IFE and FIA fire safety guidance targets serviced apartments and aparthotels in England

Fire safety grey area inside aparthotels

The Institution of Fire Engineers (IFE), working with the Fire Industry Association (FIA), has published an introductory note on serviced apartments and aparthotels and the fire safety challenges they can create for design, compliance and building management in England.

The IFE said serviced apartments and aparthotels are increasingly common in UK urban developments and mixed-use buildings, with rental durations ranging from single nights to months or longer.

It said this creates uncertainty because the units can resemble standard flats but operate more like hotels in terms of occupant turnover and familiarity with the building.

The note said this grey area can affect both building design decisions and the way fire safety is managed during occupation.

Why occupancy affects compliance routes

The IFE said many fire regulations treat buildings containing “dwellings” differently from buildings that do not, and that the definition can be complex.

It said duration of occupancy is often a key factor, with daily rentals less likely to be classed as dwellings and year-long rentals more likely to meet that definition.

Regulation 5 of the Building Regulations sets out scenarios that can count as a “material change of use”, including changes to the number of dwellings or converting a building into a hotel.

The IFE said converting an existing building to serviced apartments or an aparthotel is likely to be treated as a material change of use, requiring compliance with the functional requirements of the Building Regulations.

In this scenario, the “non-worsening” criteria often applied to existing buildings would not apply.

The IFE said the trend of converting redundant city-centre offices into aparthotels or flats can be complex and may fall short of purpose-built residential standards if not carried out competently.

Fire safety strategy and evacuation decisions

The IFE said blocks of flats are often designed around a stay put approach, based on compartmentation and occupants being familiar with escape routes and procedures.

It said serviced apartments and aparthotels can challenge that approach because short-term occupants may be unfamiliar with the building, which can point towards simultaneous evacuation in some cases.

The note said any move towards simultaneous evacuation would bring different design and management needs, such as enhanced detection and alarm, clear signage, escape route management and a continuous staff presence with evacuation planning.

It said a hybrid approach may suit some buildings, where an initial smoke detector activation triggers an alarm within the flat of origin and escalates to full evacuation if a heat detector activates in a key location.

The IFE said this would need careful consideration alongside management response expectations and any smoke control system designed around one flat evacuating at a time.

Sprinklers or alternative automatic suppression systems should be considered as part of the overall strategy.

The note added that a hotel-based approach can also be challenging because many aparthotels include cooking facilities, which are not typically present in hotel bedrooms.

HRB status and fire risk assessment scope

The IFE said the status of a building as a Higher Risk Building (HRB) in England can depend on height and whether it contains at least two residential units, a care home or a hospital.

It said the definition of “residential units” excludes hotels, and that it is currently unclear how serviced apartments and aparthotels fit within HRB occupancy definitions.

The IFE said this distinction affects whether building control applications go to a Local Authority or Registered Building Control Approver for non-HRBs, or to the Building Safety Regulator (BSR) for HRBs.

It said HRBs in occupation must register with the BSR and have a Building Safety Case in place, and that failing to do so could be a criminal offence.

The note said changes in how units are rented could change the regulatory position, including scenarios where longer-term rentals lead to units being classed as dwellings.

The IFE said fire risk assessment scope can also change under the Regulatory Reform (Fire Safety) Order 2005, because dwellings are excluded but non-dwellings must be included.

It said if units are not dwellings, fire risk assessments would need to cover the apartments themselves as well as common areas, affecting responsibilities, enforcement and compliance.

What this means for building fire roles

Fire engineers and fire engineering consultants may need to confirm intended occupancy patterns early, because the note links rental duration to how terms like “dwelling” may be interpreted in practice.

Risk assessors may face changes to fire risk assessment scope where units are treated as non-dwellings, because the note says this can extend assessment beyond common parts into apartments.

Architects, building services engineers and M&E engineers may need to reflect on evacuation strategy choices where occupant familiarity is low, because the note contrasts stay put assumptions with short-term occupancy patterns.

Facility managers and building managers may need to test whether any managed evacuation approach can be sustained over time, because the note describes reliance on 24/7 staffing, training and long-term financial commitment in some strategies.

Developers and those engaging with building control may need clarity on regulatory pathways and HRB status, because the note describes different oversight routes for HRBs and non-HRBs and the legal consequences tied to registration and safety case duties.