PAS 9980:2026: What the September 2026 Revised Standard Means for External Wall Fire Risk Appraisals

PAS 9980 has undergone its first major revision since its introduction in 2022.

The new edition, PAS 9980:2026, provides a revised methodology for determining whether a Fire Risk Appraisal of External Walls, or FRAEW, is required and, where one is necessary, how the appraisal should be undertaken.

The revision is significant for building owners, Responsible Persons, managing agents, fire risk assessors, fire engineers and other professionals involved in the management of residential buildings.

Importantly, the revised PAS does not simply introduce a new assessment format. It strengthens the risk based and proportionate approach that underpins the FRAEW process.

PAS 9980:2026 supersedes PAS 9980:2022. However, publication of the revised edition does not automatically invalidate FRAEW reports prepared under the 2022 edition. Whether an existing report requires review or updating remains a matter for the dutyholder, taking account of professional advice and the circumstances of the building.

What is PAS 9980?

PAS 9980 provides a methodology for assessing the risk to occupants arising from fire spreading over or within the external walls of an existing building.

The process is known as a Fire Risk Appraisal of External Walls.

The appraisal considers matters including:

• The construction of the external wall

• Cladding and insulation materials

• Cavities and cavity barriers

• The configuration and extent of external wall systems

• Balconies and other attachments

• The potential for secondary fires

• The building's evacuation strategy

• Means of escape

• Compartmentation

• Smoke control

• Fire detection and alarm arrangements

• Fire and rescue service access and intervention

The FRAEW is intended to inform the wider fire risk assessment. It is not a replacement for the building's FRA.

This distinction is important.

PAS 9980 is concerned with risk to life from external wall fire spread. It is not simply an exercise in determining whether the external wall complied with Building Regulations when the building was constructed.

What has changed in PAS 9980:2026?

The 2026 edition is a full revision rather than a minor amendment.

Several changes will have practical consequences for those commissioning and undertaking FRAEWs.

1. Not every building requires an FRAEW

One of the most useful changes is a clearer process for deciding whether an FRAEW is required in the first place.

The revised PAS specifically recognises that an FRAEW is not necessary for every building or every external wall construction.

The standard introduces a clearer triage process.

Certain buildings can be regarded as inherently low risk in relation to external wall fire spread. These include detached houses, terraced and semi detached houses, blocks of flats with no more than two storeys above ground, and certain three storey blocks where there is no obvious external wall hazard.

There are also circumstances where the construction of the external walls themselves can establish sufficiently low risk without progressing to a full FRAEW.

This is an important change in approach.

Commissioning a full FRAEW should not become an automatic administrative response simply because a building has external walls or contains some combustible material.

The first question should now be:

Does this building actually require an FRAEW?

2. Four risk outcomes replace the previous three band approach

PAS 9980:2022 used three broad outcomes:

Low

Medium

High

The revised edition introduces four:

Low

Tolerable

Medium

High

The new tolerable category effectively separates what was previously described as the lower, tolerable part of the medium risk band.

This is more than a change in terminology.

A risk rating and a risk outcome are not the same thing.

The risk rating considers the hazard, probability and consequences associated with external wall fire spread.

The risk outcome then considers that risk in the context of whether further risk reduction is proportionate.

This distinction should help prevent an overly simplistic interpretation that the presence of combustible materials automatically means extensive remediation is required.

3. Proportionality is central to the assessment

PAS 9980:2026 reinforces the principle that external wall fire safety should be assessed according to risk rather than through a binary compliant or non compliant approach.

The FRAEW should consider the benefit of proposed measures alongside their practicability, cost and effect on risk.

That does not mean cost overrides life safety.

It means remediation and mitigation should address the actual risk presented by the building.

The PAS specifically recognises that mitigation, partial remediation or full replacement of an external wall system can represent different proportionate responses depending upon the circumstances.

This is particularly important when combustible materials are identified.

Combustible does not automatically mean dangerous.

Equally, evidence that an individual material achieves a particular reaction to fire classification does not, by itself, establish that the complete external wall arrangement presents an acceptable risk.

The whole system and the building in which it is installed must be considered.

4. The FRAEW process is more clearly structured

The revised standard makes the assessment methodology more explicit.

The process considers three principal groups of risk factors:

• Fire performance

• Façade configuration

• Fire strategy and associated fire hazards

These factors are considered individually and then collectively to determine the overall external wall fire risk.

This is important because external wall risk cannot reliably be determined from the combustibility of one product alone.

For example, an assessor may need to consider how combustible material is positioned within the wall, whether cavities exist, whether cavity barriers are present and effective, how extensively the system covers the building, its relationship with windows and escape routes, and how external fire spread could affect the building's evacuation strategy.

The revised methodology therefore requires the assessor to understand the building as a fire safety system rather than assessing the façade in isolation.

5. The process is explicitly iterative

Another important development is the clearer recognition that an FRAEW may develop as evidence becomes available.

The appraiser can initially work with available information and reasonable worst case assumptions.

If the outcome is clearly low risk despite uncertainty, further intrusive investigation may provide little safety benefit.

Where uncertainty materially affects the risk outcome, further investigation may be justified.

