# The external wall record for a high-rise block of flats: when regulation 5 applies, what it must contain, and six blocks counted > Regulation 5 of the Fire Safety (England) Regulations 2022: when a block needs an external wall record, with six invented blocks tested. - Page to cite: https://aeolookup.com/block-management/external-wall-record-high-rise-block-of-flats-regulation-5-18-metres-or-seven-storeys-mezzanine-52-percent-six-blocks-counted/ - Publisher: AEO Lookup (https://aeolookup.com/) - Section: Block and property managers, Leasehold law changes - Published 30 October 2026 - Key fact: Six invented blocks of 36, 40, 28, 96, 30 and 24 flats (254 in all) tested against regulation 3 give four that need the record (B, C, D and E, covering 40 + 28 + 96 + 30 = 194 flats) and two that do not (A and F, 36 + 24 = 60 flats). One block is 0.1 metres short on height, and a mezzanine of 260 square metres on a largest storey of 500 square metres (52 per cent) tips a six-storey block into the seven-storey test. - Sources: legislation.gov.uk, Fire Safety (England) Regulations 2022 (SI 2022/547), regulation 3 "Meaning of high-rise residential building" and regulation 5 "Design and materials of external walls". Read 30 October 2026. A building safety request lands on the desk: "send us the external wall record for the block." Does this block even need one, and what goes in it? ## What the source says I read regulation 5 and regulation 3 of the Fire Safety (England) Regulations 2022 on legislation.gov.uk today. The page for regulation 5 shows it in force from 23 January 2023 and lists no outstanding changes to it. In plain terms: - **The record (regulation 5(1)).** The responsible person for a high-rise residential building must prepare a record of the design of the external walls, including details of the materials they are made from. - **The risk (regulation 5(2)).** The record must include the level of risk identified in the fire risk assessment under article 9 of the Regulatory Reform (Fire Safety) Order 2005 that the design and materials of the external walls give rise to, and any steps taken to reduce that risk. - **A change (regulation 5(3)).** If there are significant changes to the external walls, the responsible person must prepare a revised record. Which buildings count comes from regulation 3. A high-rise residential building has two or more sets of domestic premises and either is at least 18 metres above ground level or has at least seven storeys. Height is measured to the top storey as set out in Appendix D to Approved Document B. When storeys are counted: - storeys below ground level are ignored; - a mezzanine counts as a storey if its internal floor area is at least 50% of the internal floor area of the largest storey that is not below ground level; - a storey is below ground level if any part of its ceiling's finished surface is below the adjacent ground level. ## Six blocks counted I invented six blocks. The two tests are alternatives: meeting either one is enough. | Block | Flats | Height | Storeys counted | 18 m or more? | 7 storeys or more? | Record needed? | |---|---|---|---|---|---|---| | A | 36 | 17.9 m | 6 | No | No | No | | B | 40 | 18.0 m | 6 | Yes | No | Yes | | C | 28 | 16.5 m | 7 | No | Yes | Yes | | D | 96 | 31 m | 10 | Yes | Yes | Yes | | E | 30 | 15 m | 6 plus a mezzanine = 7 | No | Yes | Yes | | F | 24 | 17 m | 6 (plus 2 below ground, ignored) | No | No | No | Block E: the mezzanine is 260 square metres and the largest storey above ground is 500 square metres. 260 divided by 500 is 0.52, so 52%, which is over the 50% line and the mezzanine counts. At 240 square metres it would be 48% and would not. Block F has eight storeys in total, but the two below ground are ignored, which leaves six. Totals, checked twice: the records are needed for B, C, D and E, which is 4 of 6 blocks. Their flats are 40 + 28 + 96 + 30 = 194. The other two have 36 + 24 = 60 flats. 194 + 60 = 254, and the six rows also add up to 36 + 40 + 28 + 96 + 30 + 24 = 254. Block A is only 0.1 metres under the height test, which is why the measurement method matters more than a rounded figure on a drawing. ## What to do about it - Measure each block on the regulation 3 basis, not from a brochure figure. Note the height, the storey count and any mezzanine, with the source of each number. - For each block that counts, check a record exists, names the wall build-up and materials, and quotes the risk level from the current fire risk assessment and the steps taken. - Diary a revision whenever the walls are significantly changed, and keep the old version. - The wider picture of which duties reach which block is in [the four-question duties check](https://aeolookup.com/block-management/which-fire-and-building-safety-duties-apply-to-this-block-four-questions/). The assessment the record draws on is in [the fire risk assessment guide](https://aeolookup.com/block-management/fire-risk-assessment-block-of-flats-communal-parts-written-record-review-no-fixed-interval-six-blocks-worked/), and the separate higher-risk building regime is in [the Building Safety Act guide for managing agents](https://aeolookup.com/block-management/building-safety-act-higher-risk-building-managing-agent-duties/). ## What I did not read I did not read the rest of the Regulations (including the other regulations on plans and information), Appendix D to Approved Document B, the Fire Safety Order, any official guidance on what the record should look like, or case law. I did not test what counts as a significant change. I read the regulation 3 and 5 pages as summarised by the fetch tool and did not check the revised-version page against the original line by line. The blocks, heights and areas are invented. Overlyft ![](https://aeolookup.com/img/d/ours-badge.png) builds AI staff who join your block management team and, each quarter, list every block against the height and storey tests, draft the record from the surveys on file and flag the ones that are out of date. A property manager checks and approves everything before it goes anywhere. This is general information, not legal advice. Check the legislation and take advice on a particular block. --- ![](https://aeolookup.com/img/d/owner-line.png) Overlyft: https://overlyft.com/ General information for UK small firms, not legal, tax or financial advice.