How Many Legal Duties Does a Block of Flats Carry? We Counted

TL;DR: By our count, a converted house with three or four flats, run by a residents' management company (RMC) with no staff, carries 40 legal duties in force today, and a higher-risk building with every common trigger present carries 151. Two in three of the larger building's duties did not exist in June 2017, and directors can be personally liable when the company commits a fire or building safety offence through their neglect. The useful questions for a director are which duties apply to your building, which come with fixed dates, and which familiar "duties" are guidance or not yet law.

Check if your building qualifies as higher-risk →

This is a count of the legal duties on the people who own or manage an existing block of flats in England: the responsible person under the fire safety law, the accountable persons under the Building Safety Act 2022, the landlord for service charge purposes, and the client when works happen. We read more than 30 Acts and statutory instruments on legislation.gov.uk and counted one duty per statutory provision. No lawyer or consultant has reviewed the count yet. The method, and the judgement calls that move the numbers, are at the end.

#The smallest block still carries 40 legal duties

A converted Victorian house with three flats and a shared hall carries 40 legal duties that are in force, by our count. Picture an RMC owned by the three leaseholders, two volunteer directors, no employees, no lift, under 11 metres, and no works in progress. It still has a full set of obligations because the law attaches duties to the common parts, and the common parts exist.

Where a building contains two or more sets of domestic premises, the things to which this order applies include— (a) the building's structure and external walls and any common parts; (b) all doors between the domestic premises and common parts.

(Regulatory Reform (Fire Safety) Order 2005, art 6(1A))

Here is where the 40 come from:

Two of those lines rest on assumptions you should check against your own building. The health and safety duties bind your RMC only if someone works in the common parts, such as a cleaner or a contractor, and on our reading that running a block is an "undertaking", which s.4(4) says covers undertakings "whether for profit or not". In Westminster City Council v Select Managements Ltd (Court of Appeal, February 1985), the hall, landings, staircases and lifts of a block of flats were held to be premises made available to lift engineers and electricians as a place of work, so s.4 applied to the company that managed them. That company was a commercial managing agent; we have not found a decision on a residents' company. The fire safety count assumes your RMC is the responsible person, which is usually true for the common parts but depends on who has control.

#What moves a block up the range

Height, evacuation strategy, staff, a lift, building works, who owns the freehold and the number of accountable persons each change the count from the small block's 40. Each figure below is measured against that small converted block, so the figures overlap and do not add up.

Try the combinations for your own building. Every figure in the calculator comes from the same count as the tables.

The 18-metre line is the largest single jump: 73 duties in force over the small block, and 42 more than an 11-metre block with simultaneous evacuation. The PAP responsibilities guide covers who holds those duties when there is more than one accountable person.

The 11-metre line moved on 6 April 2026. Since then, a 12-metre block whose fire strategy says everyone leaves at once carries the same evacuation-plan duties as a tower. Our post on what reasonable steps means for residential PEEPs covers how those duties work in practice.

#The top of the range: 151 duties on one building

With every common trigger present, a building carries 151 duties in force by our count. Enforcement notices and orders on top of that could take it to 158, but we left those out because they follow a breach. The building:

• is over 18 metres, so it is a higher-risk building
• has more than one accountable person, with a tripartite RMC holding the repairing obligations as Principal Accountable Person and a separate freeholder
• has a lift, communal water and gas plant, and asbestos present or presumed
• uses a simultaneous evacuation strategy
• has remediation works underway
• employs a concierge
• is under a special measures order made by the Building Safety Regulator

We dropped one fact the profile could have had: a compliance notice. Compliance notices lapse once a special measures order is made (BSA 2022 Sch 7), so a building cannot carry both.

Personal liability sits behind the count. Where a company commits an offence under Part 2 or Part 4 of the Building Safety Act with a director's consent or connivance, or through their neglect, that director is personally guilty too (BSA 2022 s.161). The Fire Safety Order has the same rule, and where members manage the company, members count as directors (art 32(8)-(9)).

