NFPA 25 ITM: what building owners actually have to do

A facility manager walks into a 2026 insurance renewal meeting with a binder of quarterly inspection reports. The contractor has been turning up on schedule for nine years. The carrier has accepted the same evidence every renewal. This year the loss-control engineer asks a different question. Where is the five-year internal pipe inspection report? Where is the obstruction investigation? Where is the documentation of the sprinkler sample test on the ESFR heads installed in 2002?

The binder gets thinner the longer the meeting runs.

NFPA 25 has been the standard for water-based fire protection ITM since 1992. The 2023 edition is what most jurisdictions enforce in mid-2026, with the 2026 edition in late review at NFPA. The gaps owners run into have not changed much across the editions. What follows is a working summary of what NFPA 25 actually asks of a US building owner, where the schedule gets misread, and what insurers and AHJs are looking for that goes beyond the letter of the standard.

Whose problem this is

NFPA 25 is explicit on this point and it surprises owners every time. The property owner or the designated representative is responsible for ITM. Section 4.1.1 of the 2023 edition. You can hire a fire protection contractor to perform the work. You cannot hire them to take the responsibility.

If a sprinkler head is painted over in a tenant suite and a fire spreads, the question "did the contractor not flag this" is interesting but not exonerating. The owner is the duty-holder. This shapes everything that follows.

For multi-tenant buildings, lease language matters. A net lease may push the ITM cost to the tenant, but the regulatory responsibility usually stays with the owner. Read the lease before you assume otherwise.

NFPA 25 vs NFPA 13: a clarification that costs people money

NFPA 13 is the install standard. NFPA 25 is the ITM standard. They are different documents with different scopes. Owners regularly conflate them and end up over-specifying installation work or under-specifying inspection frequency.

If a sprinkler contractor is quoting you a new install, NFPA 13 is the governing document for the design. Once installed, NFPA 25 takes over for the life of the system. The clean break matters because the 2023 NFPA 25 references components by their installed standard, and the inspection regime varies depending on what was put in. Wet-pipe sprinkler systems get one schedule, dry-pipe get a stricter one, preaction systems stricter still, ESFR storage-occupancy systems different again.

The frequency map

Here is the spine of NFPA 25, distilled to the inspections owners and facility managers most often miss.

Weekly

• Control valves that are not locked open or electrically supervised. Most owners have these but call them "monthly" out of habit. They are weekly unless one of those two conditions is met.
• Fire pump no-flow (churn) test for diesel pumps. Electric pumps with most arrangements are monthly under the 2023 edition; the diesel weekly is still the default.
• Air pressure gauges on dry-pipe and preaction systems.

Monthly

• Control valves that are locked open or electrically supervised.
• Gauges on wet-pipe systems.
• Electric fire pumps (weekly under earlier editions; the 2023 edition relaxed this for most arrangements).

Quarterly

• Alarm devices and water flow switches.
• Hydraulic nameplate (yes, the plate itself: legibility, accuracy).
• Hose connections.
• Inspector's test connection. The flow test through the inspector's test is the most basic functional check on the whole system. It gets skipped more often than any other quarterly item.

Semiannual

• Supervisory signal devices.
• Pressure-reducing valves (some configurations).
• Some standpipe components.

Annual

• Sprinklers, visual inspection from the floor. Walk every space and look up. Discolored heads, painted heads, obstructed heads, loaded heads (dust and grease in kitchens). One head per room is one too few; you inspect every head you can see, and you note the ones you cannot reach.
• Hangers and seismic bracing.
• Pipe and fittings, visible portions.
• Spare sprinkler cabinet: the right wrench, the right heads, the right count (minimum six for installations of 300 or fewer sprinklers, up to 24 for larger systems).
• Main drain test. One full drain, recorded static and residual pressure.
• Fire pump annual performance test. Flow at 0%, 100%, and 150% of rated capacity. The 150% point is the one that catches degraded pumps.
• Backflow preventer forward-flow test at system demand.

