What the gap between EV charging regulations and fire safety guidance means for building owners and managers

Since June 2022, Part S of the Building Regulations has required EV charging infrastructure in all new residential and commercial buildings. New non-residential buildings with more than ten parking spaces must have at least one charge point, with cable routes to at least 20% of the remaining spaces. Major renovations trigger the same requirement. The mandate is clear, and adoption is accelerating.

The problem is that Approved Document B – the statutory guidance for fire safety in buildings – does not yet address the fire risk introduced by internal EV charging points. The document is currently under review in relation to car park guidance, but as it stands, the general provisions were designed around a maximum three-car fire scenario. The Liverpool Echo Arena fire in 2018 and the Luton Airport fire in 2023 both demonstrated that uncontrolled fire spread across large numbers of vehicles is a realistic consequence, not a theoretical one.

Where the compliance gap sits

A building owner installing EV chargers in a basement car park or enclosed parking structure is complying with Part S. But if the fire risk assessment has not been updated to reflect the changed risk profile of that space, the building may not be meeting its obligations under the Fire Safety Order. These are two separate regulatory regimes, and compliance with one does not discharge the other.

The Office for Zero Emission Vehicles published guidance (authored by Arup) on fire safety and EV charging, but the document itself states that following it does not guarantee the functional requirements of Part B have been met. A competent fire engineer is needed to assess the specific risks presented by each installation.

For existing buildings retrofitting chargers, the gap is often wider. A car park designed and risk-assessed in the 1990s or 2000s will have been evaluated against a fire load that did not include lithium-ion battery packs. The detection, suppression (if any), ventilation, and structural fire resistance may all be inadequate for the revised risk.

Electrical compliance adds further layers

Every EV charger installation must comply with BS 7671, the 18th Edition Wiring Regulations, including Amendment 2 requirements. Each charge point needs a dedicated final circuit. Where buildings use a PME earthing system – common in UK commercial properties – there is a specific risk from open PEN faults that can make a vehicle’s chassis live. Compliance requires either an earth electrode or a dedicated open PEN detection device.

These are not optional enhancements. They are regulatory requirements, and non-compliance can void insurance cover. For multi-tenant buildings where different parties are responsible for different aspects of the electrical installation, the coordination requirement is considerable.

What responsible persons should do now

If EV chargers have been installed or are planned, the fire risk assessment needs updating by someone competent to assess the specific risks. That assessment should cover detection adequacy in charging areas, ventilation rates in enclosed or underground spaces, suppression provision (Approved Document B research has noted that the effectiveness of standard sprinkler densities against EV fires is not fully understood), structural fire resistance of the car park, and the evacuation implications if a charging area is adjacent to escape routes.

The electrical installation should be verified as compliant with BS 7671 Amendment 2, with particular attention to earthing arrangements. If chargers were installed before the Amendment 2 requirements, they may need retrospective assessment.

Insurance should be reviewed. Some commercial property policies now include specific conditions around EV charging, and failing to disclose the installation of chargers or to maintain compliant electrical systems can create coverage gaps that only become apparent after an incident.

Looking ahead

The number of EVs on UK roads tripled between 2022 and 2025, and the trajectory is set to continue. The buildings being constructed and retrofitted today will be managing EV charging for decades. Getting the fire safety provisions right now is not a discretionary improvement; it is the responsible person’s legal obligation under a risk landscape that the regulations have not yet fully caught up with.

New Path group companies provide fire alarm installation, maintenance, and fire risk assessment services across Southern England. To discuss how EV charging is affecting your building’s fire safety provisions, visit newpathfire.co.uk or contact your local group company.

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