PAS 9980:2026: what it is, and what it isn’t

The revised code for appraising external walls brings more structure and rigour. It doesn't change the purpose, and a rating is still evidence, not proof.

Simon Owen, Technical Director, HAALO · October 2026

PAS 9980:2026, published by BSI, came into effect on 30 September 2026 and replaces the 2022 code of practice for fire risk appraisal of external walls (FRAEW). It's worth being clear about what it is, and what it isn't.

FRAEWs competently produced under the 2022 version remain valid and in most cases may continue to be relied upon. The core methodology hasn't changed, but the revision brings more structure and rigour to how appraisals are carried out and reported:

A defined process for deciding whether an FRAEW is needed at all.
Four distinct risk outcomes (low, tolerable, medium and high), with "tolerable" now a band in its own right rather than the lower end of "medium".
A requirement for assessors to make reasonable worst-case assumptions.
Clearer terminology and reporting, so conclusions can be traced back to the evidence.
Greater emphasis on demonstrating competence. Clause 5, "Competence and Ethics", sets out what is expected of assessors, and letters after a name are no longer enough on their own. The onus is on the assessor to show competence, not assume it: government guidance expects the report to name its authors and reviewers, set out their qualifications and experience, and declare any conflicts of interest. Annex A breaks the FRAEW process into tasks and sets the skills needed for each. One person need not hold all of them: several may be needed to cover the full range.

What hasn't changed is the purpose

PAS 9980 is an appraisal of the risk posed by an existing external wall. It is not a design document. It does not apply to the design of new buildings, and it is not an alternative route to compliance.

Nor should it be used to justify retaining combustible materials in a façade build-up that amount to a relevant defect. A "tolerable" outcome is a conclusion reached on the evidence, not a target to work back from. Where remediation is needed, that work must be designed to satisfy the Building Regulations in its own right, including regulation 7(2) where it applies.

Tribunals have reinforced this. Under s.120 of the Building Safety Act 2022, a relevant defect is one that causes a building safety risk, and the Act assigns no risk rating. In Vista Tower, the First-tier Tribunal rejected the argument that only risks above "tolerable" should count. On appeal, the Upper Tribunal went further: any risk qualifies, with no threshold, though the level of risk still bears on what work is needed. In Canary Riverside (2026), the First-tier Tribunal treated PAS 9980 assessments as relevant evidence but not the deciding factor. An FRAEW is important evidence, but on its own it is not proof that a relevant defect has been resolved.

For building owners and Accountable Persons, the message is simple: use competent people to complete PAS 9980 assessments to understand the risk, and create an actionable plan for remediation where required.

Questions worth asking of your FRAEW

Does it set out the qualifications, experience and role of those who produced it?
Where components are unknown, were they assumed worst case and then investigated?
Has it been used to support a design, or to argue against remediation?
Would it pass the government's quality checklist, "Recognising quality in your FRAEW report"?
When is it due for review?

These are the questions our Asset Defensibility work starts from, as part of our wider Building Safety Act and Gateway advisory.

This paper sets out HAALO's professional perspective on this matter at the time of drafting. It is meant to be general information, not advice or legal or financial opinion on any specific building. The content of this paper should not be relied upon and we always recommend the reader retains their own professional advisory team.

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