Five-year

• Internal inspection of piping. Open a flushing connection, inspect for obstruction, corrosion, microbiologically influenced corrosion (MIC), zebra mussels in some regions. This is the inspection that finds the problems that years of external inspection cannot.
• Standpipe hydrostatic test (Class I, II, III).
• Sprinkler obstruction investigation. Separate from the internal pipe inspection. It looks for foreign material in the cross mains and branch lines.
• Gauges: replace or recalibrate.
• Check valves: internal inspection.

Sprinkler sample testing

This is the one owners forget most often, and it is the most expensive to catch up on.

• Quick-response sprinklers: sample test at 20 years, then every 10 years.
• Standard-response sprinklers: sample test at 50 years, then every 10 years.
• Dry sprinklers: sample test at 10 years, then every 10 years.
• Sprinklers exposed to harsh environments (high temperature, corrosive atmospheres, freezer rooms): sample test at 5 years, then every 5 years.
• ESFR and other high-pressure sprinklers: follow manufacturer guidance and the same intervals as quick-response unless listed otherwise.

The 5-year harsh-environment test catches owners of cold storage, food processing, plating shops, and similar facilities. The 20-year quick-response test catches owners of buildings installed in the early 2000s who are coming up on the interval right now.

The five regimes that catch owners out

After enough field inspections, the same gaps surface. Five of them account for most of the findings.

1. Control valves that should be weekly are inspected monthly. The condition for monthly is locked open or electrically supervised. "Closed during last contractor visit" is not the same as locked open. Open the lock or install the supervision; do not assume the inspection drops to monthly by default.

2. The inspector's test connection is not being flowed quarterly. It is one of the most informative tests on the entire system. It confirms the alarm signal, the water motor gong (if fitted), the supervisory connection to the monitoring company, and water delivery at the design pressure. When contractors skip it, they are usually saving time at the cost of validating the only thing a fire would actually exercise.

3. Annual main drain pressures are recorded but never compared. Year on year, the main drain test should land within 10 PSI of last year's residual. A 30 PSI drop is the water authority telling you something has changed in the supply main, or telling you a backflow preventer is degrading. Most contractor reports record the number; very few flag the comparison.

4. Internal pipe inspection at 5 years is missed entirely. This is the single most-skipped requirement in NFPA 25. Owners get nine years of quarterly visits and one or two annuals before someone asks for the 5-year. The contractor often did not include it in the original maintenance contract. The cost of catching up tends to be three times the cost of doing it on schedule.

5. Sprinkler sample testing is treated as "we will get to it." The intervals are firm. The 20-year quick-response test on heads installed in 2004 is due in 2024. If it has not happened, the owner is non-compliant from the day the interval lapsed. Some AHJs are lenient. Insurance carriers increasingly are not.

Documentation: what the records have to look like

NFPA 25 Section 4.3 sets out the documentation requirements. Records must include the inspection or test performed, the date, the inspector's name and credentials, the equipment identification, deficiencies found, and the corrective action taken.

Records have to be retained for at least one year after the next scheduled ITM. In practice, insurers want five years and AHJs in some jurisdictions want longer. Treat one year as the floor, not the target.

The 2023 edition added an important clarification on electronic records. Digital records are accepted, but they must be available to the AHJ on request. That means a contractor's portal is fine as long as the owner has export rights and the AHJ can read the export without specialty software. Owners who lose access to the contractor's portal at the end of a contract period have, by definition, lost compliance.

The AHJ and insurance overlay

NFPA 25 is the floor. Two parties commonly add to it.

The Authority Having Jurisdiction (AHJ), usually the local fire marshal, can require stricter inspection frequencies, additional documentation, or a specific tagging system. In many US jurisdictions, sprinkler systems get a tag after each inspection: green (passed), yellow (deficiency noted, system in service), red (impaired, system out of service). The tag system is not in NFPA 25 itself. It is a state or local convention layered on top.

