PAS 9980:2026 and the new FRAEW guidance: what it actually changes for assessors

On 14 September 2026, two things landed at once. BSI published PAS 9980:2026, replacing the 2022 code of practice for fire risk appraisals of external walls. The same morning, MHCLG published five guidance documents aimed squarely at the people who commission those appraisals — building owners, landlords, managing agents and residents.

The industry coverage has focused on the first. For most fire risk assessors, the second matters more. Your clients have just been handed an 18-point checklist for judging the quality of the reports they pay for, plus a plain-English guide to what a good executive summary should contain. That changes the conversation you have with them, whether or not you carry out FRAEWs yourself.

What changed in PAS 9980

PAS 9980:2026 replaces PAS 9980:2022. It remains a voluntary code of practice rather than law, and it still applies to existing buildings rather than new build.

For anyone worried about a wholesale rewrite: MHCLG states the updated version provides a clearer and more structured assessment process but does not significantly change how risk is assessed. The principle that recommendations should be proportionate to the risk, rather than defaulting to cladding removal, is unchanged. The risk bands aren't: 2022 had three, and the 2026 edition splits the old medium band in two, giving four — high, medium, tolerable and low. So if you pick up a 2022-basis FRAEW rated medium, check which end of that band the assessor meant before you carry the rating into your FRA.

Existing work is not invalidated. An FRAEW completed by a competent assessor under PAS 9980:2022 stays valid until it needs review or updating. A new appraisal is usually only needed where the external walls have changed, or where a subsequent FRA recommends one.

The standard is largely an evolution, with one addition worth your attention — I'll come to it. The guidance published alongside it is the part that will change your client conversations.

Your clients now have a checklist

"Recognising quality in your FRAEW report" sets out 18 checks for commissioners, grouped into four themes: understanding the assessment, competence and evidence, how risk was assessed, and recommendations and outcomes. It is explicitly written for readers who have never opened PAS 9980.

Each check follows the same pattern — what good looks like, common issues to look for, why it matters. Several of the named issues are uncomfortable reading:

• assumptions presented as facts, and uncertainty not acknowledged
• multiple wall types present but treated as a single wall type throughout
• roof plant included in the height calculation
• no competency statement, and no evidence of independent peer review
• conclusions not clearly linked to the evidence provided
• risk factors listed without explaining how they interact
• generic recommendations such as "replace cladding"
• recommendations copied from standard templates

The companion guide on executive summaries goes further. It tells commissioners to expect your name, qualifications, professional body and registration number, confirmation of professional indemnity insurance, and any declared conflicts of interest — in the summary itself, not buried in an appendix. And it tells them that if something on the list is missing, they should raise it with whoever carried out the appraisal.

If you don't carry out FRAEWs, this still reaches you

The commissioning guide is blunt: a standard fire risk assessor may not have the specialist skills needed for an FRAEW, and PAS 9980 is intended for specialist fire engineers and building professionals. If that isn't your qualification set, nothing here obliges you to acquire it.

The 2026 edition does hand you something new, though. It now covers buildings that don't need an FRAEW as well as those that do, and says that triage is expected to be within the capability of a broad range of building professionals, property managers and fire risk assessors. You're named.

Clause 4 does the work. Blocks of no more than two storeys above ground are deemed inherently low risk, as are blocks of no more than three unless there's an obvious hazard on the external walls, along with a defined list of wall build-ups — solid masonry, A1 or A2 construction with cavity barriers, systems closely matching a BR 135 classification. Where a building clears it, the output is a Clause 14 report: not an FRAEW, but a factual record of how the low-risk conclusion was reached, with a minimum content list and a competence statement from whoever signs it.

That's work you can do without becoming a façade specialist.

The referral decision is the flip side of the same judgement. Where a building doesn't clear Clause 4, the recommendation is yours to make and justify. Whether an appraisal actually gets commissioned is the responsible person's call — they hold the duty, they appoint, they pay, and the entire step-by-step commissioning guide is addressed to them rather than to you. Record your recommendation clearly enough that the distinction is obvious to anyone reading the file in two years.

