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Guide · External walls, FRAEW & EWS1

FRAEW for commercial buildings: do hotels, offices and warehouses need one?

PAS 9980 was written for blocks of flats, but hotels, offices, warehouses and other non-residential buildings have external walls too – and their owners still have legal duties. Here's how an FRAEW for commercial buildings works outside the residential sector, and why investors and insurers are asking for one.

Updated 3 min read London Fire Safety Consultants

In short

  • PAS 9980 is written for multi-storey, multi-occupied residential buildings.
  • For other buildings, the Fire Safety Order still requires the fire risk assessment to consider the external walls.
  • Since 1 December 2022, the combustible materials ban has applied to new hotels, hostels and boarding houses 18m+.
  • Investors, lenders and insurers increasingly expect an external wall assessment for commercial assets.

Where PAS 9980 stops

PAS 9980 – the code of practice for fire risk appraisals of external walls – is written for existing multi-storey, multi-occupied residential buildings. Its risk factors and examples assume people living in flats, often with a stay put evacuation strategy. It doesn't directly cover hotels, offices, warehouses, retail, healthcare or schools.

For non-residential premises, the Regulatory Reform (Fire Safety) Order 2005 applies to the whole premises, including the external walls. The responsible person must carry out a suitable and sufficient fire risk assessment, and that includes the risk of fire spreading over the external walls and to or from neighbouring buildings. Where the external walls include combustible materials, a general fire risk assessor will often recommend a specialist assessment.

New buildings: the combustible materials ban

The ban on combustible materials in the external walls of "relevant buildings" of 18m and over was extended to hotels, hostels and boarding houses from 1 December 2022. It applies to new building work, not retrospectively – but it shows how the government regards the risk in buildings where people sleep.

How an FRAEW for commercial buildings is carried out

Specialists usually adapt the PAS 9980 approach with fire engineering judgement, considering:

  • Who is in the building – awake or asleep, familiar or unfamiliar with it, able to evacuate independently
  • The evacuation strategy – most non-residential buildings evacuate simultaneously
  • Height and fire service access
  • Sprinklers and detection
  • The materials – their combustibility, extent and location
  • Fire spread between buildings and to neighbouring property
  • Property protection and business continuity – often a bigger concern for insurers than life safety

Building types

Hotels

Guests sleep in unfamiliar surroundings, often at height. Hotels with combustible cladding, timber or high-pressure laminate panels need careful assessment, and insurers and lenders frequently ask for one. Hotels were included in the original post-Grenfell ACM programme.

Offices

Occupants are usually awake and familiar with the building, and evacuate together, so life-safety risk from external walls is often lower. But tall offices, mixed-use buildings and those being converted to flats need a closer look – see office-to-residential conversions.

Warehouses, logistics and self-storage

Large areas of insulated sandwich panels can drive rapid fire spread and total loss. The main concerns are often firefighter safety, property protection and business continuity, which is why insurers focus on panel type and condition.

Why investors and lenders are asking

External wall liabilities can move asset values and affect financing for commercial property just as for residential. A clear external wall assessment is increasingly part of acquisition due diligence – see fire safety due diligence.

What an external wall assessment of a commercial building includes

  • Desktop review of drawings, specifications and product information
  • Site inspection of each wall type and attachment
  • Intrusive investigation where the build-up can't be confirmed
  • Assessment of fire spread risk, taking account of occupants, height, evacuation strategy and suppression
  • Consideration of fire spread to and from neighbouring buildings
  • Recommendations – management measures, targeted remediation or further investigation – proportionate to the risk
  • Clear outputs for insurers, lenders and investors

Mixed-use buildings

Where a building contains flats and commercial uses – for example shops or a hotel below apartments – the residential parts usually bring PAS 9980 into play directly, and the whole building may be a higher-risk building. The external wall assessment needs to consider the building as a whole.

Our FRAEW service covers residential and non-residential buildings, and our due diligence team reviews external wall risk across commercial portfolios.

How we can help

We match each project to a qualified specialist and confirm the scope, the named professional and a fixed fee before you commit.

Sources

This guide is general information based on the law and guidance in England as at 8 November 2026. It isn't legal advice – for advice on a specific building, get in touch.

FAQs

Frequently asked questions

Does PAS 9980 apply to hotels?

PAS 9980 is written for multi-storey, multi-occupied residential buildings. Hotels aren't directly covered, but specialists often adapt its approach, and the hotel's fire risk assessment must still consider the external walls.

Do commercial buildings need an external wall assessment?

The Fire Safety Order requires the fire risk assessment to consider fire spread over the external walls. Where combustible materials are present, a specialist assessment is often recommended – and investors, lenders and insurers increasingly ask for one.

Does the combustible cladding ban apply to hotels?

Since 1 December 2022, the ban on combustible materials in external walls of buildings 18m and over has applied to new hotels, hostels and boarding houses. It isn't retrospective.

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