Insurance carriers, particularly the highly-protected-risk underwriters (FM Global, AIG, Allianz Global Corporate), often require their own inspection cadence above NFPA 25. FM Global's data sheets (FM DS 2-81 for sprinkler ITM) are the most common overlay; their requirements include shorter intervals on certain components and additional documentation on others. If your policy references FM data sheets, those become your floor, not NFPA 25.

Owners who run a building to NFPA 25 alone and assume that satisfies the insurer are often wrong. Read the policy.

What good looks like

A building owner with a clean NFPA 25 posture can answer six questions, fast, about every water-based fire protection system in the portfolio.

What is the system, where is it, and what is its hydraulic design basis? When was the last quarterly, semiannual, annual, and 5-year inspection, and when is each next due? Who performed each inspection, what license number, and what was the report reference? Are there open deficiencies, and if so what tag color, what corrective action, and what is the response timeline? When are the next sprinkler sample tests due, by head type and installation year? If a fire happened tomorrow, would the inspector's test connection flow, the alarm signal reach the monitoring company, and the fire pump deliver design pressure at 150% of rated capacity?

If the owner can answer those six on the spot, the binder is doing its job. If not, the binder is documentation theater.

The platform we build at Hovermarks is shaped around those six questions for NFPA 25 and the other ITM regimes US owners run alongside it (NFPA 72 for fire alarm, NFPA 10 for extinguishers, NFPA 80 for fire doors). But you do not need a platform to answer them. You need a record system that an AHJ, an insurance loss-control engineer, or a new facility manager can walk through without your help. If yours cannot, that is where to start.

For more on how Hovermarks handles fire safety inspections specifically, see the fire safety solution page.

Frequently asked questions

Who is responsible for NFPA 25 compliance, the owner or the contractor?

The property owner or designated representative is responsible under Section 4.1.1 of NFPA 25. You can hire a fire protection contractor to perform the inspection, testing, and maintenance work, but the regulatory responsibility cannot be delegated. Even with a contract in place, an enforcement action lands on the owner.

How often does NFPA 25 require sprinkler inspection?

The frequency depends on the component. Annual visual inspection of every sprinkler head from the floor is the headline requirement. Control valves are weekly unless locked open or electrically supervised, in which case monthly. The inspector's test connection is quarterly. The main drain test is annual. Internal pipe inspection is every 5 years.

What is the 5-year internal pipe inspection under NFPA 25?

Every five years, a flushing connection is opened so the inside of the piping can be inspected for obstruction, corrosion, microbiologically influenced corrosion (MIC), and in some regions zebra mussels. It is the most-skipped requirement in NFPA 25 because it does not show on the external inspections.

When do I need to test sprinkler heads for age under NFPA 25?

Quick-response sprinklers: sample test at 20 years, then every 10 years. Standard-response sprinklers: sample test at 50 years, then every 10 years. Dry sprinklers: every 10 years. Sprinklers in harsh environments (cold storage, food processing, plating shops, freezer rooms): every 5 years.

Is NFPA 25 a federal requirement?

NFPA 25 is a consensus standard published by the National Fire Protection Association, not a federal law. It becomes legally enforceable when adopted by a state, county, or city through its fire code. Almost every US jurisdiction adopts it in some form. Insurance carriers also commonly require NFPA 25 compliance through policy terms.

What documentation does NFPA 25 require?

Section 4.3 of NFPA 25 (2023 edition) requires records of each inspection, test, and maintenance activity, including the date, the inspector's name and credentials, equipment identification, deficiencies found, and corrective actions taken. Records must be retained for at least one year after the next scheduled ITM. Insurance carriers and many AHJs want longer.

Can NFPA 25 inspections be done by in-house staff?

Yes for the routine visual inspections (weekly, monthly, quarterly). Many owners run those in-house and only contract out the annual performance tests and 5-year internal inspection. The in-house staff must have appropriate training and the AHJ may require evidence of competence.

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Disclaimer. This guide reflects the position under NFPA 25 (2023 edition) as adopted in most US jurisdictions in mid-2026. Specific compliance questions should be referred to a licensed fire protection contractor or your local Authority Having Jurisdiction.