PAS 9980 and the FRAEW: External Wall Fire Appraisals

A Fire Risk Appraisal of External Walls answers one narrow question: how readily could fire spread over or within the external walls of your building, and what would that mean for the people living in it. PAS 9980:2022, published by BSI on 31 January 2022, sets out how a competent professional answers it. It is a published British Standards document that has to be bought from BSI, so this article describes its approach and takes the detail from free government guidance, rather than quoting the standard.

What a FRAEW Is, and What It Is Not

BSI describes the standard as a methodology for appraising the risk to occupants from a fire spreading over or within the external walls of an existing block of flats. Government guidance puts the same point more bluntly: an appraisal to the PAS 9980 methodology is used to identify what, if any, works are required to address the life safety fire risks associated with cladding and external wall systems.

Two limits follow. The appraisal is about life safety, not property, which is how the funding guidance frames it throughout. And it is for buildings that already exist, BSI giving the scope as existing multistorey, multi-occupied residential buildings.

The approach matters more than the document. On 10 January 2022 the government withdrew its Consolidated Advice Note, saying it had been used to justify an excessively risk averse approach. Its guidance for regulators says the PAS 9980 code of practice was introduced to make sure a proportionate and risk based approach to building safety is adopted. The appraisal categorises risk. It does not certify safety.

An FRAEW also appraises the walls, not the building. Its findings feed into the fire risk assessment for the whole building, which still governs fire safety management. It is separate again from the valuation form a lender may ask for.

When a Building Actually Needs One

For most blocks, it does not. The government’s guidance for applicants says it should be obvious to a competent fire risk assessor that the risk of fire spread, particularly in buildings with brick or masonry walls, is sufficiently low that an FRAEW is not required. The appraisal is for walls whose build-up has not been shown to resist fire spread adequately.

Height is not the trigger either. Government funding schemes ask for appraisals carried out to PAS 9980:2022 on buildings above 18 metres, on buildings between 11 and 18 metres, and now on buildings under 11 metres. What decides it is the wall build-up, not the storey count.

In practice an appraisal gets commissioned for one of four reasons:

The fire risk assessor has raised a concern, or made a generic recommendation because the build-up is unknown.
An investigation found combustible material and whoever found it cannot advise on what it means for occupants.
The building is applying for government remediation funding, which requires one.
A lender, insurer or buyer has asked something the documents cannot answer.

The first question is whether an appraisal is needed at all, which is why your fire risk assessor’s view on the external walls is the right starting point rather than an immediate instruction to a facade specialist. For lower blocks that sits alongside the question of what the Building Safety Act requires below 11 metres.

How the Appraisal Is Carried Out

Government guidance describes PAS 9980:2022 as setting out steps to identify and assess risk factors, as well as mitigation steps that might improve the risk rating of a building, through a holistic and fact based assessment of the building’s construction. In outline that means:

Confirming that the external walls are within the scope of an appraisal at all.
Gathering information on the wall build-ups and what is attached to them, including balconies, cavity barriers or their absence, and the extent of any cladding.
Identifying the risk factors relevant to external fire spread on that particular building.
Weighing how those factors, positive and negative, bear on the risk.
Placing the building on the risk scale, and identifying any mitigation that would improve the rating.

The assessment is holistic rather than a materials checklist. It weighs the fire performance of the materials in the external walls, the configuration of the facade, including where combustible material sits, and the building’s current fire strategy. Whether the block runs a stay put strategy therefore bears on the outcome.

There is no standard report template. What a report has to contain is set out in the government’s technical guidance for funding applicants: the building’s name, address and postcode, a competence statement for the assessor, evidence of the building’s height, document control information, an explanation of the scope of the appraisal, and conclusions and recommendations with any proposed remediation or mitigation.

Low, Medium and High: What the Outcome Means

The rating has three points. Government funding guidance uses the same vocabulary, sorting buildings into high risk and medium, action required, and defining unsafe cladding as an external wall system where a risk to life from fire spread has been identified through a PAS 9980:2022 compliant assessment and that risk is not tolerable without mitigation or remediation. Most buildings sit between the extremes, on a graded scale.

FRAEW risk outcomes and what usually follows
Outcome	What it means	What should follow
Low	External spread is judged to be within normal expectations for that kind of building.	No remediation of the external walls is indicated. The finding is recorded and informs the fire risk assessment.
Medium, risk tolerable	Spread may be faster than normally expected, but the assessor concludes the heightened risk is tolerable.	No works. The position is kept under review through the fire risk assessment, which has to be reviewed regularly in any event.
Medium, action required	The risk is not tolerable as things stand.	Mitigation or remediation. Under the government schemes these buildings are funded after the high risk ones.
High	The risk to life from external fire spread is clearly not tolerable without action.	Action is necessary, but not necessarily removal of the cladding. These buildings are prioritised for funding.