Worth knowing too: appraisals get triggered by routes that never touch your FRA at all. A First-tier Tribunal remediation order can require a landlord to obtain one. A Cladding Safety Scheme funding application must include an FRAEW from a firm on the CSS panel. Lenders and valuers chasing an EWS1 can push an owner toward an appraisal on their own timetable. Clients will arrive with these already in motion.

A few points to carry into your next residential assessment:

Height is not the trigger. Above the Clause 4 thresholds, an FRAEW may be needed for blocks of flats of any height. It is not limited to medium or high rise. The trigger is what you find — combustible materials identified, wall construction not fully understood, or further investigation needed.

Masonry is not an automatic exemption. Traditional brick or masonry construction is generally unlikely to need a detailed appraisal, but the guidance is specific that the construction must be confirmed as masonry, and not, for example, brick slip over combustible insulation. That is a judgement you need to evidence, not assume.

Your FRA has to carry the reasoning. Under the Fire Safety Act 2021, structure, external walls, cladding, insulation, balconies and windows are already in scope. Where you conclude no specialist appraisal is needed, the basis for that belongs in the report. Where you conclude one is needed, the action plan should say so clearly enough that a managing agent can act on it.

Findings flow back. Where an FRAEW identifies external wall risks, the building's FRA should be updated to reflect them. If you hold the FRA for a building going through an appraisal, that's scheduled work, not a surprise.

There's a commercial read here as well. Your clients are about to receive reports they've been told to scrutinise, mostly without the technical background to do it alone. The assessor who already holds the FRA is the obvious person they turn to.

Why templated language became normal, and why it doesn't have to be

Strip out the technical detail and nearly every one of the 18 checks asks for the same thing: building-specific reasoning, clearly linked to evidence, in language a non-technical reader can follow. Not more words. More particular words — this building, these walls, this evidence.

That has always been hard to do in a time efficient manner. The tools the last generation of software offered to speed up work — dropdown menus, phrase banks, standard actions, pre-written paragraphs — bought speed by trading away specificity. That's why templated language became normal practice. But that's a tradeoff that belongs with the last generation of technology. It's a constraint that no longer holds.

Where FireCheckr fits

FireCheckr helps assessors write detailed, tailored reports in a fraction of the time it took before. We use AI but FireCheckr's AI doesn't write your assessment — it takes your words and observations and puts them in the right places in your report. On site you get three buttons: Type, Talk, Take a photo. Make a note about anything, in any order, and the AI works out which part of the report it belongs in. No typing up of handwritten notes in the evening. No fiddling around with dropdown menus on an iPad.

The impact on report quality is evident. Talking is faster than typing, so assessors provide more detail — and they say it standing in front of the thing they're describing, rather than reconstructing it from memory on a laptop three days later. What reaches the report is your own words, typed up into your own custom template, and ready for validation.

Four things worth doing this month

1. Review how your FRA template handles external walls. If that section produces a generic paragraph rather than a building-specific description and a clear referral decision with reasoning, it won't stand up to the scrutiny the new guidance invites.
2. Check what your reports say about you. Competence statements, professional registration, PI insurance and conflict-of-interest declarations are now things commissioners have been told to look for.
3. Tell your clients this has happened. A short note pointing housing association and managing agent clients at the new guidance costs you nothing and positions you as the person on top of it.
4. Book a demonstration with FireCheckr to see how we can support your fire risk assessments or external wall surveys. We have templates for both, or you can bring your own.

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Sources: Fire risk appraisals of external walls (FRAEWs), MHCLG, 14 September 2026; PAS 9980:2026, BSI. The MHCLG guidance applies to England. PAS 9980:2026 relates to blocks of flats across the UK, though Scotland, Wales and Northern Ireland operate under separate fire safety legislation.