The labels differ. England and Wales place the duty on the responsible person. Scotland places broadly equivalent duties on dutyholders: employers, and anyone with control of relevant premises. Northern Ireland uses the appropriate person. In each case the role attaches to control of the building, so employers, occupiers, owners and managing agents are the usual candidates, and more than one person can hold duties over the same premises at once. A landlord with stock in Carlisle and Dumfries therefore answers to two different statutes for the same portfolio, even though the assessments themselves look almost identical.
Coverage is aligned in substance too: workplaces and other non-domestic premises are in scope everywhere, shared parts of residential buildings are covered, and the single private home sits outside the assessment duty in all four nations. Sleeping accommodation such as HMOs, hostels and care homes attracts the closest regulatory attention wherever in the UK it stands.