completed.
A more effective approach is to consider fire safety from the outset.
The fire risk assessment provides information about the current building, its hazards and the precautions being relied upon.
The fire strategy establishes the design principles for protecting occupants and supporting the building’s intended use.
Where alterations are proposed, those documents should inform the design, but they shouldn’t be treated as substitutes for demonstrating compliance with the applicable Building Regulations.
At completion, the fire safety documentation, commissioning records and relevant handover information should also be updated.
Where Regulation 38 of the Building Regulations applies, the required fire safety information must be provided to the Responsible Person within the prescribed timeframe.
This helps ensure that the people managing the building understand the precautions installed and how they should be operated and maintained.
What Should Building Owners Check Before Starting Refurbishment Work?
Before committing to a substantial refurbishment, extension or conversion, we’d recommend establishing five things.
- Does the work fall within the Building Regulations? Not every alteration has the same requirements, so establish the correct position with the designer and building control body.
- Which edition of Approved Document B applies? Check the project dates, approval route and any relevant transitional arrangements before relying on an older version.
- What does the existing fire risk assessment say? Review any outstanding findings that could affect the proposed work, particularly those involving escape routes, fire doors, compartmentation and detection systems.
- Will the work affect existing fire precautions? New partitions, service penetrations, doors, layouts and changes of use can alter the protection on which the building relies.
- Will the fire strategy and management arrangements still be suitable afterwards? Plan any necessary reviews, commissioning, documentation and changes to operating procedures before the work is completed.
Where the building is complicated, mixed-use or involves sleeping accommodation, competent fire safety advice should be obtained early in the project.
That’s particularly important where different occupiers, landlords or managing agents share responsibility for the premises.
Should You Upgrade an Existing Building Before the Law Requires It?
Sometimes, improvements can be sensible even where they aren’t automatically required by a new edition of Approved Document B.
For example, an owner undertaking extensive refurbishment may have a cost-effective opportunity to improve compartmentation, replace unsuitable fire doors or upgrade fire detection.
But that doesn’t mean every building should be brought up to every modern new-build recommendation.
The decision should reflect the existing risks, the condition of the building, the intended work and the practical benefits of the proposed improvements.
A properly considered fire strategy can help distinguish necessary compliance work from additional improvements that may be desirable.
It can also help prevent unnecessary expenditure.
The objective isn’t to spend money upgrading everything simply because the guidance has changed. It’s to make sure the building remains safe and that new work is designed to the requirements that actually apply.
What Should Existing Building Owners Remember About Approved Document B?
Approved Document B is changing, and further revisions are expected.
The March 2025 and September 2026 amendments have already taken effect, while the changes to BS 476 fire resistance references are scheduled for September 2029.
The Government is also consulting on additional revisions covering existing buildings, specialised housing, evacuation lifts and other technical matters.
But these changes shouldn’t automatically be interpreted as a requirement to undertake extensive alterations to every existing property.
For owners, landlords and managing agents, the most important considerations are whether the existing building remains suitably protected and what happens when new building work is proposed.
That’s where early planning and competent technical advice can make a significant difference.
A refurbishment that looks straightforward on paper can affect escape routes, fire-resisting construction, detection systems and the building’s evacuation strategy.
Identifying those implications before contractors start work is usually much less disruptive than discovering them when the project is nearly finished.
The question isn’t simply whether your building meets the latest Approved Document B. It’s whether the fire safety arrangements remain suitable today and whether your next project is designed to meet the requirements that apply tomorrow.
Fire Safety Consultancy and Fire Strategies from ESI: Fire Safety
At ESI: Fire Safety, we help building owners, developers, landlords, RTM companies and managing agents understand the fire safety implications of refurbishment, conversion and changes of use.
Our services include fire risk assessments, fire strategies for building control and planning applications, retrospective fire strategy reviews, compartmentation surveys, fire door assessments and independent fire safety consultancy.
We also provide ongoing fire safety management support for organisations responsible for residential blocks, commercial properties and multi-occupied buildings.
With more than 25 years of experience in electrical safety and fire safety compliance, we understand the practical challenges of maintaining existing buildings while undertaking alterations and meeting evolving technical requirements.
Our services cover offices, restaurants, factories, warehouses, residential developments and mixed-use premises across Hampshire, Surrey, Berkshire, Sussex, Kent, Oxfordshire and South West London, including Portsmouth, Ewell, Earley, Hove, Broadstairs, Charlbury and Clapham.
Whether you’re planning a conversion, reviewing an existing fire strategy or concerned about the cost of changes recommended during refurbishment, we can help establish what is necessary, what may be proportionate and what technical assessments are required.
ESI: Fire Safety — No Shortcuts in Safety.
Contact ESI: Fire Safety, call 01276 300 351 or email office@esifiresafety.co.uk to discuss your refurbishment, fire strategy or ongoing fire safety management requirements.
This article concerns Approved Document B and Building Regulations guidance applicable in England, as published in November 2026. Different requirements apply in Wales. The Building Regulations, Fire Safety Order and individual project circumstances should be considered separately, and future consultation proposals should not be treated as requirements already in force.
