Two pieces of legislation govern the matter. DM 9 April 1994 is the technical fire prevention rule for tourist-hotel accommodation businesses, and it sets out what the building must have, including the fire reaction requirements for upholstery and furnishing materials. DPR 151/2011, on the other hand, sets out which administrative procedure applies, and lists accommodation businesses with more than 25 beds under activity no. 66 of its Annex I, which are subject to Fire Brigade inspections and to the fire safety SCIA (certified start-of-activity notice).
The 25-bed threshold is the watershed that separates two different administrative paths, and the question every hotelier asks sooner or later is whether staying below that threshold also changes how you furnish the property.
The short answer only concerns the administrative procedure: a fire behaves the same way in a ten-bed property as in a hundred-bed one. The long answer means putting the two cases side by side.
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DM 9 April 1994 and DPR 151/2011: the two fire safety rules for hotels
The 1994 technical rule answers the question of what to build: construction features, escape routes, systems, and the fire reaction of materials and furnishings.
DPR 151/2011 answers the question of which procedure to follow. Above 25 beds, the property falls under activity no. 66: project assessment where required, SCIA before opening, subsequent inspections, and periodic renewal of compliance. The same decree divides activities into categories A, B and C according to complexity and risk, and that classification determines whether a preliminary project assessment is needed. The classification is made by the fire safety professional appointed to the case.
Alongside these two texts, workplace safety legislation still applies, requiring the employer to carry out a fire risk assessment, train staff and manage emergencies. This obligation doesn’t look at bed numbers: it exists for an eighty-room hotel just as it does for a bed and breakfast with one employee.
Other decrees, articles and clauses are deliberately left out of this page. For a specific case, the answer comes from the professional who signs off on the paperwork.
Hotels with more than 25 beds: fire safety SCIA and furniture documentation
Under activity no. 66, furniture documentation goes into a file that someone will actually read. When filing the SCIA, the appointed technician collects and attaches the declarations for upholstered items and covering materials, and if one piece is missing, the paperwork doesn’t close. What catches people out is the timing: those documents are needed before opening, that is, once the hotel already has its rooms full of furniture and bookings open.
On furnishings, the fire brigade’s requests are recurring: type approvals for upholstered items with a legible number, fire reaction certificates for the coverings installed in rooms, corridors, stairs and communal areas, a supplier’s declaration of conformity referring to the actual supply, a declaration of correct installation where relevant, and correspondence between what is declared and what is physically present. It’s the last point that trips up most properties, because the documents exist, but they describe different furniture.
For upholstered items, the requirement is Class 1 IM, referring to the tested combination of frame, padding and covering. Class 1 IM is obtained through a small-flame test applied to the padding and covering together, and simply changing the fabric is enough to invalidate it.
A clarification on where responsibilities lie: sizing the escape routes and carrying out the fire risk assessment are the fire safety professional’s job. The furniture supplier’s job is to ensure the products meet the requirements and are documented in a way that can be traced back to the delivery.
Hotels and B&Bs with up to 25 beds: which obligations still apply to furniture
A property with up to 25 beds doesn’t file the fire safety SCIA, doesn’t receive the periodic inspections of activity 66, and has no renewals to schedule. For a bed and breakfast or a small agriturismo, this is a genuine relief.
What still stands is less visible, but it carries weight in four directions.
The first is insurance. Fire policies look at the compliance of furnishings at the moment there’s a claim. A B&B with twelve beds where a fire starts from a sofa lacking the required specifications ends up discussing it with the loss adjuster, not with the Fire Brigade, and that discussion happens once the damage is already done.
The second is growth. Many properties start out below the threshold and cross it with an extension, or with two rooms carved out of the loft. Those who furnished with approved upholstered pieces simply add rooms; those who didn’t have to redo the existing ones too.
The third is the operator’s liability towards guests, which the absence of a procedural obligation doesn’t erase. If people are harmed, choosing furniture without fire reaction requirements is a factor that can be taken into account.
The fourth is regional legislation and municipal regulations on accommodation businesses, which in several regions set their own requirements even below the threshold. These need to be checked with the local technical office before buying, because they come from a different direction to fire prevention rules.
Approved furniture below and above the threshold: what’s worth doing
Above 25 beds there’s no real choice to make: approved furniture and documentation referring to the specific supply are the condition for opening, and the question is about timing, not whether to do it. The right moment is the specification stage, when the fabric is being chosen and making a change costs nothing.
Below 25 beds the choice does exist, and our recommendation is to comply on upholstered items regardless. The reasoning is arithmetic before it’s precautionary: on a small-scale supply, the premium for approved upholstered items sits roughly between 5% and 15%, which on six rooms amounts to a few hundred euros. Fire reaction certification carries little weight in the overall cost of furnishing a hotel, which remains determined by floor areas, finishes and the level of customisation.
An intermediate case deserves a different answer: a below-threshold property with no plans to grow that is only renewing curtains and fabric coverings. There, a fireproofing treatment carried out by a specialist company, documented and scheduled, is a proportionate route. Not for upholstered items, though, for reasons that lie inside the foam before they lie inside the regulation.
| Over 25 beds | Up to 25 beds | |
|---|---|---|
| Activity subject to Fire Brigade inspection | Yes, activity no. 66 under DPR 151/2011 | No |
| Fire safety SCIA | Yes | No |
| Periodic inspections and renewal | Yes | No |
| Employer’s obligations on fire risk | Yes | Yes |
| Requirements of the 1994 technical rule | Applicable | Reference for good practice |
| Regional and municipal regulations | To be checked | To be checked |
Escape routes in hotels: when a piece of furniture becomes a non-compliance
Escape routes are the path that takes people from their room to the outside. They must have an adequate usable width, be signed and lit even during an emergency, stay clear, and be built with low fire-reaction materials. This is where furniture comes into play in two ways.
