The panels went up faster than the fire rules. 21RISK asks every site what it has installed, follows up only the questions that apply, and keeps the evidence on the same record as your COPE and values.
Green ambition has outrun fire safety in Danish industry. Codan's benchmark puts 85% of larger companies at high ESG ambitions and investments. The numbers below are what happens next.
Source: Codan, Risici i den grønne omstilling, September 2026.
A fire rarely comes from the panel or the battery alone. It comes from what they meet: combustible insulation, a critical store underneath, a roof the fire service can only reach from one side.
Those facts normally live with four different people. In 21RISK they sit on one site, next to the COPE data and the values you already keep for the renewal.
Rooftop PV, 420 kWp
Outdoor BESS, 1,000 kWh, LFP
Sandwich panels, PIR core
Array crosses one fire wall
BI €18.4M, 18 months
Finished goods store under the array
Roof access from one side
Emergency plan review expired
Read together: a fault on this roof reaches a combustible core, above the stock that carries the BI, with one way up for the fire service.
These are not bigger versions of a fire you already plan for. They behave differently, and they stop the business differently.
A PV array produces DC for as long as light reaches it. The switch makes the building side safe, not the roof. The fire service treats the array as live.
Once it starts in a cell, the battery makes its own heat and oxygen and gives off explosive, toxic gas. It can re-ignite hours or days later. Off-gas detection gave 5 to 20 minutes of warning in some FM tests.
Re-ignition and toxic gas often keep a building closed for 24 to 72 hours after the fire is out. The replacement price of the panels is rarely the big number. Lost production is.
These are the real 22 questions and the real rules. Tick what one site has installed. Add a combustible roof and watch the fire barrier question appear.
9 of 22 questions apply
4 come back with an expiry
It runs on a compliance standards board, on the sites you already have. No separate list, no separate tool.
Once a year each site confirms its PV, BESS and Li-ion UPS. Capacity, chemistry, the roof under the panels and who owns the installation go on the site record.
The declaration drives the board. A site with a ground-mounted array is not asked about fire walls on the roof. A site with nothing answers one question and is done.
Each answer asks for the document: the thermography report, the roof plan, the UL 9540A test. Yearly checks expire after 15 months at the latest and go back to the site.
| Questions | Odense | Aalborg | Malmö | Bergen | Tampere | Leeds | Ghent | Bremen |
|---|---|---|---|---|---|---|---|---|
| 1 Site declaration 1 | ||||||||
| 1.1 Solar PV, BESS and Li-ion UPS on site | ||||||||
| 2 Solar PV 9 | ||||||||
| 2.1 Handover documentation and commissioning record | ||||||||
| 2.2 DC isolation outside the building, signed and tested | ||||||||
| 2.3 Inverters outdoors or in a separate fire compartment | ||||||||
| 2.4 Cable routes and isolation points in the fire plans | ||||||||
| 2.5 Ground-fault alarm to a staffed location | ||||||||
| 2.6 Fire barrier or coating over a combustible roof | ||||||||
| 2.7 PV-free zone of 2.5 m at fire walls, distance to vents | ||||||||
| 2.8 Periodic inspection including thermography | ||||||||
| 2.9 Emergency shutdown procedure, staff instructed | ||||||||
| 3 Battery storage 12 | ||||||||
| 3.1 Listed to UL 9540 or equivalent | ||||||||
| 3.2 UL 9540A fire test data available | ||||||||
| 3.3 Hazard mitigation analysis completed | ||||||||
| 3.4 Approved by or notified to the local authority | ||||||||
| 3.5 Emergency response plan agreed with the fire service | ||||||||
| 3.6 Fire suppression for the battery system | ||||||||
| 3.7 Gas and smoke detection, also at floor level | ||||||||
| 3.8 BMS alarms sent to a staffed location | ||||||||
| 3.9 Damaged or end-of-life batteries quarantined | ||||||||
| 3.10 Separation from buildings and boundaries | ||||||||
| 3.11 Dedicated fire compartment | ||||||||
| 3.12 Explosion control: venting or exhaust ventilation | ||||||||
The EU buildings directive makes solar part of building and renovating. The rules for how to place it safely are still being written, so the responsibility stays with you.
Over 250 m², where technically and economically feasible.
Existing non-residential buildings over 500 m², at major renovation or a permit.
Expected, up from 4.6 GW in 2026 and 1.1 GW in 2020.
Sources: Directive (EU) 2024/1275, article 10. Capacity figures from Codan, September 2026.
There is no single rulebook yet, so the programme uses the ones insurers already read. Each question names its standard. Where a number is our recommendation and not a requirement, it says that too.
Thermography finds a problem. It becomes a sub-task on the question, with a responsible person and a due date.
RISK IMPROVEMENTSA risk engineer's recommendation on the array gets an owner, a due date and a cost estimate, next to the report it came from.
COPESolar and lithium battery details sit in COPE, so what the site declares and what your underwriter reads stay on one record.
OVERVIEWCompliance per section, the least compliant sites and the questions open at the most sites. Questions by site shows the rest.
AI"Which sites have an indoor battery and the largest business interruption value?" A connected assistant reads the same records you do.
SHARINGInvite your broker or the insurer's risk engineer to the board. They read the evidence in 21RISK, not in an email chain.
22 questions in three sections: a yearly site declaration, 9 questions on solar PV and 12 on stationary batteries, including BESS and Li-ion UPS. Each question says what to attach and which standard it comes from.
Not yet. The programme covers solar PV, BESS and Li-ion UPS. Forklift charging sits in COPE. If indoor charging or electric trucks are a risk for you, add your own questions to the board: they work the same way, with the same rules and evidence.
Yes, and this is the cheapest moment. Use the questions as your list before you sign with a supplier or apply for a building permit: test data, placement, separation, fire service access. Fixing placement afterwards costs far more.
No. A certified fire adviser and your insurer should look at each installation, ideally before you buy. 21RISK keeps the questions, the answers and the evidence across your sites. It does not approve an installation.
Your insurer decides that. What 21RISK gives you is the answer when they ask: which sites have PV or batteries, what is on the roof, and the documents behind it, in one place.
Mostly not. Many standards say "regularly". Where an interval is our recommendation, the question says so. The answer then expires after 15 months at the latest, and you can change the interval to fit your insurer or local rules.
The site records who owns and maintains the installation, including a PPA. The fire still starts on your roof, so the questions apply either way. The answer is often a document from the owner.
The common basis is European and international: CFPA-E, FM and NFPA. Local rules come on top, such as DBI Vejledning 39 in Denmark or RC62 in the UK. Every question can be edited to match your countries.
Talk to us. We set the board and the site fields up on your 21RISK organization, and from there every question, rule and interval is yours to change.
The programme runs on the sites, COPE and values you already keep in 21RISK. Show us your sites and we will set it up with you.