This could include:

• Additional document review

• Further site inspection

• Intrusive investigation

• Additional technical analysis

• Fire testing where proportionate

The purpose is not to investigate until every uncertainty has disappeared.

The purpose is to obtain enough reliable information to make a defensible risk based decision.

PAS 9980:2026 specifically recognises that additional certainty should only be pursued where the benefit justifies the cost and impact.

6. Competence receives greater attention

PAS 9980:2026 reinforces an issue that should concern anyone commissioning this work.

A FRAEW is specialist work.

Different parts of the process may require different competencies.

Document review, façade inspection, fire performance assessment and advanced fire engineering analysis do not necessarily require the same professional skill set.

The standard therefore recognises that additional specialists may need to contribute where the external wall construction or analysis exceeds the competence of the principal appraiser.

This also means that appointing someone simply because they undertake general fire risk assessments is not sufficient evidence that they are competent to undertake an FRAEW.

Competence must relate to the work actually being undertaken.

7. Peer review has a clearer role

The revised edition introduces more detailed guidance on reviewing FRAEW reports.

This is significant because an FRAEW can contain substantial professional judgement.

Peer review can therefore provide additional assurance where the building, wall construction or analysis is complex.

However, the revised approach remains proportionate.

A straightforward assessment producing an obvious outcome does not necessarily require the same level of independent review as a complex appraisal where professional judgement materially influences whether remediation is required.

8. FRAEW reports need to explain the reasoning

The revised reporting provisions are more detailed.

This should improve the quality of FRAEW reports.

A report should not simply state:

"Medium risk"

or

"Remediation required."

The reader needs to understand how that conclusion was reached.

PAS 9980:2026 requires the report to explain the risk outcome, the relative significance of the risk factors and the professional judgements used in reaching the conclusion.

Where uncertainty contributes to a medium or high outcome, the report should also explain why further appraisal work was not possible or proportionate.

This creates a stronger audit trail.

It should also make it easier for Responsible Persons, fire risk assessors, enforcing authorities and other professionals to understand and challenge the conclusions where necessary.

9. Residents should be able to understand the outcome

Technical reports can become inaccessible to the people most affected by their conclusions.

PAS 9980:2026 addresses this directly.

FRAEW reports should include an executive summary that can be readily understood by non specialists, including residents.

That summary should explain the building, wall systems, overall risk outcome, how that outcome was reached and any recommended mitigation or remediation.

This is a positive development.

A technically correct assessment has limited value if the dutyholder and residents cannot understand what the findings mean.

10. Existing PAS 9980:2022 reports do not automatically become obsolete

This is likely to be one of the first questions asked by building owners and managing agents.

Does every existing PAS 9980:2022 FRAEW now need to be replaced?

No.

The revised PAS expressly states that its publication does not, by itself, invalidate reports prepared under PAS 9980:2022.

The dutyholder should instead consider whether review is appropriate.

Relevant factors could include changes to the external wall, new evidence about materials or systems, changes affecting the building's fire strategy, significant uncertainty in the original assessment or other circumstances that could materially affect the original conclusions.

Automatically recommissioning every FRAEW purely because the standard has changed would conflict with the risk based and proportionate philosophy of PAS 9980 itself.

What does PAS 9980:2026 mean for the Fire Risk Assessment?

An FRAEW should not sit in a building safety file disconnected from the FRA.

Its purpose is to inform the fire risk assessment.

Where the FRAEW identifies significant external wall risks, those findings need to feed into the assessment of the building's overall fire precautions, evacuation strategy and action plan.

Conversely, the FRAEW may need to consider information obtained through the FRA, including compartmentation, means of escape, smoke control, fire detection, suppression and the evacuation strategy.

The two assessments therefore need to work together.

For Responsible Persons and building managers, this means that commissioning an FRAEW is not the end of the process.

The question should be:

What does the FRAEW tell us about the overall fire risk in this building, and what action is proportionate?

A move away from binary thinking

Perhaps the most important message from PAS 9980:2026 is that external wall fire safety cannot be reduced to a simple combustible versus non combustible test.

The methodology requires consideration of the building as a whole.

Material performance matters.

So does the extent and configuration of the façade.

So do cavity barriers.

So do windows and openings.

So do balconies.

So does compartmentation.

So does the evacuation strategy.

So do the characteristics of occupants.

So does the ability of the fire and rescue service to intervene.

The result is necessarily dependent upon competent professional judgement.

That judgement must, however, be evidence based, transparent and proportionate.

How London Fire Consultants can assist

London Fire Consultants can support Responsible Persons, freeholders, managing agents and other dutyholders in understanding how external wall fire risk interacts with the wider fire risk assessment and fire strategy.

Where an external wall issue is identified during a life safety fire risk assessment, the correct response should not automatically be to demand remediation or commission unnecessary specialist work.

The first stage is to establish the nature of the concern, determine whether specialist appraisal is required and ensure that any FRAEW is properly integrated into the wider assessment of fire risk.

For advice concerning external wall fire risk, Fire Risk Assessments, existing FRAEW reports or the implications of PAS 9980:2026 for your building, contact London Fire Consultants.

Reference

British Standards Institution (2026) PAS 9980:2026 Fire risk appraisal of external wall construction and cladding of existing blocks of flats: Code of practice. London: BSI.