Fire statement thresholds: floorspace, height and storeys
The statutory fire statement trigger is height and storey count, not square metres. London Plan Policy D12 and screening checklists are where the 1,000 square metre figure comes from, and they ask for different things.
There is no floorspace trigger for a fire statement in national law. The statutory requirement in Article 9A of the Development Management Procedure Order 2015 turns on height and storey count, not on square metres, and it only bites on a relevant building. So if a checklist tells you that 1,000 square metres of homes requires a fire statement, that number is coming from somewhere other than Article 9A, and knowing where matters because the two routes ask for different things.
The floorspace figure comes from two real places: London Plan Policy D12, and the screening logic built into software and validation checklists. Both are real. Neither is the Article 9A trigger.
The statutory trigger: relevant buildings and the height condition
Article 9A requires an application to be accompanied by a fire statement, on a form published by the Secretary of State, where the development involves providing one or more relevant buildings or developing an existing relevant building.
A relevant building is one that contains two or more dwellings, or educational accommodation, and meets the height condition. The height condition is 18 metres or more in height, or seven or more storeys. Height is measured upwards from ground level, finishing at the floor surface of the top storey, and a storey consisting only of plant or machinery is left out of both the measurement and the count.
Two consequences follow for an architect sizing a scheme. A six storey block at 17.4 metres is outside Article 9A however many flats it holds. And a seven storey block of maisonettes at 16 metres is inside it, because the storey count is an alternative test rather than a corroboration of the height one. The measurement conventions are unforgiving and worth resolving on section drawings before the submission is assembled, as set out in the discussion of fire and regulator consultation as building height rises.
Where 1,000 square metres actually comes from
In London, Policy D12 of the London Plan asks for a fire statement with all major development proposals, and major development includes 10 or more dwellings or 1,000 square metres or more of floorspace. That is a development plan requirement rather than a procedural one, so a London borough can refuse to validate or can refuse permission on policy grounds for a six storey scheme that Article 9A never touched.
Outside London, the figure usually appears as a prompt rather than a rule. Software that screens a site for likely report requirements, including PlanScope's own recommendation engine, flags a fire statement for residential schemes at or above 1,000 square metres so that the question gets asked early. It is a trigger for a conversation with the authority, not a statement that the law requires the document. Councils' own validation lists and the national requirements take precedence, and some authorities have adopted local policies closer to the London position.
| Route | Trigger | What it asks for |
|---|---|---|
| Article 9A DMPO 2015 | Relevant building at 18 m or more, or 7 or more storeys | Fire statement on the published form, plus Building Safety Regulator consultation |
| London Plan Policy D12 | Major development, including 1,000 m² or more | Fire statement addressing the policy's listed matters |
| Screening checklists | Residential floorspace prompts, commonly 1,000 m² | A question to put to the case officer |
What the statement has to address
The published form is structured, and that structure is the easiest way to judge whether a draft is adequate. It asks about the site layout and access for fire appliances, water supplies for firefighting, the construction method and materials, the means of escape and the evacuation strategy, features that reduce the risk to life, and how the proposals affect occupants with reduced mobility.
The honest difficulty is that several of those answers depend on design decisions that are not fixed at planning stage. A fire statement should say what the strategy is and what constrains it, and it should not invent a sprinkler specification to fill a box. Where the strategy is still undetermined, say which options remain open and what would close them off.
A fire statement is not the same document as a fire safety strategy to BS 9991 or BS 9999. The first is a planning submission answering Article 9A or Policy D12. The second is a fire engineering document for building control and the design team, and it is considerably longer.
Who can prepare it
Both documents require fire engineering competence. The fire statement asks for the author's details and relevant qualifications, and an authority that receives one signed by an architect with no fire engineering background will treat the content accordingly. For buildings in scope of the Building Safety Act 2022 framework, a competent professional is legally required, and an AI-assisted draft is a starting point for that professional rather than a substitute for their judgement.
That division of labour works well in practice. Let the draft assemble the site description, the access arrangements, the water supply information from the undertaker and the policy context. Let the fire engineer write the evacuation strategy and sign the form.
Validation, consultation and the effect on programme
An application that should have a fire statement and does not will be returned as invalid. That is the cleanest failure mode, because you lose days rather than weeks.
The slower problem is consultation. The Health and Safety Executive, acting as the Building Safety Regulator, is a statutory consultee at Planning Gateway One for relevant applications, and its response has to be considered before the authority decides. Budget for the full consultation period and expect questions where the statement is thin on firefighting water supplies or on access for a high reach appliance.
Illustrative example, not a real scheme: a seven storey block of 34 flats at 19.2 metres in a London borough is caught twice, by Article 9A on height and by Policy D12 as major development. The applicant commissions a fire engineer at concept stage, the statement goes in with the application, the Building Safety Regulator responds within its period, and the scheme reaches committee on programme. A comparable six storey block at 17.1 metres in the same borough still needs a statement under D12, but no Gateway One consultation follows. Same borough, same number of flats, two different procedural routes.
Where a scheme is close to the line, the decision about an extra storey is no longer only a density question. It pulls the building into the gateway regime for the whole of its design and construction, and it often moves the application out of delegated powers and onto a committee agenda, which the analysis of scale and the shift from delegated to committee decision covers in more detail.
Practical sequence for a scheme near the threshold
- Fix the top storey finished floor level and the ground level datum on a section, then state the measured height in metres on the drawing.
- Count storeys, excluding any level that is exclusively plant, and record the count.
- Check whether the building contains two or more dwellings or educational accommodation.
- Check the development plan for a local fire statement policy, which in London means Policy D12.
- Ask the case officer in a pre-application enquiry whether a statement is required, and get the answer in writing.
- Appoint the fire engineer before the design is frozen, not after.
Do step one properly and the rest follows. Most arguments about whether a fire statement was needed turn out to be arguments about where ground level was measured.
This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it. For specialist technical reports, qualified professional input may be required.
PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.
Frequently asked questions
Does 1,000 square metres of housing legally require a fire statement?
Not under Article 9A of the Development Management Procedure Order 2015, which turns on the building being 18 metres or more in height or having seven or more storeys. In London, Policy D12 of the London Plan asks for a fire statement with all major development, and major includes 1,000 square metres or more, so the figure is a development plan requirement there.
How is the 18 metre height measured?
Upwards from ground level, finishing at the floor surface of the building's top storey. A level consisting only of plant or machinery is excluded from both the measurement and the storey count. Because ground level on a sloping site is open to argument, mark the datum and the top storey finished floor level on a section drawing and state the measured figure.
Is a fire statement the same as a fire safety strategy?
No. A fire statement is a planning submission on a form published by the Secretary of State, answering the matters Article 9A or Policy D12 lists. A fire safety strategy is a fire engineering document prepared to BS 9991 or BS 9999 for building control and the design team. The strategy is far longer and more technical.
Who has to write the fire statement?
Someone with fire engineering competence. The form asks for the author's qualifications, and for buildings within the Building Safety Act 2022 framework a competent professional is legally required. A draft can assemble the site description, access arrangements, water supply information and policy context, but the evacuation strategy and the sign-off belong to the engineer.
What happens if the statement is missing?
The application is returned as invalid, so the clock never starts. That is recoverable within days. The costlier failure is a thin statement that survives validation and then draws questions from the Health and Safety Executive as Building Safety Regulator at Planning Gateway One, which can add weeks to determination of a scheme already on a tight programme.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.