Policy D12 of the London Plan (2021), the Mayor of London's spatial development strategy for Greater London, requires development proposals to achieve the highest standards of fire safety. The policy has two parts. Policy D12(A) sets out six criteria that development proposals should address, demonstrated through a Planning Fire Safety Strategy (PFSS). Policy D12(B) requires major development to go further and submit a Fire Statement — a standalone document that incorporates the PFSS content and is written by a suitably qualified fire safety assessor.
It is worth being precise about what this is not. The Fire Safety London Plan Guidance explicitly distinguishes Policy D12 from the government's own Gateway One fire statement requirement, which operates nationally under the Building Safety Act regime for higher-risk residential buildings. Compared with Gateway One, Policy D12 applies to all land uses, applies at a lower size threshold, and requires more fire safety information to be demonstrated at the planning stage. Where a scheme is large and tall enough to trigger both, the applicant typically needs to satisfy each separately.
Who needs to submit one
Per the Fire Safety London Plan Guidance, a Planning Fire Safety Strategy should accompany planning applications for development that includes a new residential or commercial unit, a new lift, alterations to the materials used on external walls, or alterations to internal or external communal areas that support the building's evacuation strategy. Major development proposals must go further and submit a Fire Statement under Policy D12(B), incorporating the PFSS content. Separately, Policy D5(B5) requires any application proposing a lift or lift core — major or not — to demonstrate how evacuation lift provision has been considered.
Where an applicant considers that part or all of Policy D12 does not apply — most householder applications, and other minor works that do not touch fire safety — a Reasonable Exception Statement can be submitted instead, setting out which criteria are not relevant and why. Outline planning applications submit an Outline Fire Statement, with the level of detail scaled to whichever reserved matters — access, appearance, landscaping, layout, scale — are included in that particular application.
What a Fire Statement or PFSS actually has to cover
Both documents work through the same six criteria, proportionate to the development's size and complexity. They must identify suitably positioned, unobstructed space for fire and rescue service appliances and for an evacuation assembly point; set out the passive measures (compartmentation, fire doors, fire-resisting construction) and active measures (alarms, detection, suppression, ventilation) that reduce the risk to life; and address construction methods and materials, including — for major development — a specific commitment that the development will not use combustible materials in its external walls, other than materials achieving Class A2-s1 or better under the European classification system in BS EN 13501-1, subject to the limited exemptions in Regulation 7(3) of Approved Document B.
The remaining three criteria cover means of escape and the evacuation strategy — which must be inclusive and workable for people with mobility, sensory or cognitive disabilities and for people who do not have a good understanding of English, with an explanation of how occupants would be kept safe if they chose to self-evacuate from a stay-put building — a strategy that is periodically reviewed and published so occupants can have confidence in it; and suitable access and equipment for firefighting, including a confirmed water supply. The guidance is explicit on one point that catches out weaker submissions: simply reproducing excerpts from Approved Document B, without relating them to the specific site, does not demonstrate compliance.
Competence requirements scale with the document. A Fire Statement for major development should be authored by an assessor registered with the Engineering Council as an Incorporated or Chartered Engineer and registered with the Institution of Fire Engineers at Member, Fellow or Life Fellow grade — or by another professional with qualifications and demonstrable experience commensurate with that standard. For non-major development, the PFSS author needs no fixed minimum qualification, but must still demonstrate a fire safety background proportionate to the scheme, and for major development a signed declaration of compliance is also required.
Common misconceptions
The first misconception is treating Policy D12 as simply the London version of the national Gateway One requirement. They overlap in subject matter but differ in scope and threshold, as the London Plan Guidance itself sets out, and satisfying one does not automatically satisfy the other on a scheme large enough to trigger both.
The second is assuming a generic Approved Document B write-up will pass — the guidance rejects that approach directly. The third, more relevant to smaller schemes, is assuming every planning application needs a full Fire Statement: for householder applications and minor works that leave the building's fire safety measures unaffected, a short Reasonable Exception Statement is the proportionate route, provided it honestly says so and identifies any mitigation needed where existing measures are altered.
Practical next steps
Fire safety information is meant to evolve alongside the design, not be produced retrospectively to answer a planning question. The practical starting point is to establish early whether a scheme is major or non-major development, which of the four triggers (new unit, new lift, external wall material change, communal area alteration) apply, and to bring in a suitably qualified assessor at the concept stage rather than once the application is otherwise ready to submit — a PFSS or Fire Statement written against a design that is already fixed tends to surface conflicts too late to resolve cheaply.
Apex prepares Fire Statements and Planning Fire Safety Strategies for developments across London (Apex holds no installation or remediation arm), scaled to the size and complexity of the scheme rather than assembled from a standard template.
Common questions
What is the difference between a Fire Statement and a Planning Fire Safety Strategy?
They address the same six policy criteria. A Planning Fire Safety Strategy (PFSS) is the document non-major development submits under Policy D12(A). A Fire Statement is what major development submits under Policy D12(B); it incorporates the PFSS content but must additionally be authored — and its compliance declared — by an assessor meeting a specific competence standard.
Does Policy D12 apply to developments outside London?
No. Policy D12 is a policy in the London Plan, the Mayor of London's spatial development strategy, and applies to planning applications determined in Greater London. Developments elsewhere in England may still need a fire statement under the national Gateway One requirement if they meet its higher-risk building threshold, but that is a separate regime with its own scope.
Can a major London development use combustible materials in its external walls?
The Fire Statement must include a specific commitment that it will not, other than materials achieving Class A2-s1 or better under BS EN 13501-1, subject to the limited exemptions set out in Regulation 7(3) of Approved Document B. This is a London Plan Guidance requirement additional to whatever the Building Regulations separately require.