If you manage residential buildings, you’ll know 2025 wasn’t short on fire door “hot takes”. We saw well-meaning programmes spiral into blanket replacements. We saw leaseholders told their doors were “non-compliant” because they didn’t look like a brand-new certificated set. And we saw the same three myths repeated on loop:

• “No label = not a fire door.”
• “No smoke seals = fail.”
• “If it isn’t today’s standard, it must be replaced.”

In August 2025, that fog began to clear. The government updated its fire door guidance linked to the Fire Safety (England) Regulations, with a simple message: the purpose isn’t to force all existing flat entrance doors to meet modern new-build standards — it’s to make sure they’re effectively self-closing, maintained, and not functionally deficient.

That change matters because it brings proportionality back into the conversation. Here’s what shifted in 2025, and how to turn it into a clean, defendable plan for 2026.

What changed in 2025 (in plain English)

The updated guidance makes several points crystal clear:

1) “Adequate” is not the same as “latest new-build standard”

The guidance explicitly states that the purpose of the Regulations is not to ensure existing flat entrance doors satisfy the current standards used for new blocks of flats under Building Regulations.

Instead, it points you back to risk: a door that met the relevant standard at the time the building was built (or when the door was manufactured) will, in most circumstances, continue to provide adequate protection if it’s undamaged and the gaps aren’t excessive.

2) No strips, no seals, no certification doesn’t automatically mean “unfit”

This is where 2025 really cooled down the noise.

The guidance is clear: the absence of intumescent strips and smoke seals, and the absence of certification, does not imply the door is unfit for purpose.

That doesn’t mean “ignore it”. It means you don’t default to replacement purely on paperwork (or lack of it). You default to performance, condition, and risk.

3) Regulation 10 checks are “simple, but important” — not a full FRA

The guidance also draws a strong line between:

• what a fire risk assessment considers (door fire resistance suitability within the wider strategy), and
• the simple checks required under Regulation 10 to make sure doors remain suitable thereafter.

That distinction helps you scope your programme properly: routine checks, clear records, and targeted remedials.

What Responsible Persons actually need to do (and record)

The guidance confirms Regulation 10 covers:

• information to residents (for all blocks of flats with common parts), and
• routine checks in buildings where the top storey is more than 11m above ground level (typically 4+ storeys).

For flat entrance doors, it also stresses you must keep a record over each 12-month period of the steps taken, including where access wasn’t granted.

This is where 2026 programmes often succeed or fail: not on the first inspection day, but on the repeatability of the system (who checks, how it’s recorded, and what triggers escalation).

A practical 2026 checklist for flat entrance doors

When you carry out checks, the guidance lists practical items such as:

• Has a resident replaced a fire-resisting flat entrance door with a non-fire door? If there’s doubt, they may need to confirm it’s fire-resisting and provide technical information.
• Letterplates: are they firmly closed, not jammed open, and suitable if newly installed?
• Damage/defects: leaf, frame, wall/lining, warping affecting fit, holes/alterations, glazing damage.
• Hinges/ironmongery: obvious defects like missing/loose screws.
• Strips and seals: if present, are they undamaged, making contact, and not painted over? If not originally present, that may be acceptable depending on the FRA.

The theme is consistent: function, condition, and obvious defects.

The real lesson from 2025: stop buying “certainty theatre”

A lot of 2025 spend was driven by a desire for certainty. The irony is that the most defensible position is often simpler:

• A door that closes properly, fits properly, and isn’t damaged is a stronger safety outcome than a rushed replacement programme that introduces poor installation, bad interfaces, and weak QA.
• A record of routine checks and prompt remedials is more credible than “we replaced everything” with no evidence trail.

The government’s revised wording basically gives Responsible Persons permission to be risk-led, not rumour-led.

How to build a clean 2026 plan (that stands up to scrutiny)

Here’s a simple approach that works whether you manage 40 doors or 40,000:

Step 1: Separate “routine checks” from “specialist assessment”

Use Regulation 10 checks to catch obvious issues and prevent deterioration. Use competent specialist assessment when:

• defects are widespread,
• building strategy is unclear,
• door types are mixed/unknown,
• or resident alterations are common.

The guidance itself notes routine checks are not a substitute for periodic assessment by specialists (for example during FRAs).

Step 2: Create a clear “repair vs replace” decision path

2025 taught the industry this: blanket replacement is a procurement habit, not a safety strategy.

Your decision path should consider:

• functional deficiency (won’t self-close, significant warping, damaged glazing, compromised leaf/frame),
• repeated failure despite repair,
• incompatibility with the building’s fire strategy,
• inability to confirm suitability where risk demands it.

Step 3: Make the evidence trail effortless

If your process relies on memory, it will fail. The goal is repeatable records:

• door ID/location
• date checked
• defect type
• remedial action
• close-out proof (photos, sign-off)

That’s the difference between “we think we’re compliant” and “we can demonstrate we’re compliant”.

FAQs

Do all flat entrance fire doors need replacing if they’re not certificated?

Not automatically. The guidance states that lack of certification does not imply a door is unfit for purpose. Condition, damage, gaps, and ability to do the job are what matter.

Are intumescent strips and smoke seals mandatory on older doors?

Not automatically. The guidance states their absence does not automatically mean a door is unfit, and notes that if strips/seals were not originally present this may be acceptable subject to the fire risk assessment.

What is the main point of the 2025 update?

To clarify that the Regulations are not about forcing existing doors to meet current new-build standards, but about ensuring doors (especially flat entrance doors) are effectively self-closing and maintained.

What records do we need to keep?

For flat entrance doors, Regulation 10 requires a record over each 12-month period of steps taken to check doors, including where access wasn’t granted.

Did your 2025 seem confusing?

If your 2025 programme felt like confusion, cost, and conflict, make 2026 the year you switch to risk-led, evidence-led fire door management: routine checks that actually happen, records you can defend, and remedials that fix what matters.