Grenfell Progress Report, September 2026: Fire Risk Assessor Regulation Is Next

On 10 September 2026 the government published its latest progress report on the Grenfell Tower Inquiry's Phase 2 recommendations. It marks 30 of the 61 recommendations complete, nine of them since the May 2026 report, and commits to a response on fire risk assessor regulation between October and December 2026. For anyone who appoints a fire risk assessor, that response is the one to watch. It will set out how the government intends to make independent certification of assessors mandatory, and your file should already show who assessed your building and why they were a reasonable choice.

What the September 2026 report says

The report, updated on 2 October 2026 to add translations, is split into four themes: the construction industry (28 recommendations, 9 complete), fire and rescue services (13 recommendations, 9 complete), response and recovery (14 recommendations, 7 complete) and vulnerable people and Phase 1 (6 recommendations, 5 complete). The government says it "continue[s] to expect that all recommendations will be implemented by the end of 2029", and that a further progress report will be published in December 2026.

The implementation timeline published alongside it lists every recommendation with a status. As of 12 October 2026 the recommendations marked complete are 2, 3, 9, 17, 22, 23, 25, 27, 28, 31 to 34, 37 to 42, 44, 51 to 59 and 61. Most of those are fire and rescue service items, such as the London Fire Brigade inspections and the BS 750 amendment published on 11 August 2026, and response and recovery guidance for local authorities.

The recommendations that matter most to responsible persons and building owners are still in progress, and the report puts dates on them.

Recommendation 26: fire risk assessor certification

Recommendation 26 asked for a system of mandatory accreditation for fire risk assessors. The government accepted it in full and the report restates the commitment: "We will legislate to make it a mandatory requirement for fire risk assessors" to have their competence independently verified by a UKAS-accredited certification body.

The consultation on the fire risk assessor profession, published by the Ministry of Housing, Communities and Local Government, ran from 26 March to 18 June 2026 and applied to England. It covered the future development of the profession, the powers needed to regulate it and how competency requirements should be implemented. The consultation page still says "We are analysing your feedback" and no response had been published as of 12 October 2026.

The progress report is specific about what comes next: "We intend to publish the government's response in Q4 (October to December) 2026." The timeline then shows primary legislation in 2027 to 2029, "subject to Parliamentary time", and a single regulator with sector-specific accreditation requirements in 2028 to 2029. The named lead is the Director of Fire Policy at MHCLG.

Two things follow from that. First, there is no legal requirement today for an assessor to hold a particular certificate, qualification or register entry. Second, the direction of travel is settled, and the words used to describe an assessor's competence will change within the life of most current assessments. The record you keep now should be written so that it still makes sense when they do.

The uncommenced competence duty

Parliament has already passed a competence duty. Section 156(4) of the Building Safety Act 2022 inserts a new article 9A into the Regulatory Reform (Fire Safety) Order 2005, under which the responsible person "must not appoint a person to assist them with making or reviewing an assessment under article 9" unless that person is competent.

The rest of section 156 came into force on 1 October 2023 through commencement regulations SI 2023/362 (England) and SI 2023/914 (Wales). Subsection (4) is not listed in either commencement entry on legislation.gov.uk, and as of 12 October 2026 no commencement date is shown for it. The duty to record the identity of anyone who assists with an assessment, under article 22A, has been in force since October 2023. The duty to appoint only a competent person has not.

The Q4 2026 response is likely to say how article 9A will be switched on and what "competent" will mean in practice. Until then, competence is a matter of the responsible person's judgement, and the file should show how that judgement was made.

Qualifications and certification schemes are moving first

Industry has not waited for legislation. On 7 September 2026 the Fire Industry Association announced three Ofqual-regulated qualifications awarded by FireQual: a Level 3 Certificate in Foundation Fire Risk Assessment, expected in early 2027; a Level 4 Certificate in Intermediate Fire Risk Assessment, available now by an assessment-only route for experienced assessors; and a Level 5 Certificate in Advanced Fire Risk Assessment, to follow. The Level 4 qualification was developed with reference to BS 8674:2025, the framework for competence of individual fire risk assessors, which grades assessors against the complexity of the buildings they work on.

BAFE SP205, the main third-party certification scheme for fire risk assessment organisations, was revised to version 6 in November 2025 and took effect for audits from 1 April 2026. The scheme is mapped to BS 8674 and gives certificated organisations until 31 March 2028 to hold the regulated qualifications at the right level. BAFE describes the 2028 date as the point at which the qualifications become mandatory under the scheme.

