Why Common Ground Now Requires Tenant Registration

1. Executive summary

Fire safety law governing residential buildings has changed fundamentally since Grenfell.
Landlords and managing agents are now expected to know who occupies their buildings, to communicate fire safety information directly to residents, and to maintain up to date records that can be inspected by Fire & Rescue Services.

Tenant registration is not optional administration.
It is a proportionate compliance measure that enables landlords and their managing agents to meet their legal duties under the amended fire safety regime.

2. What has changed in fire safety law

The Regulatory Reform (Fire Safety) Order 2005 (FSO) remains the core legislation, but it has been strengthened in three key stages:
a. Fire Safety Act 2021
This Act clarified that fire safety duties apply not only to common parts, but also to:

• the structure and external walls of buildings, and
• flat entrance doors

in short:
all buildings containing two or more dwellings

b. Fire Safety (England) Regulations 2022
In force since 23 January 2023, these Regulations introduced new mandatory duties for landlords and managing agents, including:

• providing fire safety instructions to residents,
• providing information about fire doors,
• keeping information up to date, and
• demonstrating compliance if inspected.

These duties apply to all multi occupied residential buildings, not just high rise blocks.

c. Building Safety Act 2022 – section 156 (in force 1 October 2023)
Section 156 amended the Fire Safety Order itself.
Key effects include:

• a requirement to record fire safety arrangements in full,
• stronger duties to co operate and co ordinate where responsibilities overlap,
• an explicit requirement to provide residents with relevant and comprehensible fire safety information.

In short:
fire safety law now assumes active management, not passive ownership.

3. Why knowing who occupies each flat now matters

Under the amended Fire Safety Order, the Responsible Person (usually the landlord or managing agent) must:

• identify who is at risk in the building,
• ensure residents receive fire safety instructions,
• keep information accurate and current, and
• be able to evidence compliance if challenged.

These duties cannot be met reliably if:

• tenancy changes are unknown,
• records only reflect historic leaseholder details, or
• the managing agent does not know who actually lives in each flat.

Fire risk assessments must consider people, not just buildings.
That necessarily requires accurate occupancy information.

4. Resident information duties – a practical reality

The law now requires that residents are told:

• how to report a fire,
• what to do if a fire occurs,
• what fire safety measures are in place, and
• why certain features (such as fire doors) matter.

This information must be provided to the actual occupiers of the flats.

If a managing agent does not know:

• who the occupiers are,
• when they moved in, or
• how to contact them,

then the landlord is exposed to a clear compliance gap.

5. Why Common Ground is implementing tenant registration

Common Ground manages fire safety obligations across multiple buildings and landlords, often where:

• ownership is fragmented,
• responsibility is shared, and
• occupancy changes frequently.

A consistent tenant registration process allows Common Ground to:

If a managing agent does not know:

• maintain accurate fire safety records,
• ensure information reaches the correct people,
• support landlords in meeting their statutory duties, and
• demonstrate compliance if inspected by Fire & Rescue Services.

This is a risk management and governance measure, not an expansion of scope.

6. Why this is being done portfolio wide

Fire safety law does not allow a “building by building” interpretation of basic duties.

Where a managing agent acts across a portfolio:

• inconsistent practices increase legal risk,
• gaps between buildings are difficult to defend, and
• enforcement action tends to focus on systems, not exceptions.

A portfolio wide approach:

• reduces regulatory exposure,
• creates a clear audit trail, and
• protects both landlords and managing agents.

7. Fees and proportionality

Fire safety legislation does not require compliance to be cost free.
It requires it to be effective, demonstrable, and proportionate.

Tenant registration supports:

• statutory record keeping,
• lawful communication with residents,
• inspection readiness, and
• enforcement defence.

A modest registration fee reflects:

• verification of information,
• creation and maintenance of compliance records, and
• ongoing regulatory obligations placed on managing agents.

This is consistent with how fire safety compliance costs are treated across the sector.

8. What tenant registration is – and is not

Tenant registration is:

• a compliance measure,
• a fire safety governance tool,
• a response to legislative change.

Tenant registration is not:

• data collection for its own sake,
• an optional administrative preference,
• a change to landlords’ ownership rights.

9. Key takeaway for landlords

Fire safety law now expects landlords and managing agents to know who lives in their buildings, to communicate fire safety information directly to those people, and to prove they have done so.

Tenant registration is the simplest and most defensible way to meet that expectation.