Any person guilty of an offence under paragraph (1)(a) to (d) and (2)(h) is liable— (a) on summary conviction to a fine not exceeding the statutory maximum; or (b) on conviction on indictment, to a fine, or to imprisonment for a term not exceeding two years, or to both.

(Regulatory Reform (Fire Safety) Order 2005, art 32(3))

Paragraph (1) includes breaches of the main fire safety duties, including the Fire Safety (England) Regulations, where the breach puts someone at risk of death or serious injury.

That applies at the bottom of the range as well as the top. The volunteer directors of the three-flat RMC are within the same article. Section 161 has one carve-out for unpaid directors, which applies only when some of the board are paid for a building safety purpose; our post on building safety directors explains it.

See every dated duty in the compliance calendar →

#Who holds these duties

The law gives each duty to a role, and the lease and management arrangements decide who fills that role in your building. We have not published a count of duties per role, because matching each duty to a person is the part of our inventory that most needs expert review. The roles themselves are set out in statute:

• Responsible person (fire safety). Where the premises are a workplace, it is the employer with control of them. Otherwise, for the common parts of a block, it is the person who controls the premises in connection with an undertaking, or failing that the owner (Fire Safety Order art 3). Anyone else with control, or a contractual obligation to maintain or repair the premises, carries the same duties for the matters within their control (art 5(3)-(4)). In practice that can be the RMC or RTM company, the freeholder and the managing agent at once, each for its own part.
• Accountable person and Principal Accountable Person (higher-risk buildings only). An accountable person holds a legal estate in the common parts or is under a repairing obligation for them (BSA 2022 s.72). The Principal Accountable Person is the one responsible for the structure and exterior (s.73). Our PAP responsibilities guide covers how that plays out with RTM companies and tripartite leases.
• Landlord (service charges). For the service charge rules, "landlord" includes anyone with a right to enforce payment of a service charge (LTA 1985 s.30), so an RMC that collects the service charge carries those duties.
• Client (building works). Whoever a construction project is carried out for is the client under CDM 2015, and has its own duties from planning the work to keeping the health and safety file.
• Employer. Employer-only regimes, such as the Electricity at Work Regulations and COSHH, apply to the company only if it employs someone. If it does not, they bind the managing agent and contractors for their own staff instead.

A managing agent can carry out the work behind these duties without taking the duties over.

APs and the PAP cannot delegate their legal obligations to others. APs and the PAP can employ an organisation or individual, like a managing agent, to carry out duties on their behalf.

(BSR guidance, Safety in high-rise residential buildings: accountable persons)

#How this compares

Two in three of the maximum building's duties did not exist on 13 June 2017, the day before the Grenfell Tower fire. Applying today's building facts to the statute book as it stood that day gives 50 duties in force for the maximum building and 28 for the small converted block, by our count.

The maximum building had 50 duties in force by 2015 and gained none for the next seven years. Then 101 arrived in under four years, from June 2022 to April 2026. Most came in four steps: 23 on 23 January 2023 (the Fire Safety (England) Regulations), 26 on 1 October 2023 (mostly the Building Safety Act's changes to the Fire Safety Order and the new building control regime for higher-risk buildings), 15 on 16 January 2024 (the main accountable person duties) and 14 on 6 April 2026 (the Residential Evacuation Plans Regulations).

We also checked the other direction: duties that bound these buildings in 2017 and have since gone. Comparing each instrument as it stood on 13 June 2017 with today's text, six provisions have been repealed. None was an owner's duty for either building: four are local authority and building control procedure, and two made an RTM company pay the landlord's costs of a right-to-manage claim, which the Leasehold and Freehold Reform Act 2024 removed in March 2025. The old Fire Safety Order recording duties that have been replaced applied only where there were five or more employees, a licence or an alterations notice, so they never bound either building.

