From 18 May to 26 July 2022, a consultation exercise has been underway covering a package of proposals for the reform of fire and rescue services (FRS) in England, which includes three principal areas of vision: People, Professionalism and Governance. This exercise follows the challenging feedback raised in Sir Thomas Winsor’s HMICFRS State of Fire reports, which concluded that significant reform is required.

The Government’s white paper sets out its vision for fire reform. Whilst it intends to drive change and improvement, we understand this may cause uncertainty for our clients.

Find out how the proposed reform could affect you, and what FRS can do to prepare for potential changes to employment, leadership and governance structures.

The white paper can be accessed here.


The consultation questions the effectiveness of the National Joint Council – the body that oversees decisions on firefighter pay and terms and conditions. We anticipate there will likely be a departure from the current pay structure to one that is performance-focused, with standard progression routes and links pay to progression.

We anticipate our clients will make note of the remarks surrounding participation in industrial action (i.e. at page 13 that strikes put public and non-striking fire professionals at risk, and that robust continuity plans will be considered).

There will also be a review on whether the entry requirements for FRS roles might become more consistent. Currently there is no standardised national progression routes or consistent levels of education or experience required for entry into roles. The National Fire Chiefs’ Council is leading a project on direct entry schemes at station and area manager level; however, there is minimal detail so far on what the entry requirements could be. We consider there is also likely to be a focus on tackling the findings made in the HMICFRS State of Fire reports that the workforces of all FRS remain unrepresentative of the communities that they serve and further efforts are required to enable diverse recruitment. 


Building upon the reforms following the establishment of the National Fire Chiefs’ Council and Fire Standards Board, the consultation considers a new 21st century leadership programme, which could be made mandatory to complete before becoming an Assistant Chief Fire Officer or Chief Fire Officer. The HMICFRS State of Fire reports noted that currently not enough is being done to plan for future leaders, which is a particular issue following the recent high turnover of Chief Fire Officers. It also criticised a lack of talent management programmes and patchy development appraisals.

Overall there is a clear focus on improving the culture in FRS which undoubtedly follows the HMICFRS State of Fire reports. Although the consultation does not directly comment on the findings of toxic workplace cultures and bullying that was raised in the reports, it confirms there will be discussion on whether a statutory code of ethics and service oath should be implemented.


FRS can expect a major governance shift, possibly to a single, elected individual accountable for the service and the control of funding rather than governance by committee, although other options are explored in the consultation. Proposals include transferring responsibility for FRS in England to police and crime commissioners and associated boundary changes.

What to take away

  1. Take part in the consultation. A response on the consultation will be published on the Government website in due course. Unfortunately, it will be a matter of waiting for the response before any practical steps can be taken but organisations have until 26 July to issue their responses to the consultation.
  2. Review the current core code of ethics. Although the current code has no legal status, there is potential for a statutory code of ethics in the future. We recommend considering whether your internal policies and procedures accurately reflect the current code and the issues highlighted in the HMICFRS reports (e.g. improve processes and promote workforce diversity).
  3. We consider there is a possibility we will see the implementation of regulation standards for senior roles following the consultation (perhaps similar to the fit and proper person regulations that came into force for NHS trusts in 2014, requiring those organisations to seek assurances that all executives and non-executives directors are suitable and fit to undertake the responsibilities of their role). 

How Capsticks can help

We advise FRS on a variety of contentious and non-contentious matters. In particular, we regularly provide training on the Equality Act, learning culture, avoiding claims of discrimination, disciplinary and grievance procedures and responding to complaints.

If you would like to find out more about how we can support your organisation, especially following the issues highlighted in the HMICFRS reports, please get in touch with Alessandra Gettins or Anna Semprini for further information about how Capsticks can help.