Does a Holiday Let Flat in a Converted Building Need Its Own Fire Risk Assessment? (Wales)

2 days ago

7 min read

The building is a handsome three-flat conversion of a Victorian house in Cardiff. One of the flats is a holiday let we manage. When the owner moved to a specialist holiday-home insurance policy this autumn, the insurer's paperwork prompted an obvious question: where was the fire risk assessment?

The only one on file dated from 2015. It had been commissioned by a previous freeholder, and it covered the communal hallway and stairs — not the flat. So, as far as the flat itself was concerned, there wasn't one. We asked three accredited assessors to quote, compared the prices (£300 and £330 for an in-depth assessment of the flat; one assessor offered to include the whole building and communal areas for a little more), checked the booking calendar for a gap between guests, and booked the visit.

It is one of the most common gaps we see in converted buildings, so here is the short version of what the law in Wales expects of a holiday let fire risk assessment in 2026.

A white smoke alarm on the ornate ceiling of a period apartment hallway — A holiday-let flat is treated as business premises for fire safety — even inside a residential building.

Does a holiday let in Wales need its own fire risk assessment?

Yes. In Wales, a flat let to paying guests is not treated as a private home for fire safety purposes. The person in control of it — usually the owner, and the manager to the extent they control it — must make sure a suitable and sufficient fire risk assessment is carried out, and since 1 October 2023 the whole assessment has to be recorded in writing. The communal assessment for the building does not cover it.

Two sets of premises, two responsible persons

The Regulatory Reform (Fire Safety) Order 2005 applies to non-domestic premises in England and Wales. A home someone lives in is outside it. But Welsh Government guidance is clear that wherever someone pays to stay somewhere other than as their permanent home, the Order applies — even if the property is only let occasionally. The duty sits with the "responsible person": the person in control of the premises in connection with the business, or the owner if no one else is in control. Anyone else with a degree of control, such as a managing agent, shares those duties to that extent.

In a converted building, that gives you two layers:

The holiday-let flat itself — the owner (and their manager) as responsible person.
The common parts — hallway, stairs, structure, external walls and the doors between each flat and the common parts. Since the Fire Safety Act 2021 came into force in Wales on 1 October 2021, these are explicitly within the Order. The responsible person is usually the freeholder, the residents' management company or its managing agent.

Infographic: in a converted building the holiday-let flat and the common parts are separate premises with separate responsible persons — Two premises, two responsible persons — and two assessments that should talk to each other.

The two must co-operate and share information. And if the management company is run by the leaseholders themselves, it's worth knowing that directors can be personally liable if an offence happens with their consent or through their neglect. Insurance on the building doesn't discharge that duty — an assessment does.

It has to be written down — in full

This is the change most owners have missed. Until 2023, a written record was only required in limited cases, for example with five or more employees. Since 1 October 2023, section 156 of the Building Safety Act 2022 has required every responsible person in Wales, as in England, to:

record the full fire risk assessment and all its findings, as soon as practicable;
record the name of anyone who helped carry it out, and their organisation;
record the fire safety arrangements for the premises;
identify the other responsible persons in the building and share relevant information with them;
in buildings with two or more homes, give residents relevant fire safety information.

An assessment from 2015, or one that only covers the hallway, doesn't meet that standard for a holiday-let flat.

What an assessor will look at in a holiday-let flat

The staircase and landing of a converted Victorian house in Cardiff, with a dark timber banister and white doors — Stairs and landings are the escape route, so an assessor looks at them — and the doors that open onto them — as closely as the flat itself.

The Welsh Government's guide for small paying guest accommodation applies only in Wales — don't rely on the English Home Office version — and South Wales Fire and Rescue Service publishes its own self-catering guidance. Between them, expect the assessor to look at:

Smoke alarms: mains powered with a tamper-proof battery backup, interlinked, in the hall or landing, living room and bedrooms. Sealed long-life battery alarms are only an interim measure.
A heat alarm in the kitchen, and a carbon monoxide alarm in any room with a gas, oil or solid-fuel appliance.
The flat entrance door: fire-resisting and self-closing where it opens onto communal areas. Fire Service guidance describes this as a 30-minute self-closing door.
Internal doors on the escape route: solid doors rather than hollow-core.
Escape lighting: rechargeable torches that switch on automatically in each bedroom, or plug-in night lights, are usually enough in a small flat.
Fire blankets: here the two guides differ. The Welsh Government says they aren't needed in self-catering; the Fire Service guidance suggests a kitchen fire blanket as a minimum. We provide one.
Gas and electrics: an annual gas safety check by a Gas Safe engineer is a legal requirement for holiday lets, and guidance expects the electrics to be inspected and tested at least every five years.
Guest information: clear instructions on what to do in a fire and how to get out.

