Fire Statement or Fire Safety Strategy: which one you need

A Fire Statement is a planning document. A Fire Safety Strategy is a fire engineering document. They arrive at different points in the consent sequence, they are read by different regulators, and submitting one where the other is required is a validation failure rather than a helpful extra.

The short version: if your scheme is a relevant building, you need a Fire Statement on the published form with the planning application. The fire safety strategy comes later, for the building control route, unless the council has asked for one as supporting information.

Where each document sits in the sequence

Planning Gateway One is the first of the three gateways introduced under the building safety framework. It sits at the planning application stage and its purpose is to make sure fire safety has shaped the design before the layout is fixed, rather than being resolved afterwards by adding sprinklers and hoping.

Article 9A of the Town and Country Planning (Development Management Procedure) (England) Order 2015 is the provision that requires the Fire Statement, and it took effect on 1 August 2021. The Health and Safety Executive, acting as the Building Safety Regulator, is a statutory consultee on those applications and comments on the fire statement.

Gateway Two comes before construction begins and is where the Building Safety Regulator approves the detailed design for higher-risk buildings. Gateway Three is at completion. A fire safety strategy prepared to the relevant British Standard is the document that carries the technical case through those later stages and supports compliance with the fire requirements of the Building Regulations.

So the two documents are sequential, not alternatives. One informs the planning decision. The other informs the construction approval.

Relevant buildings and the Article 9A trigger

The requirement bites on a relevant building, which in broad terms means a building containing two or more dwellings, or educational accommodation, and which either contains seven or more storeys or is 18 metres or more in height.

Two points catch architects out.

Height and storey count are alternatives, not cumulative. A building of seven storeys that measures under 18 metres is caught. So is a five-storey building that reaches 18 metres because of tall floor-to-floor dimensions or a sloping site.

And the trigger applies to development of a relevant building, which includes works to an existing building that would create or alter one, not only new construction. A rooftop extension taking an existing block from six storeys to seven brings the scheme into scope.

Where the scheme sits just under a threshold, say so explicitly in the planning statement with the measured height and the storey count, and state the datum used. Validation officers check this, and an application that is silent on it invites a query.

What the Fire Statement asks for

The Fire Statement is completed on the form published by the Secretary of State, and it is a planning-level document about the matters planning can influence. It asks about the principles of the fire safety design as they affect the layout and the site, including:

• the siting of the building and its relationship to neighbouring structures
• access and hardstanding for fire service vehicles, including turning and setting-down
• water supplies for firefighting and their location
• means of escape strategy in outline, including the evacuation approach
• the principles of external wall construction and any features affecting fire spread
• the arrangement of any car parking, refuse and plant that could affect fire spread or access
• how the design responds to the site constraints, such as a narrow frontage or a restricted access route

It also asks who prepared it and on what basis of competence. That question is not decorative.

What the form does not ask for is compartmentation detail, smoke control calculations, sprinkler design or fire resistance periods. Those belong in the strategy, and stuffing them into the planning submission does not improve it.

What a fire safety strategy contains instead

A strategy prepared to the residential or the general British Standard sets out the fire engineering case for the building. It covers the fire strategy diagram floor by floor, compartmentation and fire resistance periods, means of escape with travel distances and stair capacity, the evacuation strategy, smoke control, detection and alarm, suppression, firefighting shafts and facilities, external fire spread and facade design, and the management assumptions on which all of it depends.

It is a live document. It develops from concept through detailed design, and it is the reference point for the Building Safety Regulator, the building control body and, eventually, the responsible person under the fire safety regime once the building is occupied.

Illustrative example: a seven-storey residential block

Take a proposed block of 34 flats over seven storeys, measured at 17.4 metres to the top storey floor level. This example is illustrative.

The height is under 18 metres, but the storey count is seven, so it is a relevant building and Article 9A applies. A Fire Statement on the published form goes in with the application, the Health and Safety Executive is consulted, and the planning submission has to demonstrate that fire service access, water supplies and the escape principle work on this constrained site.

The design consequences show up early. If the only vehicular access is a 3.5 metre wide route with a tight turn, the layout may need reworking before the planning drawings are fixed. If the scheme relies on a single stair, the escape strategy has to be explained at the planning stage rather than deferred.

The strategy document then develops that outline into the technical case for Gateway Two, and it will be a substantially longer document dealing with matters the planning authority never sees.

Competence: who may author each

Both documents require fire engineering competence, and neither is a form-filling exercise.

The Fire Statement asks the author to state their competence, and the expectation is someone with fire engineering knowledge appropriate to the building, not the project architect completing a form. A strategy to the relevant British Standard is unambiguously a fire engineering document and should be authored by a suitably qualified fire engineer.

This matters legally as well as practically. A Fire Statement is a report type where a competent professional is required rather than merely advisable, under the building safety framework and Article 9A. PlanScope can draft the structure, the policy framing and the planning-level content, and flags where information is missing rather than inventing it, but the document is a starting point for the fire engineer who signs it, not a substitute for one. For specialist technical reports, qualified professional input may be required.

Validation failures caused by the wrong document

Four recur.

Submitting a fire strategy instead of the Fire Statement. The strategy may be excellent and the application will still be invalid, because Article 9A requires the specified form.

Using an old version of the form, or a consultant's own template that reproduces the headings. Download the current published form.

Leaving the competence declaration blank or naming a practice rather than a person.

Failing to address the site-level questions at all, because the author has written a building-level document. Fire service access, water supplies and siting are the planning questions, and an answer that says these will be addressed at Gateway Two misses the point of Gateway One.

Where the scheme is close to a threshold or the building type is unusual, ask the council at pre-application stage whether a statement is required and put the answer in writing. Alongside it, the design and access statement should explain how the fire strategy shaped the layout, since that is the evidence that Gateway One has done its job.

This is general guidance, not legal advice. Check the position with your local planning authority, the Building Safety Regulator or a qualified professional before relying on it.

Browse the 66 PlanScope report types to see how the fire documents sit alongside the rest of a major application pack. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.