So an assessor you appoint in 2026 may describe their competence by reference to a BS 8674 level, a FireQual or IFE qualification, a BAFE SP205 certificate held by their employer, membership of a professional register, or simply experience. All of those are legitimate today. The point of the record is to capture which one applies.

The wider timetable: Approved Document B, products and the regulator

Item	Status at 10 September 2026	Next dated step
Fire risk assessor regulation (rec 26)	In progress; consultation closed 18 June 2026	Government response Q4 2026; primary legislation 2027 to 2029
Fire functions under one Secretary of State (rec 3)	Complete	Fire policy moved from the Home Office to MHCLG from 1 April 2025
Approved Document B review (recs 5 to 8, 11, 12)	In progress; BSR consultation closed 1 July 2026 with more than 500 responses	Analysis Q1 2027; recommendations to update ADB Q2 2027; Fundamental Review next steps Q4 2027
Advisory body on fire safety guidance (rec 9)	Complete; Building Advisory Committee and its Fire Safety Working Group operating	None
Construction products (recs 13, 14, 24)	In progress; White Paper and General Safety Requirement consultations closed May 2026	Government responses Q4 2026; legislation 2027 to 2029
Chief Construction Adviser (rec 4)	In progress; interim adviser in post since 2025, recruitment underway	Appointment anticipated by end of 2026
Single construction regulator (rec 1)	In progress; BSR an arm's length body since January 2026, out of HSE since June 2026	Regulatory Reform Prospectus and design consultation later in 2026; primary legislation later in the Parliament
Residential PEEPs (rec 60)	Majority in force since April 2026	Primary legislation for one remaining element, 2027
Next progress report		December 2026

Two points for the file. Any fire strategy or external wall appraisal commissioned before the Approved Document B recommendations appear in 2027 should note which edition of ADB it relied on. And because fire policy now sits with MHCLG, the fire risk assessor response will come from the department that also owns the Fire Safety Order, building regulations and the Building Safety Regulator.

What a responsible person should record now

Article 22A of the Fire Safety Order already requires you to keep a record of the identity of anyone you appointed to assist with making or reviewing a fire risk assessment, and to pass it to your successor. The assessor identity and competence record is the place to build on that. For each assessment and each review, the note filed with the report should hold:

• Name and organisation. The individual who walked the building, and the company that contracted with you, where they differ.
• Qualification. The title, level and awarding body, for example a FireQual Level 4 Certificate in Intermediate Fire Risk Assessment, or an IFE qualification, with the certificate number.
• Certification scheme or register. BAFE SP205 (organisation), a professional register entry (individual), the certificate or membership number, and the date and place you checked it. A screenshot of the register entry on the day is enough.
• Insurance. Confirmation of professional indemnity cover, the insurer and the expiry date.
• Scope. What the assessment covered and excluded, including external walls, areas not accessed and any assumptions, and the BS 8674 level the assessor considered appropriate for the building.
• Dates. The site visit date and the report date, which are often different.

Keep historic notes with the historic assessments. If an assessment from 2024 is ever questioned, the 2024 note is the evidence of what you knew and checked at the time, and this year's note is irrelevant to it. The same discipline applies to the action plan that follows the assessment: close-out evidence should be dated and filed against the assessment that generated it.

If you carried out the assessment yourself, record that fact and the training and experience you relied on. Government guidance on who may carry out a fire risk assessment has not changed, and the consultation asked whether responsible persons should retain the ability to do their own. The response may answer that.

Frequently asked questions

Is my existing fire risk assessment still valid after the progress report?

Yes. The report changes no law. The duty under article 9 to have a suitable and sufficient assessment, reviewed regularly, is unchanged, and so are the record keeping rules that apply to it.

Must my assessor hold a FireQual qualification or BAFE certification today?

No. As of 12 October 2026 no law requires it. BAFE SP205 certificated organisations have until 31 March 2028 to hold the regulated qualifications under the scheme. The government's Q4 2026 response will set out when and how certification becomes mandatory.

What is the difference between article 22A and article 9A?

Article 22A, in force since 1 October 2023, requires you to record the identity of anyone appointed to assist with an assessment and to hand that record on. Article 9A, inserted by section 156(4) of the Building Safety Act 2022, would require you to appoint only a competent person. It had not been commenced as of 12 October 2026.

Does the Q4 2026 response apply in Wales and Scotland?

The consultation applied to England. Wales has its own commencement arrangements for section 156 and Scotland has separate fire safety law. Check the response for its territorial scope when it is published.

How long should I keep the assessor record?

For as long as the assessment it relates to could be relied on or challenged. Our retention guide sets out periods by record type. At minimum, keep it for the life of the assessment plus the period in which enforcement or civil action could follow.