The first is bulk. The corridor is wide enough on paper, then a service cupboard, a planter, a console table or a wardrobe door opening outwards reduces the actual passage. The width that counts is the clear width measured at the narrowest point, not the width of the wall opening. The same goes for temporary clutter: housekeeping trolleys, spare chairs from the breakfast room, packaging from a delivery in progress. It’s more a management issue than a furnishing one, and it’s the first thing an inspection finds.
The second is the finish. The corridor is where the interior designer would want soft carpet and warm wood panelling, and it’s also the part of the building with the strictest fire reaction requirements, on both horizontal and vertical surfaces. Materials that combine the desired look with the required class do exist, and they don’t necessarily cost more, but they need to be sought out at the design stage, not once the covering is already fitted. A corridor leading to an exit is an escape route even if no one on site has ever called it that.
On projects carried out while the hotel stays open, it’s worth putting in writing with management where materials are stored, for how many hours, and who clears the corridor at the end of the day. It’s one of the things settled together with the installation sequence.
Rigid furniture, communal areas and the fire safety document chain
Wardrobes, bedside tables, desks, minibar units and counters aren’t upholstered items and don’t carry IM type approval. They matter for surface finish when they form large continuous wall surfaces, and they matter for bulk along escape routes. Technical data sheets for panels and finishes should still be requested and kept, because a technician needs them when reconstructing what a corridor’s fitted walls are made of. The areas with the most upholstered pieces remain the lobby, the lounge and the breakfast room, which are also the busiest spaces: that’s where a sofa bought without approval, to save money, opens up the biggest documentation gap. The contract-grade ranges for these spaces are gathered on the communal areas page.
As for the documents, the chain has four links. The manufacturer obtains type approval for the combination from an authorised laboratory. The supplier who delivers issues a declaration of conformity referring to the specific supply, with order reference, model, quantity, covering and date. Whoever installs the covering materials issues, where required, a declaration of correct installation. The property gathers everything into its fire safety file.
The link that most often breaks is the second one: the supplier delivers, gets paid, and the declaration referring to that specific supply never arrives, or arrives as a generic photocopy of a catalogue type approval. In refurbishments carried out in batches, the problem multiplies, because every delivery has its own traceability of fabric and padding and needs its own document.
A practical measure that resolves most cases: making delivery of the documentation a condition for the final payment. It puts order into the sequence, and a supplier working properly has no reason to object. Every upholstered item installed in a room should come with its fire-resistance certificate, showing the fire reaction class, brand, model and reference to the material’s type approval.
Frequently asked questions about fire safety regulations for hotel furniture
My hotel has 30 beds, am I subject to the fire safety SCIA?
Yes. Tourist-hotel accommodation businesses with more than 25 beds fall under activity no. 66 of Annex I to DPR 151/2011 and are subject to fire prevention procedures, including filing the SCIA before opening. The paperwork must be prepared by a fire safety professional, who also gathers the furniture documentation.
Which regulation sets the fire safety requirements for hotel furniture?
The reference technical rule for tourist-hotel accommodation businesses is DM 9 April 1994, which governs, among other things, the fire reaction of covering materials and the characteristics of upholstered furniture. DPR 151/2011, on the other hand, establishes which activities are subject to Fire Brigade inspection and under which administrative procedure.
Does a B&B with 10 beds have to use approved upholstered furniture?
It’s not subject to the SCIA for activity no. 66, but the employer’s safety obligations and any regional or municipal requirements still apply. In practical terms, approved upholstered items have little impact on the budget of a small property, they provide protection in the event of a claim, and they don’t need to be redone if the property crosses the threshold through an extension.
What am I risking if I don’t have the furniture documentation?
During the SCIA process, the paperwork won’t close and opening can be held up. During an inspection, you’ll receive requirements with a deadline to comply, which can go as far as requiring the furniture to be replaced. In the event of a claim, the lack of documentation is a factor assessed by the insurance company and when establishing liability.
Do wardrobes and desks need to be certified?
Rigid furniture doesn’t fall under Class 1 IM, which applies to upholstered items. It can, however, matter for surface fire reaction when it forms large continuous wall coverings, and in any case it must not reduce the clear width of escape routes. It’s still worth getting the technical data sheets for panels and finishes.
Do curtains and carpet fall under Class 1 IM?
No. Curtains, carpet and fabric wall coverings aren’t upholstered items: they follow the fire reaction classification for materials, with stricter requirements along escape routes. For these elements, fireproofing treatment carried out by a specialist company is permitted, though it has limited validity over time and must be documented and renewed.
Who decides whether my hotel falls into category A, B or C?
Placement in the categories set out by DPR 151/2011 depends on the complexity and risk level of the activity, and is determined by the fire safety professional handling the case. That placement determines the administrative path, in particular whether a preliminary project assessment by the provincial command is needed before carrying out the works.
