Over 700,000 leaseholders in England are estimated to live in buildings with potentially unsafe cladding — and a significant proportion of those properties sit in the 11–18 metre height range that regulators and lenders now scrutinise most closely. Yet for years, this "middle tier" of residential blocks fell into a regulatory grey zone: too tall to ignore, too short to trigger the strictest high-rise rules. That gap has now closed.
The convergence of the Building Safety Act 2022, updated RICS guidance on the EWS1 process, and shifting lender expectations has fundamentally changed what building surveyors must assess, report, and communicate when instructed on medium-rise residential blocks. Understanding Fire Safety in Medium-Rise Blocks: What Building Surveyors Must Now Report Under the EWS and Building Safety Regime is no longer optional — it is a professional and legal obligation.
Key Takeaways 📋
- 11–18 metre blocks now sit firmly within the scope of lender EWS1 requirements and the Building Safety Act's broader accountability framework.
- Surveyors must identify, describe, and flag external wall materials, cladding systems, balcony construction, and cavity barriers — even where a full EWS1 is not within their remit.
- An EWS1 form is still required by most lenders for medium-rise blocks where combustible cladding or balconies are present or suspected.
- Failure to communicate limitations clearly in a survey report creates professional liability under RICS standards.
- Buyers, lenders, and leaseholders all rely on surveyor reports to make critical financial decisions — accuracy and transparency are non-negotiable.
Understanding the Regulatory Landscape for Medium-Rise Blocks
The Building Safety Act 2022 and the 11–18 Metre Threshold
The Building Safety Act 2022 introduced a tiered system of oversight based on building height. Buildings over 18 metres (or seven storeys) are classified as "higher-risk buildings" and are subject to the most stringent controls, including mandatory registration with the Building Safety Regulator. However, the Act also introduced duties and accountability measures that affect buildings in the 11–18 metre range, particularly around fire safety remediation, the Building Safety Fund, and leaseholder protections.
For medium-rise blocks specifically:
- Leaseholders cannot be charged for cladding remediation costs where the landlord or developer is responsible under the Act.
- Qualifying leaseholders (those who own their main home or have owned no more than two other properties) receive additional protections on non-cladding remediation costs.
- Responsible persons — typically building owners or managing agents — must take active steps to assess and address fire risks.
This matters to surveyors because a building survey or valuation report that ignores these obligations may leave a buyer exposed to significant financial and safety risk.
What Changed with EWS1 After Grenfell
The External Wall System (EWS1) form was introduced by UK Finance and the Building Societies Association in December 2019 following the Grenfell Tower fire. It was designed to give lenders confidence that a building's external wall construction had been assessed by a qualified professional.
Initially, EWS1 requirements were applied broadly — even to low-rise buildings with no cladding. Following RICS guidance updates, the scope was refined. As of 2026, the key position is:
"An EWS1 form is required where a building has cladding or has balconies with combustible materials, regardless of height — but lenders may apply their own thresholds."
For medium-rise blocks in the 11–18 metre range, most major lenders still require an EWS1 where external wall systems include anything other than brick, stone, or concrete. This includes:
| Material Type | EWS1 Likely Required? |
|---|---|
| Aluminium Composite Material (ACM) | ✅ Yes — always |
| High-Pressure Laminate (HPL) panels | ✅ Yes |
| Timber cladding or render on combustible substrate | ✅ Yes |
| Brick or stone with no combustible insulation | ❌ Generally not |
| Balconies with timber decking or glass balustrades | ✅ Yes — check lender policy |
| Brick with combustible insulation behind | ⚠️ Depends on lender |
Fire Safety in Medium-Rise Blocks: What Building Surveyors Must Now Report
The Surveyor's Core Reporting Obligations
When conducting a RICS building survey or a Level 3 Building Survey on a flat within a medium-rise block, surveyors face a specific set of reporting duties that go well beyond checking for damp or structural movement.
Surveyors must now:
- Identify the external wall system — including cladding type, substrate, and insulation where visible or inferable from age and construction type.