For the small block, the 12 additions are seven Fire Safety Order duties added or rewritten by BSA 2022 s.156 from 1 October 2023 (recording every FRA finding, recording the fire safety arrangements, giving residents fire safety information and keeping records of it, finding out whether there are other responsible persons, and keeping and handing over records when the responsible person changes) and five from the Fire Safety (England) Regulations 2022. For the maximum building, the largest sources of new duties are the Building Safety Act itself (28), the Fire Safety (England) Regulations 2022 (23), the Residential Evacuation Plans Regulations 2025 (14) and the building control procedures for higher-risk buildings in SI 2023/909 (10).

#What the duties mean in dated tasks

Only 2 of the small block's 40 duties, and 11 of the maximum building's 151, come with an interval set by law (two of those 11 are the records of a check, which we count with the check itself). The rest are standing obligations, such as keeping escape routes clear, or start with an event, such as a new resident moving in. Counting only the checks where the law states the interval:

• The small block has 2 dated tasks a year: giving every resident the fire safety instructions (FSR 2022 reg 9(3)(b)) and the fire door information (reg 10(3)(b)).
• The maximum building has 21.5 a year: 12 monthly checks of firefighting lifts and equipment (reg 7), 4 communal fire door checks (reg 10(6)), the annual flat entrance door round (reg 10(4)), the secure information box inspection (reg 4(5)), the two annual resident information rounds, the yearly review of the building emergency evacuation plan (REP 2025 reg 13), and a review of the resident engagement strategy every two years (SI 2023/907 reg 10).
• On top of that, each resident who needs help to evacuate adds a yearly review of their person-centred fire risk assessment (REP 2025 reg 9), and a passenger lift adds two thorough examinations a year if LOLER applies.

None of those fixed-interval tasks existed on 13 June 2017. A further 3 recurring duties for the small block, and 10 for the maximum building, recur with no interval in law: the text says "regularly", "at regular intervals", "periodically" or "where necessary", or describes a system of maintenance without a frequency. They include the fire risk assessment review and the Building Safety Act s.83 risk assessment. Someone has to choose those intervals and write the choice down.

The 21.5 counts each round once. The annual flat entrance door round on a 60-flat block is one task in this count and 60 doors on the day.

#The company duties underneath

Every RMC and RTM company also carries company law duties, whatever building it runs. By our count that is 23 duties in force for an RMC and 25 for an RTM company, which also has two notice and reporting duties to the landlord under the Commonhold and Leasehold Reform Act 2002. Three of them have fixed annual dates: preparing the accounts (Companies Act 2006 s.394), filing them within nine months of the year end (s.441), and the confirmation statement (s.853A). These sit underneath the 40 and the 151 and are not added to them.

The register rules changed on 18 November 2025. Companies no longer keep their own registers of directors or of people with significant control. Changes go to Companies House within 14 days instead (s.167G), and a director must not act until their identity is verified (s.167M).

#Against a shop and an office block

The clearest comparison with other premises is the number of checks where the law fixes the interval. We counted a small shop with three staff and an 18-metre office block let to several tenants, using the same rule.

Four of the office block's 5.2 are the six-monthly thorough examination of each passenger lift. LOLER applies there without argument, because the lifts carry people at work, and the regulations allow an examination scheme to replace the six-month interval. The rest come from its air conditioning: an annual F-gas leak check and an energy inspection every five years. None of the shop's duties has an interval fixed by law; nine recur "regularly" with no number.

The office block is as tall as the residential tower and carries none of its Building Safety Act Part 4 duties. A higher-risk building has to be at least 18 metres or 7 storeys and contain "at least 2 residential units" (BSA 2022 s.65). The Fire Safety (England) Regulations 2022 and the leaseholder protections in Part 5 also depend on the building having homes in it.

We have not put the shop's and the office's total duty counts next to the 40 and the 151. Our inventory for those premises lists workplace regulations article by article, while the residential inventory groups them, so the totals are not counted on the same basis.

#Duty-like, but not law

Ten items in the maximum building look like duties and are not settled law. They mislead in two directions: guidance gets treated as law, and law that has not started gets treated as live.

