Legislation Updates

Draft BS 9996: a new code of practice for keeping fire safety systems working together

BSI has opened consultation on draft BS 9996 for commissioning and maintaining integrated fire safety systems. What it means for responsible persons.

The British Standards Institution (BSI) has opened a public consultation on a proposed new British Standard, BS 9996 – Commissioning and maintenance of integrated fire safety systems – Code of practice. The draft was issued for public comment on 21 October 2026, and the consultation closes on 6 January 2027.

As reported by Fire Safety Matters, the draft covers how active and passive fire safety measures in a building are commissioned, tested together, inspected and maintained across the life of the building, and how information and changes are managed so those measures stay effective and coordinated, with a clear audit trail.

It is important to be clear: this is a draft for comment, not a published standard, and it does not change the law. But it points firmly in a direction that anyone responsible for a building should already be heading.

What the draft covers

According to the published summary, the draft BS 9996 addresses:

  • Planning and carrying out commissioning of active and passive fire safety systems, including integrated systems testing and whole-building performance verification.
  • Planned inspection, testing and maintenance arrangements across the building's life.
  • How design, specification, commissioning, verification, inspection and maintenance relate to each other.
  • Managing information and change, so fire safety measures remain effective and coordinated, with a clear audit trail.
  • A process for jointly commissioning and maintaining systems that interact with each other, recorded across the full building lifecycle.

The intended audience is broad: clients, designers, fire engineers, installers, commissioning agents, maintainers, facilities managers, Accountable Persons, duty holders, Building Control bodies and fire and rescue service personnel.

Why "integrated" matters

In my experience carrying out fire risk assessments, the systems in a building are usually maintained in silos. The alarm engineer services the alarm. A separate contractor looks at the AOVs or smoke vents. Someone else checks emergency lighting. Fire doors get looked at when something breaks. Each certificate may be in order, yet nobody has checked that the whole lot works together.

That is where real problems hide. A fire alarm that no longer triggers the smoke ventilation. Hold-open devices that don't release on alarm. Compartmentation breached by a new cable run after the last inspection. A cause-and-effect matrix that no one has tested since handover. These are exactly the interactions the draft standard focuses on.

What this means for you

The legal duty to maintain fire safety measures already exists. Under Article 17 of the Regulatory Reform (Fire Safety) Order 2005, the responsible person must, where necessary, ensure that the premises and the facilities, equipment and devices provided are subject to a suitable system of maintenance and are kept in an efficient state, in efficient working order and in good repair.

For blocks of flats in England, the Fire Safety (England) Regulations 2022 add specific checks:

  • In residential buildings with storeys above 11 metres: quarterly checks of communal fire doors and annual (best endeavours) checks of flat entrance doors, including self-closers.
  • In high-rise residential buildings (at least 18 metres or seven storeys): monthly checks of firefighting and evacuation lifts and essential fire-fighting equipment, such as rising mains, smoke control, fire detection and alarm systems, and automatic door release mechanisms, with faults that can't be fixed within 24 hours reported to the fire and rescue service.

This is relevant to:

  • Social housing providers and managing agents with blocks containing several interacting systems.
  • Care and supported housing operators, where alarm, door hold-open devices, compartmentation and evacuation strategy are tightly linked.
  • Schools, NHS premises and commercial buildings, where systems are often added and altered over many years by different contractors.
  • Accountable Persons for higher-risk buildings, who are named among the draft's intended users.

Practical takeaways: what to check now

You don't need to wait for BS 9996 to be finalised. Start with these:

  1. List every fire safety system and measure in the building – active (alarm, emergency lighting, smoke control, sprinklers, door releases, lifts) and passive (fire doors, compartmentation, fire-stopping).
  2. Map how they interact. What should happen when the alarm activates? Is there a cause-and-effect document, and has it been tested end to end recently?
  3. Check who maintains what, and whether any measure has fallen between contractors.
  4. Review your records. Can you show service certificates, test logs, fire door inspection records and remedial actions in one place?
  5. Control changes. Make sure refurbishments, new services or system upgrades are checked for their effect on other fire safety measures.
  6. Make sure your fire risk assessment reflects reality. Your assessor should be reviewing maintenance arrangements and records, not just walking the corridors.
  7. Consider responding to the consultation if you manage complex buildings – BSI's project page explains how to submit comments.

How Obelisk can help

At Obelisk Fire Safety we carry out fire risk assessments to BS 9792:2025 for housing and PAS 79-1:2020 for other premises, along with fire door inspections and surveys, nationwide, with a focus on the East Midlands and surrounding areas. As part of every assessment we look at how your fire safety measures are maintained and whether they work together as intended.

If you'd like a review of your buildings, contact us at info@obeliskfire.co.uk or call 07407 156178.

This article is for general information and does not constitute legal advice.


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