- Note the presence of balconies and describe their construction materials, including decking, balustrades, and any visible fixings.
- Check for an existing EWS1 form — and report its category rating (A1, A2, B1, or B2) and whether it is in date.
- Flag the absence of an EWS1 where one is likely to be required by lenders, and explain the implications for mortgage finance.
- Describe visible fire safety features — including sprinkler systems, fire doors, compartmentation, and signage — to the extent visible during a non-invasive inspection.
- Communicate limitations clearly — a surveyor cannot open up walls or inspect cavity barriers, and this must be stated explicitly.
EWS1 Categories Explained
The EWS1 form uses a lettered and numbered rating system:
- A1 — No cladding or attachments requiring assessment. Lowest risk.
- A2 — Cladding present but assessor satisfied it meets acceptable standards.
- B1 — Cladding present; remediation may be needed but building is safe to occupy.
- B2 — Cladding present; remediation is required. Most lenders will not lend on a B2 rated building.
A surveyor completing a homebuyer survey or a RICS Home Survey is not completing the EWS1 — that is a separate, specialist process carried out by a qualified fire engineer or façade engineer. However, the surveyor must signpost the need for one and explain what the rating means for the buyer's ability to obtain a mortgage.
Balconies: A Frequently Overlooked Risk 🔥
One of the most significant changes in lender and regulatory expectations concerns balconies. Many medium-rise blocks built between 2000 and 2015 feature balconies with:
- Timber decking
- Glass balustrades with aluminium frames
- Combustible waterproofing membranes
These can create a fire spread pathway even where the main façade is non-combustible. RICS guidance confirms that balconies with combustible materials are a trigger for EWS1 requirements, regardless of the main cladding system.
Surveyors must visually inspect and describe balcony construction in their reports, note any materials that appear combustible, and flag the EWS1 implications. This is particularly important for blocks in urban areas — for example, those served by chartered surveyors in East London or chartered surveyors in Battersea, where high-density medium-rise development is common.
When Is an EWS1 Still Needed in 2026?
Lender Requirements Have Not Gone Away
Despite some commentary suggesting that EWS1 requirements were being relaxed, the reality in 2026 is more nuanced. The RICS EWS1 guidance clarified that the form is not required for buildings without cladding — but lenders retain the right to request one where they have concerns.
Key scenarios where an EWS1 is still required:
- 🏢 Any medium-rise block with non-masonry cladding
- 🔥 Blocks with combustible balcony materials
- 📋 Buildings where a previous EWS1 has expired or is under review
- 🏦 Where the specific lender's policy requires one (always check)
- ⚠️ Where the building is subject to a remediation order or is on the Building Safety Fund register
Surveyors should not assume that because a building is below 18 metres it will not require an EWS1. Many lenders apply their EWS1 requirements to all buildings with cladding, regardless of height.
What Happens When There Is No EWS1?
Where no EWS1 exists and one is likely required, the surveyor must clearly state in the report:
- That the absence of an EWS1 may prevent mortgage lending
- That the buyer should seek confirmation from their lender before exchange
- That specialist fire engineering advice should be obtained
- That the cost and timeline for obtaining an EWS1 can be significant
This is not a minor caveat — it is material information. A buyer who proceeds without this warning may find themselves unable to sell or remortgage in future.
Fire Safety in Medium-Rise Blocks: Communicating Limitations in Survey Reports
The Professional Liability Dimension
The RICS Rules of Conduct and the Home Survey Standard both require surveyors to be transparent about the scope and limitations of their inspection. For medium-rise blocks, this is especially important because:
- External wall construction is largely hidden behind finishes
- Cavity barriers and fire stopping are not visible without intrusive investigation
- The surveyor may be inspecting a single flat with no access to communal areas or the roof
A Level 3 Building Survey offers the most comprehensive assessment available through a non-invasive inspection, but even this cannot substitute for a specialist fire safety assessment. Surveyors must be explicit about this boundary.