Passed but not in force, or in force with nothing to operate (as at 15 October 2026). Each of these is on legislation.gov.uk, and we found no commencement order bringing it into force for England. That rests on searching every commencement order we could find, which cannot prove a negative, so check before relying on it.

• Competent fire risk assessors. BSA s.156(4) inserts article 9A into the Fire Safety Order, requiring the responsible person to appoint only a competent assessor. Subsection (4) was left out when the rest of s.156 commenced. Competence currently attaches through article 18 and through guidance.
• Building safety information on demands. BSA s.113 would add sections 47A and 49A to the Landlord and Tenant Act 1987, so that service charges in a higher-risk building would not be due until the landlord gives prescribed safety information. It is in force only for making regulations.
• Implied lease covenants. BSA s.112 inserts LTA 1985 s.30C, which would write building safety covenants into leases in higher-risk buildings. Section 30C has not commenced.
• Cost recovery for remediation. LTA 1985 s.20D, inserted by BSA s.133, would require landlords to seek grants and third-party money before charging remediation costs. It is in force only for making regulations, and we found none.
• Building safety directors. BSA s.111 is in force but depends on prescribed provisions for RMC articles. We found no regulations, so nothing in it operates yet.

Contested. Whether LOLER applies to a residential passenger lift is unsettled. The regulations cover lifting equipment "for use at work (whether exclusively or not)", and contractors and postal workers use lifts at work. HSE's LOLER overview says "LOLER only applies to lifting equipment which is used at work", and that passenger lifts primarily intended for use by people not at work "will generally need to be to the same stringent standards as required by LOLER and PUWER". The six-monthly examination therefore carries over in practice whichever reading is right.

Guidance cadences. Several intervals common on block maintenance calendars come from guidance rather than statute:

Guidance still matters. Under article 50(1A) of the Fire Safety Order, following or ignoring official guidance can be used in proceedings as evidence of compliance or breach. The practical difference is in how you record it: "we review the FRA annually because the assessor recommends it" is a decision you can change with reasons, while "the law requires annual review" is a claim a consultant or tribunal can test.

Some fixed intervals are law. Communal fire doors in a block over 11 metres must be checked at least every 3 months (FSR 2022 reg 10(6)), and firefighting equipment in a higher-risk building every month (reg 7). Our post on fire safety enforcement data shows which Fire Safety Order articles appear most often on enforcement notices.

#What to do with this

If you are a director of an RMC or RTM company, these five steps turn the count into a working list:

1. Work out which facts apply. Height, evacuation strategy, staff, lift, works and who owns the freehold decide most of the count. The calculator above shows the effect of each, and the building checker confirms whether you are in the higher-risk regime.
2. Get the list, not just the number. For each duty, you want a yes or no for "are we meeting this", with the provision it comes from. A spreadsheet works. So does the CSV offered below.
3. Put the dated checks in a calendar. Two a year for a small block, 7 or 8 for a block between 11 and 18 metres, and 21.5 for a higher-risk building. The compliance calendar lists the fixed dates that apply across the sector.
4. Write down an interval for every "regularly". The law gives no interval for reviewing the fire risk assessment, or for the s.83 risk assessment in a higher-risk building. Record the interval you chose and the reason, such as your assessor's recommendation.
5. Agree in writing who does what. Your managing agent, assessor and contractors can carry out the work. The duty stays with the company, and directors remain exposed to personal liability if an offence follows from their neglect.

#How we counted

The counts come from a primary-source inventory of more than 30 Acts and statutory instruments on legislation.gov.uk, read on 15 October 2026. Every row carries the provision link it was read from, or is marked where the text could not be confirmed. Nothing in the inventory has been reviewed by a lawyer or a building safety consultant, so treat every figure here as our count and check the linked provision before relying on any single row. Counts current as of 16 October 2026. Every citation in this post was checked against the current text on legislation.gov.uk on 16 October 2026, in two separate passes, and the counts are generated by a script that asserts the published totals.