Two points directors regularly misread. A medium rating is not automatically a failure, and a high rating does not automatically mean recladding. The Building Safety Fund guidance treats removal and replacement of cladding, in whole or in part, and mitigations such as sprinkler systems or smoke alarms as eligible alternatives. The guidance for regulators goes further and accepts that an appraisal may conclude the fire risk is sufficiently mitigated by an alarm or sprinkler system already in the building, so that no further works are advised.

Where works are needed, the interim arrangements matter as much as the works. Government guidance treats a waking watch as a temporary solution that should be in place for the shortest period possible, which is when the cost of a waking watch and its alternatives becomes live. One practical warning: the technical guidance says funding decisions are not made on FRAEWs which state that further investigation is needed, so an inconclusive appraisal can cost a building a funding round.

Who Is Competent to Carry One Out

Competence is judged on evidence, not on job title. The government’s guidance for applicants requires the external wall assessor to demonstrate evidence of competence in assessing the life safety fire risks posed by external wall construction and cladding, including experience of conducting investigations into external wall fire safety. Its technical guidance asks the assessor to confirm that they have adequate and relevant competence to undertake the FRAEW, and sufficient knowledge, skills and experience in relation to the fire safety of external walls. In short:

Evidence of competence shown to you, including experience of investigating external wall fire safety.
Sufficient knowledge, skills and experience in the fire safety of external walls for the appraisal actually in hand.
A competence statement in the report itself, which the funding guidance requires.

Funding schemes go further. The building safety funding technical guidance requires professional indemnity insurance of at least £1 million with no exclusions relating to fire safety and cladding, and every FRAEW submitted to the Cladding Safety Scheme since 1 November 2023 must have been completed by a firm on the scheme’s assessor panel.

Where the Legal Duties Sit

PAS 9980 is a voluntary code. The legal duty is the fire risk assessment. Section 1 of the Fire Safety Act 2021, in force in England from 16 May 2022, amended article 6 of the Fire Safety Order so that in a building with two or more sets of domestic premises the Order applies to the structure, the external walls, any common parts, and all doors between the domestic premises and the common parts. External walls include their doors and windows and anything attached to the exterior, including balconies.

Article 9 requires the responsible person to make a suitable and sufficient assessment of the risks to relevant persons, review it regularly, and, following amendment by the Building Safety Act 2022 with effect from 1 October 2023, record it. An FRAEW helps make the external wall element suitable and sufficient. It is evidence, not compliance in itself.

Taller blocks carry a separate duty. Regulation 5 of the Fire Safety (England) Regulations 2022 requires the responsible person for a high-rise residential building to record the design of the external walls, the materials used, the risk level identified by the fire risk assessment and any mitigating steps. Regulation 3 defines high-rise as at least 18 metres above ground level, or at least seven storeys.

This is likely to change. In its Remediation Acceleration Plan update of July 2025 the government said that, when parliamentary time allows, it will legally require FRAEWs to follow the PAS 9980 framework, be conducted by assessors meeting specified requirements, and be subject to approved audits. It also said PAS 9980 was under review, with updated guidance expected in early 2026. As at August 2026 BSI still lists the 2022 edition as current.

Who Pays, and What Funding Is Open

Under the Cladding Safety Scheme the applicant arranges and pays for the appraisal up front. If the building is then found eligible, reasonable FRAEW costs are reimbursed through the grant; if not, nothing is paid. Responsible entities able to apply include a management company, an RTM company with the primary repairing obligation, a freeholder and a section 24 manager.

Shorter buildings have had a dedicated funding round. Funding for multi-occupied residential buildings under 11 metres in England had an application window from 17 August to 9 October 2026; check GOV.UK for any later round. Buildings where works started before 9 July 2026 are not eligible, and no application can be submitted without a FRAEW to PAS 9980:2022, normally arranged by the responsible entity.

On service charges, Schedule 8 to the Building Safety Act 2022 protects qualifying leases, but only in a relevant building, which section 117 defines as a self-contained building in England with at least two dwellings that is at least 11 metres high or has at least five storeys. Paragraph 8 provides that no service charge is payable under a qualifying lease for cladding remediation, meaning removal or replacement of any part of a cladding system that forms the outer wall of an external wall system and is unsafe. Paragraph 9 blocks recovery for professional services relating to liability for relevant defects. Whether the FRAEW fee falls inside paragraph 9 is not settled. If works follow, the section 20 consultation rules apply.

