COVER THAT CLOSES THE GAP: Insurance across the fire door supply chain

Fire doors are among the most scrutinised elements of building safety in the UK, yet they remain one of the least compliant. According to the Fire Door Inspection Scheme’s (FDIS) latest publicly available inspection data, based on more than 100,000 inspections, 75% of fire doors failed to meet the required standard¹. The most common issues were excessive gaps around the frame (77% of failures), poor maintenance (54%) and defective smoke seals (37%), while nearly a third (31%) were linked to incorrect installation². More concerning still, the industry has made little progress: the failure rate has barely shifted since FDIS’s 2019 survey, which found that 76% of inspected fire doors were non-compliant³

This context is particularly significant from an insurance perspective. Each fire door defect can be attributed to a specific party within the contractual chain of responsibility, including manufacturers, designers, installers, inspectors, and building owners responsible for ongoing maintenance. The Building Safety Act 2022 has materially heightened the legal and financial consequences associated with non-compliance, replacing the previous maximum £5,000 fine for breaches of building regulations with the possibility of unlimited fines and custodial sentences of up to two years⁴. In addition, it extended the limitation period for enforcement action in respect of non-compliant work from one year to ten years. It also introduced provisions for personal criminal liability for directors and managers where offences are committed with their consent, connivance, or neglect.

Against this backdrop, Professional Indemnity (PI) insurance becomes a central mechanism for transferring exposure arising from fire door- related advice, design, certification, and inspection activities, alongside Public and Products liability and a range of more peripheral covers. This article examines how these insurance arrangements respond to that evolving risk landscape, and where material gaps in cover tend to arise.

Professional Indemnity insurance

PI responds to claims arising from professional advice, design, specification, certification, or inspection. In essence, it covers the “intellectual” rather than physical components of fire door work. Any party within the fire door supply and assurance chain that issues surveys, certificates, specifications, fire risk assessments or design recommendations typically requires PI cover, and it is now routinely a tender prerequisite.

When reviewing existing policies, four features are particularly worth considering:

1. Aggregate versus any one claim limits: A single building with a systemic defect, such as wrong cores, incorrect intumescent strips, or gaps beyond tolerance, can generate dozens of individual claims from one root cause. An aggregate limit means one bad project can exhaust the entire year’s cover.
2. Contractual liability and conditions precedent: Fire door contracts increasingly include enhanced indemnities, “fitness for purpose” obligations, or specific certification requirements (e.g. BWF Certifire, Q-Mark or other third-party accreditation schemes). Standard PI wordings often exclude liabilities assumed under contract that go beyond the common law duty of care. If your contracts commit you to more than your policy covers, your business may be carrying that uninsured exposure.
3. Retroactive date: Where PI is purchased after a period of trading or following a change of insurer, the retroactive date becomes critical and needs checking carefully. Fire door defects may remain latent for years, often emerging during post-incident investigation or later fire risk assessments. Work completed prior to the retroactive date is typically excluded in full.
4. Runoff cover: As PI is written on a claims-made basis, cover ceases when the policy lapses unless run-off arrangements are explicitly secured. This is particularly relevant in cases of business closure, merger, retirement, or sale, where historic liabilities may still emerge long after trading has ceased.

These exposures also underline the importance of documenting not only what defects were identified, but how they were communicated.

Identifying a defect is only part of the professional obligation; firms must be able to demonstrate that risks, limitations and recommended remedial actions were clearly communicated to the client.

With limitation periods under the Building Safety Act extending as far as 30 years in certain circumstances⁵, inspection reports, certification records, maintenance logs and correspondence may prove critical in evidencing what was known, what advice was given and where responsibility lay at the time.

The PI market has also shifted materially in recent years. Following a prolonged hard market, conditions have softened and insurers are generally showing a greater willingness to engage with fire safety-related risks.

Full fire safety exclusions are now, thankfully, rare rather than standard. This is positive for buyers, but it cuts both ways. Softer terms make it easier to negotiate the wording fixes above, but they also mean firms renewing on autopilot may be retaining legacy gaps where improved terms are now available to address them.

Liability and the efficacy problem

Public and Products Liability insurance responds to third party injury or property damage caused by your work or product. This is straightforward when the damage physical and the cause is obvious.

