Thousands spent on fire doors that didn’t need replacing. Here’s why

Since the Fire Safety (England) Regulations 2022 came into force in January 2023, there’s been a lot of discussion over what constitutes a pass or fail when it comes to flat entrance doors.

Many landlords, housing associations and building managers have spent thousands on inspections and replacements for doors deemed “unfit for purpose” simply because they lacked modern certification, when, in many cases, those doors didn't need replacing at all.

In August 2025, the Government issued updated guidance on the Fire Safety (England) Regulations 2022 to address this directly, and it’s worth understanding what it means in practice. 

Let’s talk doors

Not all fire doors are the same, and understanding the difference matters. There are three types of door you're likely to encounter. 

Certified fire doors are tested and labelled to current standards with full supporting evidence.

Nominal fire doors are intended to provide a specific level of fire resistance, typically 30 or 60 minutes, but lack complete or traceable documentation to fully support that performance.

Notional fire doors were compliant with fire-resisting standards at the time the building was constructed or refurbished. They often pre-date modern certification schemes and may lack intumescent strips or cold smoke seals, but can still offer reasonable fire resistance if they remain in good condition and haven't been altered or damaged.

Do all fire doors need replacing?

No. A fire door's primary job is to close correctly and prevent fire and smoke spreading through a building. If a door still closes properly, sits well in its frame and shows no obvious signs of damage, it may well still be adequate.

The absence of modern certification, smoke seals or intumescent strips does not automatically make a door unfit for purpose. What matters is whether it can still do its job.

Risk-proportionate fire safety

The response to any fire door concern should reflect the actual risk, not a worst-case assumption. A door in a small low-rise building presents a very different risk profile to one in a tall, complex building with challenging escape routes — and the decisions made should reflect that difference.

Before committing to replacement or major works, it's worth working through some straightforward questions:

• What is the age and construction of the door?

• Is it still functioning correctly — closing fully, latching properly, with no significant damage?

• What is the building type, height and resident profile?

• Is there a reasonable basis to believe the door still provides adequate fire resistance?

Where the evidence supports continued serviceability, repair or ongoing monitoring is often the right call. Where there are genuine concerns — major damage, failing closers, significant gaps — action should be prompt. The key is that decisions are grounded in the actual situation, not driven by assumption or fear of liability.

What do the regulations require?

The Fire Safety (England) Regulations 2022 apply to all residential buildings in England with two or more dwellings sharing common parts, such as blocks of flats or converted houses with communal corridors and stairways.

Under Regulation 10, the Responsible Person must:

• In all buildings, remind residents to keep fire doors shut, not to tamper with closers, and to report any faults or damage

• Check communal doors (stairways, lobbies, corridors) in buildings over 11 metres at least every 3 months 

• Use best endeavours to check flat entrance doors in buildings over 11 metres at least every 12 months

Failing to do this isn't just poor practice — it can be a criminal offence if it puts residents at risk.

Who should carry out checks?

Checks should be simple and visual, carried out by building managers, caretakers or other trained staff. You don't need a specialist contractor to confirm whether a door shuts properly or has obvious defects.

However, when defects are found — large gaps, faulty closers, damaged glazing — the Responsible Person must act quickly. At that point, commissioning a formal inspection by a competent third party is the sensible route.

In a nutshell

A door's functionality matters more than its label. The updated guidance is clear: you don't need to replace every door that lacks modern certification. What you do need is a consistent, documented system of checks and, where gaps exist, decisions based on inspection, risk and professional judgement.

Getting this right doesn’t have to be complicated or costly. At Peak, we give clear, practical and proportionate advice. If you need a fire door survey, contact us today.