If your board is unsure whether the block needs an appraisal, the cheapest first move is to ask your fire risk assessor to state in writing, with reasons, whether the external walls warrant one under PAS 9980. That paragraph often closes the question. Where it does not, Plymouth Block Management offers independent building safety consultancy for buildings under 11 metres.

Common Questions

The queries boards raise most often.

Does Every Block of Flats Need a PAS 9980 Assessment?

No. Government guidance for applicants says it should be obvious to a competent fire risk assessor that the risk of fire spread, particularly in buildings with brick or masonry walls, is sufficiently low that an FRAEW is not required. The appraisal is aimed at walls whose build-up has not been shown to resist fire spread adequately.

Is a FRAEW the Same as an EWS1 Form?

No. The EWS1 form is a valuation tool, created to give lenders and buyers assurance about future remediation costs, not a life safety certificate. An FRAEW is a fire risk appraisal carried out for the responsible person, and its outcome is intended to inform the building’s fire risk assessment. One may support the other, but they answer different questions.

How Long Is a FRAEW Valid For?

There is no expiry date. The duty that keeps running is article 9 of the Fire Safety Order, which requires the fire risk assessment to be reviewed regularly and kept up to date. Where the appraisal found a heightened but tolerable risk, or where the walls or their attachments change, that review is the point at which the appraisal should be revisited.

Does a Medium Risk Rating Mean the Building Is Unsafe?

Not by itself. Medium sits between the low and high bands. If the assessor concludes the heightened risk is tolerable, the outcome is periodic review rather than works. If it is not tolerable, the government schemes treat the building as medium, action required, and funding is considered after the high risk buildings.

Who Can Carry Out a FRAEW?

A competent professional. Government guidance asks the assessor to demonstrate evidence of competence in external wall fire safety, including experience of investigating it, and to confirm that they have adequate and relevant competence for the appraisal in question. For the Cladding Safety Scheme the assessor must also be on the scheme’s panel.

Can the Cost of the FRAEW Be Charged to Leaseholders?

That depends on the lease and on Schedule 8 to the Building Safety Act 2022, which applies only to a relevant building, one at least 11 metres high or with at least five storeys. Paragraph 8 rules out service charges under a qualifying lease for cladding remediation, and paragraph 9 rules out charges for professional services relating to liability for relevant defects. Whether an FRAEW falls within paragraph 9 is not settled.

Sources

Everything above is taken from these, not from a summary of them:

PAS 9980:2022 Fire risk appraisal of external wall construction and cladding of existing blocks of flats. Code of practice BSI
Building Safety Fund guidance for new applications 2022 MHCLG / GOV.UK
Annex A: Technical guidance for applicants of building safety funding applying for funding via PAS 9980:2022 GOV.UK
Annex D: Guidance for applicants for fire risk appraisal of external walls GOV.UK
Remediation enforcement: guidance for regulators, principles for remediation enforcement MHCLG / GOV.UK
Remediation enforcement: guidance for regulators, Annex B funding remediation MHCLG / GOV.UK
Applying for funding for the Cladding Safety Scheme GOV.UK / Homes England
Cladding Safety Scheme overview GOV.UK / Homes England
Buildings under 11 metres: fund overview GOV.UK
Buildings under 11 metres: leaseholders’ and residents’ guide GOV.UK
EWS1 best practice guidance Greater London Authority
[Withdrawn] Building safety advice for building owners, including fire doors MHCLG / GOV.UK
Remediation Acceleration Plan update, July 2025 MHCLG / GOV.UK
Fire Safety Act 2021, section 1 legislation.gov.uk
Fire Safety Act 2021 factsheet: commencement of sections 1 and 3 Home Office / GOV.UK
Regulatory Reform (Fire Safety) Order 2005, article 9 legislation.gov.uk
Fire Safety (England) Regulations 2022, regulation 5 legislation.gov.uk
Fire Safety (England) Regulations 2022, regulation 3 legislation.gov.uk
Building Safety Act 2022, section 117 legislation.gov.uk
Building Safety Act 2022, Schedule 8 legislation.gov.uk
Fire Safety Act 2021, section 1 (commencement information) legislation.gov.uk
Buildings under 11 metres: new funding MHCLG / GOV.UK

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