Healthcare Fire Safety Guidance Updated with Key Changes and Compliance Implications

On the 11^th Feb 2026, NHS England released the updated Health Technical Memorandum (HTM) 05-01: Managing Healthcare Fire Safety which reflects legislative changes, regulatory expectations, and best practice in fire risk management for healthcare facilities and estates.

The updated guidance reinforces and reflects the broader building safety regulatory reform introduced under the Building Safety Act 2022, requiring the need for robust safety governance, documented assurance via the Golden Thread, and proactive risk management across higher risk buildings.

In this blog we highlight some of the key changes as well as what the implications are for healthcare estate teams.

Clarification of Competency Roles and Fire Governance Structure

A significant update within the revised HTM 05-01 is the formal clarification and strengthening of competency expectations within fire safety governance structures. The guidance now defines four distinct designations under the Authorised Person (Fire) role, reflecting the need for specialist expertise across key areas of healthcare fire safety management. These specialisms include fire risk assessment, fire training, and fire project oversight, ensuring that responsibilities are clearly aligned to demonstrable competence.

In addition, the guidance introduces the role of Senior Fire Safety Adviser. This position is expected to be held by an individual with extensive knowledge and experience in healthcare fire safety. The Senior Fire Safety Adviser will typically coordinate and oversee a team of fire safety advisers, providing strategic leadership, assurance, and technical oversight across the organisation.

This formalisation of roles reinforces the broader regulatory direction towards clearly defined competency assurance and structured governance. Healthcare organisations will need to review existing fire safety structures to ensure that responsibilities, qualifications, and reporting lines align with the updated expectations.

Stronger Emphasis on Fire Safety Management Systems

Rather than relying on checklist driven approaches, the guidance encourages structured policies and reporting mechanisms that embed clear governance and accountability across all levels. The update places a clear focus on establishing robust fire safety management systems tailored to the complexity and risk profile of each healthcare organisation specifically.

For healthcare organisations, this means that fire safety management must be proactive, systematic and demonstrable. Clear roles and responsibilities, documented assurance, and evidence of performance monitoring are core compliance expectations.

Proportionate Risk Assessment and Planning

The updated HTM guidance emphasises proportionate fire risk assessment and planning based on facility and estate complexity, clinical operations, and patient dependency. Estates with high patient dependency must demonstrate comprehensive systems and controls, while smaller or less complex facilities may adopt appropriately scaled approaches.

Fire safety policies are expected to be living documents, reviewed and updated to reflect legislative change, organisational restructuring, or operational risk changes. Maintaining detailed documentation and records remains essential not only for fire safety compliance but also for satisfying requirements under the Building Safety Act 2022, which mandates accountable persons to hold robust safety cases and verifiable evidence of effective risk management.

Integration with National Standards and Regulation 

HTM 05-01 is intended to be applied alongside other components of the Firecode suite (HTM 05-02 & HTM 05-03), statutory obligations under the Regulatory Reform (Fire Safety) Order, and regulatory expectations set out in the Building Safety Act 2022.

Taken together, this promotes an integrated approach to fire safety and risk management. Demonstrating the effectiveness of systems has become a key measure of compliance. Decisions should be supported by risk assessments, operational evidence, and clear governance records.

Implications for Healthcare Estates

The updated HTM guidance and the broader regulatory context, signal a fundamental shift from simply striving for compliance to the active management and assurance of risk. Fire safety is now positioned as a core organisational function requiring governance oversight and documented accountability.

Healthcare organisations must therefore demonstrate that fire risk assessments are proportionate, action plans are current and documented, and controls are effectively implemented and reviewed. Estates and facilities teams are expected to integrate fire safety management into broader governance frameworks, ensuring that evidence of compliance and ongoing monitoring is readily accessible and auditable.

How Ventro Can Help

For organisations seeking to enhance their fire safety management frameworks in line with the revised HTM guidance and broader regulatory change, Ventro offers tailored solutions and practical expertise to help achieve compliance. Speak with one of our expert team today.