The rules that shape the numbers:

• One duty per provision. A duty is one statutory provision that requires someone to do something. Definitions, rights, and provisions that only set a penalty or a defence are not counted.
• England only, existing buildings. New-build duties, Wales and Scotland are out of scope.
• The Building Safety Act's core duties count as 20: 16 sections of Part 4 and 4 key building information regulations, with the regulations that prescribe their detail folded in. Counting each regulation separately would add 22 duties to the maximum building.
• Liability rows are excluded. Including s.161 and article 32 would add 4 to the small block and 6 to the maximum.
• The freeholder matters. If the RMC owned the freehold in the maximum building, the leaseholder protections would fall away and the in-force count would drop by 14, to 137.
• Overlapping registration regulations are counted separately. The three key building information regulations (SI 2023/396 regs 19-21) overlap. Merging them is a judgement for a lawyer and would take the maximum to 149.
• In force means in force for England on 15 October 2026. The 151 excludes 10 items: 6 passed-but-not-in-force (including s.111), 1 contested (LOLER), 1 guidance-only (legionella) and 2 where we could not confirm the duty binds an RMC (BSA s.95 for an RMC that owns a flat, and Defective Premises Act s.2A for works).

Below the duty level, the same provisions break down into roughly 140 sub-paragraph requirements for the small block and roughly 705 for the maximum. Those figures come from an automated keyword sort that nobody has reviewed, so they are rough.

Want the full list for your building type? Email [email protected] with your building's height, whether it has a lift, and whether the company employs anyone. We will send the duty list as a CSV, one row per duty, with its legislation.gov.uk link and its in-force status on every row. It is the same unreviewed inventory described above.

#Common Questions

#How many legal duties does a block of flats have in England?

By our unreviewed count, a converted house of three or four flats run by an RMC with no staff carries 40 duties that are in force. A higher-risk building with every common trigger present carries 151. Height, evacuation strategy, staff, works and the number of accountable persons decide where a block sits.

#Is an annual fire risk assessment review a legal requirement?

The Fire Safety Order requires the responsible person to review the fire risk assessment regularly and whenever there is reason to suspect it is no longer valid (article 9(3)). It sets no fixed interval. A yearly review is common practice and often an assessor's recommendation, which you can record and follow as your own decision.

#Is a five-yearly EICR a legal requirement for communal areas?

No statute sets a five-yearly interval for common-parts wiring. The five-year figure is law for private and social landlords of specified tenancies under the Electrical Safety Standards Regulations 2020. For a block's common parts the interval comes from industry guidance, and the legal duty is to keep the installation safe.

#Can RMC or RTM directors be personally liable for building safety offences?

Yes. Under Building Safety Act section 161 (for offences under Parts 2 and 4) and Fire Safety Order article 32(8)-(9), a director is personally guilty where the company's offence was committed with their consent or connivance, or is attributable to their neglect. Under the Fire Safety Order, where members manage the company, members are treated as directors.

#Does LOLER apply to passenger lifts in residential blocks?

It is contested. HSE says LOLER only applies to lifting equipment used at work, but that passenger lifts mainly used by people not at work will generally need to meet the same standards as LOLER and PUWER. Six-monthly thorough examination therefore applies in practice either way.

#Which building safety duties are passed but not in force?

As at 15 October 2026 these duties have not been brought into force: Fire Safety Order article 9A (competent fire risk assessors), Building Safety Act section 113 (safety information on demands), and the implied lease covenants in Landlord and Tenant Act 1985 section 30C. Sections 113 and 30C are in force only for making regulations. Section 111 is in force but has no regulations, so nothing in it operates yet.

#Further Reading

• Accountable person duties under the Building Safety Act
• Principal Accountable Person responsibilities
• BSA compliance checklist
• Who is the Principal Accountable Person?
• Legislation: Regulatory Reform (Fire Safety) Order 2005

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This post is for information only and is not legal advice. The counts come from an inventory that no lawyer or consultant has reviewed. For building-specific advice, consult a qualified fire safety professional or a solicitor.