What the New Guidance Means for Developers, Contractors and Building Owners
Fire engineering has changed. Under today’s building safety regime, a fire strategy report is no longer viewed as a standalone document that gets submitted and forgotten. It is now part of a much wider evidence trail that follows a project from concept design through to handover.
That is exactly what the new FIA Scope of Works for Fire Engineers 2026 has been designed to address.
The updated guidance reflects the reality of the Building Safety Act 2022, the Building Safety Regulator (BSR), and the increased scrutiny now placed on Higher Risk Buildings (HRBs). It also changes what clients should expect from a fire engineering consultant.
At FDS Consult UK, we see this as a positive step for the industry. Clearer responsibilities, earlier coordination and evidence-led design all help reduce risk, avoid delays and improve project outcomes.
Why the 2026 Scope Changes the Client Brief
Historically, some projects treated fire engineering as a relatively isolated design exercise. A fire strategy would be produced, reviewed during design, and revisited later if issues arose. The new FIA guidance moves away from that approach entirely. Instead, it defines fire engineering as an active, ongoing process that supports:
- Design coordination
- Gateway submissions
- Technical reviews
- Site inspections
- Quality assurance
- Change management
- Final compliance evidence
In simple terms, the fire engineer is no longer expected to simply “issue a report”. They are expected to help manage fire safety throughout the lifecycle of the project. For clients, that means two things become critically important:
- Appointing a fire engineer early enough to influence the design properly
- Clearly defining the scope of responsibility from the outset
Without that clarity, projects can face avoidable redesigns, delays and regulatory challenges later in the process.
What the Fire Engineer’s Responsibility Matrix (FERM) Really Means
One of the biggest changes introduced in the FIA guidance is the Fire Engineer’s Responsibility Matrix, known as the FERM.
This matrix helps define:
- What the fire engineer will review
- How detailed those reviews will be
- Whether site inspections are required
- Which stages of the project the reviews apply to
The guidance introduces different review levels:
- R0 – No review
- R1 – Basic review
- R2 – Intermediate review
- R3 – Detailed review
It also introduces construction inspection levels:
- C0 – No inspection
- C1 – Basic inspection
- C2 – Periodic inspections
- C3 – Detailed inspection regime
This is important because it removes ambiguity. Instead of assumptions being made about what the fire engineer is or is not responsible for, the expectations are agreed at appointment stage. For developers and contractors, this creates far better accountability and reduces the risk of disputes later in the project.
How Fire Engineer Involvement Changes Across RIBA Stages
The updated guidance also reinforces that fire engineering should not begin at Building Regulations submission stage. It should begin much earlier.
RIBA Stages 0–1: Preparation
At this stage, involvement is usually project-specific, but early discussions can help identify key fire safety considerations before design work progresses too far.
RIBA Stage 2: Concept Design
This is where the fire engineer begins establishing:
- Fire safety objectives
- Applicable legislation
- Project-specific requirements
- Early fire strategy principles
- General arrangement reviews
At this point, the project team can also identify whether detailed fire engineering analysis may be required later.
RIBA Stage 3: Spatial Coordination
The scope expands significantly during Stage 3.
This often includes:
- FERM-led design reviews
- Coordination with the wider design team
- Gateway 1 Fire Statements
- Preliminary fire engineering analysis
- Design review meetings
This stage is critical because many major design decisions are being locked in.
RIBA Stage 4: Technical Design
Stage 4 is now one of the most important phases under the Building Safety Act regime.
The fire engineer may be expected to:
- Review technical design information
- Re-review amended documents
- Support Gateway 2 submissions
- Coordinate technical fire safety details
- Assess engineered solutions
- Provide evidence-led justification
This is where issues can become expensive if they are discovered too late. Early coordination helps reduce redesign risk before submissions are made to the BSR.
RIBA Stages 5–6: Construction and Handover
During construction, the focus moves towards:
- Site inspections
- QA review processes
- Benchmarking
- Commissioning support
- Change control reviews
- Final compliance information
- Regulation 38 documentation
- Gateway 3 evidence for HRBs
The guidance makes it clear that inspections support contractor QA processes rather than replace them entirely. However, documented inspections and review comments now form an important part of the overall compliance record.
Why Higher Risk Buildings and Gateway Approvals Raise the Stakes
The changes introduced under the Building Safety Act have significantly increased the level of scrutiny placed on Higher Risk Buildings. For these projects, clients must now demonstrate:
- Competent appointments
- Effective coordination
- Proper change management
- Evidence-led compliance
- Clear project records and documentation
Gateway approvals are no longer simple submission exercises. The BSR expects detailed evidence showing that fire safety has been properly considered throughout the design and construction process. If major design changes occur later in the project, further approvals may also be required before those changes can proceed.
From a commercial perspective, that creates a very clear lesson; The earlier fire engineering is properly integrated into the project team, the lower the risk of delays, redesigns and approval issues later.
What to Look for in a Fire Engineering Consultant
The new FIA guidance places a major emphasis on competence and coordination.
For clients seeking fire engineering services, that means looking beyond whether a consultant can simply produce a fire strategy report.
Instead, you should assess whether they can support the wider project and regulatory process.
Key areas to consider include:
- Experience on similar projects
- Understanding of Gateway processes
- Design coordination capability
- CFD modelling and analysis capability
- Experience supporting BSR submissions
- External wall assessment expertise
- QA and inspection processes
- Clear reporting and evidence management
Most importantly, the consultant should understand how fire safety decisions affect programme, approvals and commercial risk across the entire project lifecycle.
How FDS Consult UK Helps Reduce Risk and Keep Approvals Moving
At FDS Consult UK, our approach has always been to deliver fire engineering services early, collaboratively and with a strong focus on practical project delivery.
Our services include:
- Fire strategies
- Fire Statements
- Gateway support
- CFD modelling and analysis
- Independent third-party reviews
- External wall assessments
- PAS 9980 support
- EWS1 support
We work closely with developers, contractors, architects and multidisciplinary design teams to help identify issues early, improve coordination and support smoother approval processes.
For clients, that means:
- Reduced redesign risk
- Better design coordination
- Stronger Gateway submissions
- Clearer technical justification
- Better visibility of compliance risk
- Fewer surprises later in the project
The Industry Is Moving Towards Evidence-Led Compliance
The new FIA Scope of Works does not simply introduce more paperwork. It introduces more clarity. The guidance reflects a wider shift happening across the construction industry, where fire safety must now be demonstrable, coordinated and properly documented throughout every stage of a project.
For developers, contractors and building owners, the message is becoming increasingly clear: Fire engineering is no longer a standalone report. It is an active part of the design, construction and approval process. In today’s regulatory environment, appointing the right fire engineering consultant early can make a major difference to programme certainty, approval risk and overall project success.