Choosing an assessor and what it costs

For simple premises, the guidance accepts that a confident owner can do the assessment themselves. For a holiday-let flat inside a converted building — where the escape route and the communal doors matter as much as the flat — we recommend a competent, accredited assessor. Look for registration with a professional body such as the Institution of Fire Engineers or the Institute of Fire Safety Managers, or third-party certification such as BAFE SP205. Ask for a written scope, proof of professional indemnity insurance and references. Whoever does it, the legal responsibility stays with you.

Our own quotes for a two-bedroom flat in Cardiff were £300 and £330. A whole-building assessment, including the communal areas and every flat entrance door, costs more but can be shared between the leaseholders.

How often to review it

There is no fixed legal interval. The law says to review it regularly and whenever you have reason to think it is out of date — after alterations, a change in how the property is used, or a fire. In practice the Welsh Government expects a review about once a year, and that's what we diarise for every property.

What happens if you don't

In Cardiff, South Wales Fire and Rescue Service enforces the Order. It can issue alteration, enforcement and prohibition notices, and serious breaches can lead to prosecution, with unlimited fines and, in the most serious cases, up to two years in prison. In 2025 a holiday-let business in St Ives was ordered to pay more than £33,000 in fines and costs after breaches that included having no suitable risk assessment. Beyond the law, a missing assessment is exactly the kind of gap that complicates an insurance claim.

What's coming next

Two new Welsh laws will tighten this further. The Building Safety (Wales) Act 2026 will introduce new duties for residential buildings with two or more homes, including fire risk assessment by a competent person, though most of those duties are not yet in force. And the visitor accommodation licensing scheme under the Development of Tourism and Regulation of Visitor Accommodation (Wales) Act 2026 will make a written fire risk assessment a licence requirement, alongside gas, electrical and carbon monoxide safety — expected from 2029, with a legal default date in March 2030. Owners who put a proper assessment in place now will simply carry it forward.

Common mistakes we see

Assuming the building's communal assessment covers the holiday-let flat.
Believing a written record is only needed with five or more employees.
Relying on an assessment from before 2021 or 2023.
Following the English guide instead of the Welsh one.
Assuming the Renting Homes rules on alarms and electrical checks apply — they don't apply to holiday lets, but fire safety law and the gas rules do.
Directors of a residents' management company assuming only the company is responsible.
Not recording the assessor's name or sharing the findings with the building's other responsible person.

Frequently asked questions

Does my holiday let need a fire risk assessment in Wales?

Yes. If someone pays to stay and it isn't their permanent home, the Fire Safety Order applies, and the responsible person must have a suitable and sufficient fire risk assessment recorded in writing.

Does the communal fire risk assessment cover my flat?

No. The common parts and the holiday-let flat are separate, with separate responsible persons. The two assessments should be co-ordinated, but one doesn't replace the other.

Who is the responsible person for a holiday-let flat?

The person in control of the premises in connection with the business — usually the owner. A managing agent shares the duties to the extent they control the property.

How much does a fire risk assessment for a holiday let cost?

It depends on the size and layout. Our recent quotes for a two-bedroom flat in Cardiff were £300 and £330; a whole-building assessment costs more.

How often should it be reviewed?

Regularly, and after any significant change. The Welsh Government expects a review about once a year.

How we help

For every property we manage, we keep a compliance file — fire risk assessment, gas safety, electrical certificates, insurance — source quotes from accredited suppliers, and arrange visits around guests so nobody's stay is disturbed. If you'd like us to look at what your property has on file, we'd be glad to. We also explain the wider picture in our Welsh holiday-let safety certificates checklist.

Ask us about your property's compliance

This article is general guidance based on the law and guidance in force on 19 October 2026. It is not legal advice; for your own premises, take advice from a competent fire risk assessor.