Q1. Does NCP 109 ban the use of magnetic locks?
No. NCP 109 does not ban magnetic locks. However, their use must be carefully assessed against the door’s role within the fire and escape strategy.

Magnetic locks may be acceptable on certain doors where the door is not required to comply with BS EN 179, BS EN 1125, or BS EN 13637, or where their method of operation still allows escape to be achieved by a single, simple action without the use of a key or specialist knowledge (e.g. unaccompanied visitors).

Where a door is required to meet BS EN 179 or BS EN 1125, for example, where mechanical emergency or panic escape hardware is already fitted, retrofitting a magnetic lock that requires an additional action (such as operating a separate
“press to exit” button or break-glass unit before pushing the door) would not
comply with those standards and may compromise life safety.

Approved Document B in England permits electrically powered locking devices, including magnetic locks, provided they fail safe on fire alarm activation, loss of power, and via an appropriate override device (breakglass), in accordance with BS
7273-4 and the site-specific fire strategy. These conditions must be clearly understood, correctly implemented, and fully documented at the design stage.

In all cases, the suitability of a magnetic lock depends on:

• the door’s function,
• its existing or planned certification,
• its position within the escape route,
• the documented fire and escape, strategy for the premises, and
• the knowledge of users.

NCP 109 allows a range of locking solutions, including magnetic locks, rim releases, solenoid bolts, shear locks and electromechanical latches.
The key is that the lock must be appropriate for the door’s use, the escape strategy and the fire risk assessment.
The risk assessment should clearly show why the chosen lock is suitable and how it supports safe egress.

If a door functions as an emergency or panic exit and is already equipped with a device certified to BS EN 179 or BS EN 1125, the escape mechanism is mechanical, single-action and will operate even during a power failure. Any access control added to these doors must also comply with the same standards.

Where no existing hardware is installed (i.e., the door is free-flowing), the selection of a locking system should be based on a risk assessment and the building occupancy type, and may require integration with the fire alarm system in accordance with BS 7273-4.

If egress control is required and EN179, EN1125 compliance is determined as required (for example, where readout is required on an escape door), the system must also comply with BS EN 13637.

BS EN 179 and BS EN 1125 are not new at all, they were first published in the 1990s and became widely adopted in the early 2000s as the recognised standards for emergency and panic exit devices. They became even more significant when the Construction Products Regulation (and previously the Construction Products Directive) made them harmonised standards, requiring CE-marked, tested escape hardware for relevant door sets. BS EN 13637 arrived later, in 2015, to provide a standard for electrically controlled exit systems where controlled egress is required. In essence, BS EN 13637 is optional as it only needs to be applied if you want to control egress from the building.

The reason many people are only hearing about these standards now is not that the standards have changed, but because the industry has changed, and awareness around escape from buildings in emergencies has changed. Access control is far more common today than when many buildings were originally designed. As installers add electronic locking to more escape doors, the interaction between access control, Building Regulations, fire strategies and EN escape hardware has become much more important. In addition, BS 7273-4 was amended in 2023 and now includes a reference to BS EN 13637. NCP 109.4 brings these long-standing requirements together and requires them to be considered during system design, which is why they are being discussed more widely. In short, the standards have been in place for decades; what’s new is the increased awareness, the growth in electronic locking, and the greater need to demonstrate compliance clearly and consistently.

That is certainly not the intention; NCP 109 is designed to help installers, not restrict them. It gives guidance on how to make safe and compliant choices and provides documentation to prove that work meets legal and technical standards.
It may prevent the wrong or cheapest solution from being fitted when that would risk safety or non-compliance, but the goal is to protect both installers and their clients.

Always check the door manufacturer’s certification and instructions.
Any drilling, cutting or component changes outside that approval can damage the door’s fire integrity and invalidate its certificate.
Use compatible hardware and keep written confirmation or test evidence to show that the door’s performance is maintained.

Systems installed under earlier versions of NCP 109 can continue to be maintained as originally designed, provided they remain safe, suitable and compliant with current legal requirements, including the Fire Safety Order and Building Regulations.

However, when maintaining an older system, the installer must still follow the principles of NCP 109.4. This means:

• Identifying any risks created by building changes since the original installation
• Checking that the system is still appropriate for today’s escape strategy and occupancy
• Highlighting any non-compliant hardware or configurations that would not meet current standards (i.e. 2 action escape)
• Documenting findings and advising the Responsible Person of any recommended improvements

Maintenance does not mean ignoring new safety expectations.
Installers should not automatically upgrade a system, but they must inform the client where an older design now presents a risk or falls short of current requirements.

