Yes. Every holiday let in England and Wales needs one, and since 1 October 2023 it also has to be written down. Before that date an owner letting a single cottage with no employees had to assess the fire risk but had no duty to record what they found. That exemption is gone.
The change arrived inside the Building Safety Act 2022, with no announcement aimed at holiday-let owners, which is why a good deal of guidance still describes the old position.
Where the duty comes from
Fire safety in England and Wales runs on the Regulatory Reform (Fire Safety) Order 2005. Article 9(1) puts it on the “responsible person”, who must make “a suitable and sufficient assessment of the risks to which relevant persons are exposed”.
For a holiday let the responsible person is usually the owner. Relevant persons are the people who could be harmed, which means your guests, your cleaner, and anyone lawfully on the premises.
Two things follow from that wording. The duty attaches to the premises being used as paying guest accommodation, so it applies to a single cottage as much as to a guest house. And the assessment is yours: a fire and rescue service can advise, but the responsibility for making it sits with you.
What changed on 1 October 2023
Article 9(6) used to open with the word “where”, and three conditions followed it. A recorded assessment was required only if the responsible person employed five or more people, or a licence was in force for the premises, or an alterations notice demanded it. A typical holiday-let owner met none of the three.
Section 156(3) of the Building Safety Act 2022 replaced that text. The conditions went, and so did the word “significant” in article 9(7)(a). Both changes commenced on 1 October 2023, in England through the Building Safety Act 2022 (Commencement No. 5) Regulations 2023 and in Wales through the equivalent Welsh commencement regulations made the same year.
Article 9(6), Regulatory Reform (Fire Safety) Order 2005
The three conditions that used to excuse the paperwork
The clause as it was made in 2005, and as it reads today. The struck words are the ones section 156(3) of the Building Safety Act 2022 removed.
Until 30 September 2023
"As soon as practicable after the assessment is made or reviewed, the responsible person must record the information prescribed by paragraph (7) where he employs five or more employees; a licence under an enactment is in force in relation to the premises; or an alterations notice requiring this is in force in relation to the premises."
From 1 October 2023
"As soon as practicable after the assessment is made or reviewed, the responsible person must make a record of the assessment or review, which must in particular include the information prescribed by paragraph (7)."
No threshold replaced the three conditions. The recording duty now reaches every responsible person, which includes the owner of one holiday cottage with nobody on the payroll.
The second change is quieter and easy to miss. Article 9(7)(a) used to require a record of the “significant findings” of the assessment. The word “significant” was deleted, so the record now covers the findings, with no filter applied by the person writing it.
Who the change actually caught
The three old conditions were written for workplaces. A holiday let with no staff sat outside all of them, which is how an entire category of owner ended up with a duty to assess and no duty to show anything for it.
Duty to write the assessment down
The owner with no staff is the one the change reached
Every row has always had to carry out an assessment. The columns show only whether it had to be recorded.
Only the top row changed. It is also the row most holiday lets sit in, which is why the change passed so many owners by.
What has to be in the fire risk assessment record
Article 9(7) prescribes two things.
The first is the findings of the assessment, including the measures which have been or will be taken. That second half is the part owners tend to leave out. A list of hazards with nothing written about what you did is half a record, and the clause asks for both.
The second is any group of people identified by the assessment as being especially at risk. In a holiday let that question has real content: guests asleep in a building they have never been in before, who do not know which door is the back door, and who may have been drinking. Families with small children and guests with limited mobility belong here too if your property takes them.
Beyond those two, the Order does not prescribe a format. There is no official template, no registration step, and nobody to send it to. The record exists so that you can act on it and so that a fire officer can see your reasoning if they ever ask.
Which government guide applies to your property
GOV.UK publishes a guide called “Making your small paying guest accommodation safe from fire”, issued under article 50 of the Order. It was published on 30 March 2023 and last updated on 20 January 2025.
It is written for paying guest accommodation with a simple layout, limited fire risks and a small number of bedrooms used for short-term lets, and it names small bed and breakfasts, guest houses and self-catering accommodation as its audience. It carries a fire risk assessment checklist you can work through.
If your property is larger or more complicated than that description, the same page points you to the separate guide for sleeping accommodation. Reading the right one matters, because the small-premises guide assumes a building a guest can get out of quickly.
Scotland and Northern Ireland
The 2005 Order covers England and Wales only. Scotland runs on Part 3 of the Fire (Scotland) Act 2005, where section 54(2)(a) puts the duty to assess on anyone who has control of relevant premises to any extent, and section 54(3) extends it to the owner where control is not exercised through a business. Northern Ireland has its own separate regime.
A Scottish short-term let also needs a licence, and the licensing scheme asks for fire safety evidence in its own right. The rules guide sets out what each nation requires.
What this article does not settle
It does not tell you whether your assessment is suitable and sufficient. That depends on the building, and the Order deliberately sets a standard rather than a checklist.
It does not tell you what enforcement would cost you. Penalties sit in Part 3 of the Order and vary with the offence, and figures circulating online are frequently attached to the wrong provision, so the Order itself is the place to read them.
It does not tell you whether to write the assessment yourself or pay someone. A simple cottage with a clear escape route is a different job from a converted barn with a mezzanine, and a fire risk assessor will tell you which yours is.
What it does settle is the paperwork question. If your fire risk assessment lives only in your head, it no longer meets article 9(6), and it has not since October 2023.
For the kit that a competent assessment expects to find, from interlinked alarms to furniture labels, the furnishing checklist goes room by room.
If you are still deciding whether to let the property at all, our free valuation comes back with the obvious questions flagged for your property, this one among them.
Frequently asked questions
Do I need a fire risk assessment for a one-bedroom holiday cottage?
Yes. The duty under article 9 of the Regulatory Reform (Fire Safety) Order 2005 attaches to premises used as paying guest accommodation, and it sets no minimum size and no minimum number of bedrooms. Since 1 October 2023 the assessment must also be recorded.
Is there an official fire risk assessment template for holiday lets?
No. The Order prescribes what the record must contain, which is the findings including the measures taken or planned, and any group especially at risk, and it leaves the format open. The GOV.UK guide for small paying guest accommodation includes a checklist you can work from.
Who is the responsible person for a holiday let?
Usually the owner. The Order defines the responsible person by control of the premises, so where an agent or manager has taken on control of part of the operation the duty can be shared. Having someone else run the lettings does not by itself move the duty off the owner.
Sources
- legislation.gov.uk: Regulatory Reform (Fire Safety) Order 2005, article 9 (current text, showing the 1 October 2023 amendments; read 2026-10-17)
- legislation.gov.uk: Regulatory Reform (Fire Safety) Order 2005, article 9 as made (the original three conditions in paragraph (6); read 2026-10-17)
- legislation.gov.uk: Building Safety Act 2022, section 156 (substitutes article 9(6) and deletes “significant” from 9(7)(a); read 2026-10-17)
- legislation.gov.uk: The Building Safety Act 2022 (Commencement No. 3, Transitional and Saving Provisions) (Wales) Regulations 2023 (regulation 3, 1 October 2023 for Wales; read 2026-10-17)
- GOV.UK: Making your small paying guest accommodation safe from fire (article 50 guidance; published 30 March 2023, last updated 20 January 2025; read 2026-10-17)
- legislation.gov.uk: Fire (Scotland) Act 2005, Part 3 (sections 53 and 54, the Scottish duty to assess; read 2026-10-17)