Best practice wording in reports should include:
"This inspection is non-invasive and cannot confirm the composition of the external wall system, the presence or absence of cavity barriers, or the fire performance of insulation materials. Where the building has cladding or combustible balcony materials, an EWS1 assessment by a suitably qualified fire engineer is strongly recommended before exchange of contracts."
Stock Condition Surveys and Fire Safety
For housing associations, local authorities, and registered providers managing medium-rise blocks, stock condition surveys now routinely incorporate fire safety elements. These surveys assess:
- The condition and age of fire doors
- The presence and condition of sprinkler systems
- External wall condition and cladding type
- Compartmentation integrity (to the extent visible)
These assessments feed directly into planned maintenance programmes and Building Safety Case documentation required under the Act for higher-risk buildings — and increasingly expected for medium-rise blocks as best practice.
Roof Surveys and Fire Safety Connections
It is worth noting that flat roofs on medium-rise blocks can also present fire spread risks, particularly where combustible insulation or waterproofing membranes are present. A roof survey conducted as part of a broader building assessment should flag any materials that could contribute to fire spread, particularly where the roof is adjacent to or continuous with external wall systems.
Practical Steps for Surveyors Approaching Medium-Rise Instructions
A Pre-Inspection Checklist ✅
Before attending a medium-rise block, surveyors should:
- Research the building — check the Land Registry, planning portal, and any publicly available EWS1 or fire risk assessment data.
- Identify the construction era — buildings from 1980–2010 are most likely to have problematic cladding or insulation.
- Review the lease — understand who is the responsible person and whether any remediation works are planned or underway.
- Check the Building Safety Register — for buildings over 18 metres, but also check whether the block is subject to any enforcement notices.
- Confirm lender requirements — if acting in connection with a mortgage valuation, confirm the lender's specific EWS1 policy.
During the Inspection
- Photograph all external wall materials visible from ground level and from any accessible vantage points.
- Note balcony construction in detail — decking material, balustrade type, soffit finish.
- Inspect fire doors in communal areas where accessible.
- Check for signage indicating fire strategy (e.g., "stay put" vs. "simultaneous evacuation").
- Note any visible remediation works — scaffolding, cladding removal, or new panels being installed.
For complex or high-risk buildings, surveyors in areas with significant medium-rise stock — such as those offered by chartered surveyors in North West London or chartered surveyors in South West London — should consider whether a specialist structural survey or façade investigation is warranted and recommend this to the client.
Communicating with Clients
Clients buying flats in medium-rise blocks often do not understand the EWS1 process or its implications. Surveyors have a duty to explain:
- What the EWS1 is and why it matters
- Who pays for remediation (the Building Safety Act's leaseholder protections)
- What a B2 rating means for their ability to sell or remortgage
- What the timeline for obtaining an EWS1 might be (often 6–18 months in complex cases)
This communication should be in plain language. The goal is an informed client, not a legally protected surveyor.
Conclusion: Raising the Bar on Fire Safety Reporting
The regulatory and professional landscape for fire safety in medium-rise blocks has changed profoundly since Grenfell. In 2026, building surveyors operating under the EWS and Building Safety regime face clear and demanding expectations: identify external wall risks, flag EWS1 requirements, communicate limitations honestly, and ensure clients have the information they need to make safe financial decisions.
Actionable next steps for surveyors and buyers:
- 📌 Always check for an existing EWS1 form before or during the inspection.
- 📌 Never assume a medium-rise block is safe from EWS1 requirements because of its height.
- 📌 Use clear, specific language in reports about external wall materials and balcony construction.
- 📌 Recommend specialist fire engineering advice wherever there is doubt.
- 📌 Stay current with RICS guidance updates and lender policy changes — this landscape continues to evolve.
- 📌 Buyers should commission the most comprehensive survey available — a Level 3 Building Survey — for any flat in a medium-rise block with cladding or non-standard construction.
The stakes are too high for ambiguity. Clear, thorough, and honest reporting is not just good professional practice — it is the foundation of a safer built environment for everyone.