Fire doors present a more complex risk profile because their function is passive: they are designed to remain inert until the moment they are needed. If they fail at that moment, the resulting damage is caused by the fire, the smoke and the building, not by the door itself in any conventional sense. The door’s failure is a failure to prevent harm, rather than an active cause of it. This is the efficacy problem, and it is where standard liability wordings tend to fall short.

Many liability policies draw a distinction between causing damage and failing to prevent it. Where a product or service does not perform its intended function, and there is no separate physical damage to trigger cover, insurers may seek to treat the claim as falling outside
the scope of the policy. In practice, this can mean that where a fire door fails to achieve its rated 30-or 60-minute performance due to specification or installation defects, resulting in fire or smoke spread, insurers may characterise that as
a pure efficacy failure claim, falling outside what the liability policy was written to cover.

This is a frequent source of coverage dispute. While PI may respond where professional advice or design input is implicated, parties operating without PI, or those facing allegations of defective manufacture or installation, may find that neither PI nor liability policies respond cleanly. This can result in a policy trigger, creating uncertainty between insurers regarding causation, leaving a dispute over which policy should respond, if either.

Practical implications

To mitigate these exposures, several policy considerations are critical:

• Ensure liability wordings are reviewed for explicit or silent Efficacy exclusions.
• Where PI and liability policies are placed separately, have your broker provide you with the confidence that both wordings are reviewed in conjunction rather than in isolation, as gaps love to live in the seams between policies.
• For manufacturers
  and suppliers, confirm whether Products Liability extends to the costs of removal, replacement, or rectification of defective fire door systems (often referred to as “Product Recall” or “Rectification cover”). In high-rise environments, replacement costs can significantly exceed the value of the components themselves.

A useful diagnostic question is whether your broker can clearly explain how your policies would respond to a scenario in which a fire door fails to achieve its rated performance during a fire event.

If this can’t be articulated succinctly, it’s indicative of unresolved coverage ambiguity that needs to be reviewed before renewal, not after a claim.

Wider cover considerations

Management Liability/Directors & Officers insurance: In light of the Building Safety Act 2022, directors, managers and other officers may be prosecuted alongside the corporate entity where an offence is committed with their consent, connivance or as a result of their neglect, with exposure to unlimited fines and custodial sentences.⁶ Standard management liability policies may provide cover for defence costs arising from regulatory investigations and prosecutions, but limits and whether criminal defence costs are included at all, vary considerably. For directors of fire door manufacturers, installers or inspection bodies, this is no longer a peripheral consideration.

Cyber insurance: Increasingly relevant for firms holding digital compliance records, certification databases, golden thread documentation and any element of personal data. A ransomware attack that locks a firm out of its fire door inspection records ahead of a Building Safety Regulator audit creates its own compliance problem on top of the IT one.

Three questions worth putting to a broker now, rather than after a claim:

1. How are we covered for Efficacy, on a silent or explicit wording basis?
2. Does the PI policy’s retroactive date reach back far enough, and what happens to it if the business stops trading?
3. If something goes wrong on a high-risk building, is a director personally covered for a Building Safety Regulator investigation?

For insurance purposes, the key question is often not just who installs and then owns the fire door, but who has the duty to inspect, maintain, certify, or advise on it when the defect arose. That party may ultimately bear responsibility for resulting losses or remediation costs.

Information Sources

1. Fire Door Inspection Scheme (FDIS) (2022) FDIS survey finds three-quarters of UK fire doors do not meet the required standard. Available at: https://www.fdis.co.uk (Accessed: 15 June 2026).
2. Ibid.
3. Fire Door Inspection Scheme (FDIS) (2020) Fire door inspection data 2019. Reported by LocalGov, 18 June 2020. Available at: https://www.localgov.co.uk (Accessed: 15 June 2026).
4. UK Government (2022). TSO@Blackwell and other Accredited Agents EXPLANATORY NOTES Building Safety Act 2022. [online] Available at: https://www.legislation.gov.uk/ukpga/2022/30/pdfs/ ukpgaen_20220030_en.pdf (Accessed 15 Jun. 2026).
5. Ibid.
6. Ibid.