A fire officer walks into a twenty-two room hotel in Scarborough at ten past nine on a Tuesday in February. He asks the duty manager for the fire risk assessment. The duty manager brings a ring binder containing an alarm servicing certificate, a PAT testing schedule and a copy of the buildings insurance. The officer asks again. There is an assessment somewhere, from 2016, done by a consultant who no longer trades, describing a first floor layout that stopped existing when the old function room became four bedrooms.
By eleven o'clock the second floor is out of use and fourteen guests are being moved.
You are the responsible person whether you feel like one or not
Fire safety in a hotel in England and Wales runs on the Regulatory Reform (Fire Safety) Order 2005. There is no licence and no certificate. Nobody signs your building off and nobody comes round annually to tell you it is fine. The Order instead names a "responsible person" and puts every duty on them.
In a hotel that is the employer, and in practice whoever has control of the premises. If you own the building and run the business, it is you. If you lease it, duties can sit with you and the landlord at the same time, which in an investigation means neither of you gets to point at the other. In Scotland the equivalent regime is Part 3 of the Fire (Scotland) Act 2005 with the Fire Safety (Scotland) Regulations 2006, which uses the term duty holder. In Northern Ireland it is the Fire and Rescue Services (Northern Ireland) Order 2006 and the Fire Safety Regulations (Northern Ireland) 2010.
You can pay a consultant to carry out the assessment. You cannot pay one to become the responsible person. If the assessment is poor, you are the one prosecuted for relying on it, which is why the Order expects you to satisfy yourself that whoever you engage is competent rather than cheap.
The whole assessment has to be written down now, not just the findings
There was a long period when small premises could get away with a thin paper trail. If you employed fewer than five people and held no relevant licence, you had to make the assessment but you did not have to record it.
Section 156 of the Building Safety Act 2022 changed that. Since 1 October 2023, every responsible person in England and Wales must record the fire risk assessment in full, regardless of the size of the premises or how many people they employ. You must also record your fire safety arrangements, record the name of the individual or organisation engaged to carry out any part of the assessment, and provide contact details so that a successor or an inspector can trace the work.
The test the Order sets is that the assessment is suitable and sufficient. In practice that means it identifies the hazards, identifies who is at risk, evaluates and removes or reduces the risk, and records what you decided and why. It is also not a document you write once. Convert a store cupboard into an office, install a new kitchen, change the use of a floor, or take on a member of staff who cannot hear the alarm, and the assessment is out of date from that day.
Sleeping guests change what the building has to do
The Government guidance for this sector is the fire safety risk assessment guide for sleeping accommodation, and the title is the whole point. A person asleep does not smell smoke. A guest who checked in at eight in the evening does not know there is a second staircase. Some of your guests will have had a lot to drink, some will be children, and some will be in a room they have never seen in daylight.
That is why the standards applied to a hotel are stricter than the ones applied to an office of the same size. You are relying on compartmentation to buy time: fire doors that actually close, with intumescent strips and cold smoke seals, in frames that have not been painted into uselessness. You are relying on a protected escape route that stays clear, which means the corridor is not where you keep the spare mattresses. Emergency lighting is designed to BS 5266 so the route works when the power goes. Detection in sleeping accommodation is usually specified to BS 5839-1 at category L1 or L2, which puts detectors in the bedrooms themselves rather than only in circulation space.
The single most common failure in a hotel is not a missing system. It is a wedged fire door. A magnetic hold-open device linked to the alarm is a legitimate engineering solution and it releases when the alarm sounds. A wooden wedge under a bedroom door because housekeeping is in and out with a trolley is a breach, and it is one an inspector can photograph in thirty seconds.
You also need to have thought about guests who cannot use the stairs before one of them books. Personal emergency evacuation plans are the mechanism. Refusing the booking is not, because that runs straight into the Equality Act 2010.
Enforcement is a ladder, and the top of it is immediate
Your enforcing authority is the local fire and rescue authority. The ladder runs from informal advice, to an alterations notice requiring you to tell them before you change anything, to an enforcement notice setting out what is wrong and giving you a period to fix it.
The one that ends trading is the prohibition notice. Where the authority considers that use of the premises involves or will involve a risk to people so serious that use should be prohibited or restricted, the notice takes effect immediately. There is no compliance period. It can cover the whole building or, more commonly in hotels, a floor or a wing. You have twenty-one days to appeal to the magistrates' court and the notice bites while you appeal.
Serious offences under the Order carry an unlimited fine and up to two years' imprisonment on indictment. The financial damage usually arrives before the court does, because a hotel that has lost forty per cent of its bedrooms in March is still paying the mortgage in April, and the notice tends to become local news.
Your insurer is the other party watching. Policies carry conditions about compliance with fire safety legislation and about maintaining protection systems. A claim after a fire in a building with a 2016 assessment and a wedged door is a claim with an argument attached.
Where this shows up in the game
Hotels arrive in Business Baron with the Hotels & Leisure Track, an add-on to the full game. Inspections turn up on a risk rating that a complaint can pull forward, and they ask for the records you kept rather than the ones you meant to keep. At the far end of the ladder is a notice that closes you that day, which in a business that sells nights takes the bookings with it.