If the building has changed, such as new fire doors, altered escape routes, modified door hardware or updated fire strategies, the installer must reassess the access control system to ensure it still operates safely and compliantly.

This includes checking:

• Whether the existing locking hardware is compatible with the new door set certification
• Whether EN 179, EN 1125 or EN 13637 now applies due to the change in use or occupancy
• Whether BS 7273-4 release requirements are still met
• Whether the system continues to support single-action escape where required
• Whether any older equipment now creates a safety or compliance gap

If any issues are found, the installer must clearly inform the Responsible Person and advise on corrective actions.
The system does not have to be replaced automatically, but it must remain safe, suitable, and compliant in the context of the upgraded building.

Yes. Under NCP 109 Issue 4, the installer or system designer remains responsible for competently assessing each door and ensuring that the access-control solution is appropriate, safe, and aligned with the site-specific fire and escape strategy, regardless of whether the client has specified a preferred lock type or
technology.

The reason for this is simple: the door’s function and designed purpose determine which standards apply, not the product preference. Client specifications may be incomplete, based on assumptions, or focus on security rather than life safety and compliance.

As part of a competent assessment, the installer should determine and document:

• whether the door forms part of an escape route,
• the occupancy type (staff only, public, or mixed use),
• whether the door is a fire-resisting doorset or part of a compartment line,
• whether BS EN 179 or BS EN 1125 applies,
• whether controlled egress is required and therefore BS EN 13637 is applicable,
• whether any existing mechanical hardware is compatible with electronic access control,
• and whether any proposed solution would introduce more than one action to escape.

Where a client specifies a lock type or solution that conflicts with the applicable standard or the fire and escape strategy, the installer should challenge this at the design stage and clearly explain the implications for safety and compliance.

If the client, Building Control body, or Responsible Person elects to proceed with an alternative approach, that position - including any limitations, deviations, or assumptions - must be formally documented. Provided the installer has delivered against the client’s documented requirements, captured the associated risks, and defined the scope of compliance, certification may be issued within that scope. However, installers should not knowingly implement a solution they believe to be unsafe or non-compliant.

Where uncertainty remains or conflicting opinions arise, installers should default to the safest applicable standard and seek clarification from Building Control, the Responsible Person, a fire risk assessor, or a competent fire safety consultant before proceeding.

Yes. When it comes into force, Martyn’s Law (Protect Duty) is likely to influence how organisations assess risk and design access control systems, particularly in publicly accessible locations. While the legislation will not change the technical escape standards themselves, such as BS EN 179, BS EN 1125, BS EN 13637 or BS 7273-4, it will place stronger emphasis on security risk assessments, protective measures, and the ability for buildings to implement effective dynamic lockdown procedures.

This means more sites may need to review whether controlled egress is appropriate, whether certain doors should support lockdown functionality, and whether electronic systems need to integrate with wider security plans. Where controlled egress is justified on an escape route, BS EN 13637 remains the only compliant route for providing single-action escape while still allowing electronic control. Installers may therefore find greater demand for solutions that balance both life safety and security requirements.

Importantly, Martyn’s Law will not override or relax life-safety expectations. Escape must still be possible in one action, and Building Regulations, the Fire Safety Order and EN standards continue to apply. What Martyn’s Law adds is a heightened duty to document decisions, justify chosen locking methods, and clearly demonstrate that both safety and security have been considered together. This strengthens the value of using NSI Certified companies who can evidence competence and robust risk-based system design.

A hide-in-place strategy works effectively with doors fitted with EN 179 or EN 1125 hardware, where the access control only manages entry, and the escape function is entirely mechanical (turn the handle/push the bar). In this configuration, the door does not rely on power to open in an emergency, so it does not automatically unlock when the fire alarm activates. This allows the space to remain secure during a hide-in-place or dynamic lockdown situation while still ensuring that people inside can always escape in a single action if needed.

Because the escape action is mechanical, these doors remain compliant with Building Regulations, the Fire Safety Order, and the EN standards, while also avoiding the risks associated with fail-safe unlocking. This makes EN 179/1125 hardware with controlled entry an ideal solution for environments that must balance both rapid fire evacuation and secure lockdown, such as schools, offices, healthcare rooms and other publicly accessible spaces.