HMO Fire Safety Risk Assessment: Rules, Costs & Checklist

HMO fire risk assessment is important because Houses in Multiple Occupation often need more attention to fire safety than single lets due to higher occupancy, diverse tenant behaviours, and different internal layouts. In recent years, a fire in an overcrowded east London HMO killed one resident and led to landlords being fined over £90,000. That highlighted how serious fire safety failures can be if not properly assessed.  

That’s why a fire risk assessment is now a legal requirement for HMO landlords, licence holders and managing agents in England. At Real Estate Agents London, we’ve mentioned the steps so you know exactly what you need to do to stay compliant and protect your tenants.

Do You Legally Need an HMO Fire Risk Assessment?

Yes, a fire risk assessment is a legal requirement for HMOs in England. Under the Regulatory Reform (Fire Safety) Order 2005 (SI 2005/1541), the “responsible person” for an HMO is legally required to carry out a suitable and sufficient fire risk assessment, keep it up to date, and fix any fire safety risks it identifies. This law applies to all shared areas of an HMO, including hallways, staircases, shared kitchens and shared bathrooms.

Identify Hazards (Fuel, Ignition and Oxygen) → Assess People at Risk (Who Could Be Harmed) → Implement Safety Measures (For Common Areas)

Who is the “Responsible Person” for an HMO and What They Need to Do?

Under fire safety law, the “responsible person” is the person who has control of the premises. This is often:

• The landlord who owns and manages the HMO.
• The licence holder, if they are responsible for meeting HMO licence conditions.
• A managing agent, if their agreement includes fire safety responsibilities.
• The freeholder, in some cases, especially if they manage the building’s shared areas.

In larger buildings with several flats, there may be more than one responsible person. For example, one person may be responsible for the individual flats, while another looks after the shared areas, such as hallways and staircases.

If you’re the landlord or managing agent, it’s your responsibility to make sure the shared areas are safe for your tenants by carrying out and regularly reviewing the fire risk assessment. Besides that, responsible persons need to:

• Give tenants clear fire safety instructions, including how to report a fire and what to do if a fire starts.
• Make sure smoke alarms, fire doors, emergency lighting and other fire safety equipment are working properly.
• Keep all escape routes clear and easy to use.
• Explain why fire doors are important and remind tenants not to wedge them open.
• Collect data showing that you’ve shared this information with your tenants.
• Keep a full written record of the fire risk assessment, not just a summary of the main findings. 
• Review and update the assessment whenever there are significant changes to the property or fire risks
• Provide the assessment without unnecessary delay if a fire inspector asks to see it.

Tenants have responsibilities too, even though the landlord is legally responsible for the fire risk assessment. Under their tenancy agreement and general fire safety guidance, they should not do anything that increases the likelihood of fire.

• Remove, cover or damage smoke alarms.
• Wedge fire doors open or remove the self-closing devices.
• Leave bikes, furniture or rubbish in hallways, staircases or other escape routes.
• Use extra cooking or heating appliances without the landlord’s permission.

How to Carry Out an HMO Fire Risk Assessment: Step by Step

A fire risk assessment is more than just checking your property. It follows a five-step process, and each step should be recorded properly to show you’ve met your legal responsibilities.

Identify hazards: Check for fire hazards, such as cookers, heaters, faulty wiring, furniture and stored waste.

Assess people at risk: Consider tenants, visitors and anyone who may need extra help in an emergency.

Check fire safety measures: Make sure smoke alarms, fire doors, emergency lighting and escape routes are in good condition.

Evaluate and reduce risks: Decide what needs to be repaired, removed or improved to lower the risk of fire.

Record and review: Keep a written record of your findings and review the assessment regularly or after any major changes.

The table below summarises who’s usually responsible for each step and the records to keep:

When Should You Review Your Fire Risk Assessment?

A fire risk assessment should be reviewed regularly to ensure it remains accurate and reflects any changes to the property. Review it:

Tired of Tracking Every Fire Safety Review Date Yourself? Let Us Handle It.

From review deadlines and legislation changes to the wider certificates and documentation your HMO needs, our team keeps it all managed as part of your property’s day-to-day compliance.

Who Can Conduct an HMO Fire Risk Assessment?

Honestly, it depends on the property. Only 29% of HMO fire safety inspections in England were rated satisfactory (the lowest pass rate of any property type). Across England overall, pass rates have dropped too; just 58% last year, the lowest since 2011.

So, DIY or Professional? With a fail rate that high, it’s important to choose the right approach:

Do it yourself if you have the right knowledge and your HMO is small with a simple layout.

Hire a qualified fire risk assessor if your HMO is larger, older or has a more complex layout, where important fire risks can be easier to miss.

Can a landlord carry out their own fire risk assessment?

Yes. Landlords can legally complete their own HMO fire risk assessment if they are competent to do so. But this may be suitable for a small HMO with a simple layout if they understand the fire risk assessment process and legal requirements.

When should you hire a professional fire risk assessor?

HMOs are more complex and have higher risk than other rental properties. So, in case of larger, older or more complex HMOs, it’s better to use a qualified fire risk assessor. They are more likely to identify hidden fire risks and make sure your property meets legal and licensing requirements.

Before hiring, check that they:

1. Have experience of carrying out fire risk assessments for HMOs.
2. Are competent or belong to a recognised professional body.
3. Provide a detailed written fire risk assessment, not just a checklist.
4. Explain any fire safety issues clearly and provide a clear action plan.
5. Offer advice on how to fix any problems identified during the assessment.
6. Has third-party certification, such as BAFE SP205.
7. Has professional indemnity insurance.

HMO Fire Risk Assessment Cost and How Often You Need One

A professional fire risk assessment for an HMO generally costs somewhere between £250 and £600, depending on the size of the property, the number of storeys and bedrooms, and how complex the escape routes are. Larger properties take longer to inspect due to additional storeys and complex layouts, which eventually increases the cost.

Don’t focus on price alone while choosing an assessor. A thorough assessment that identifies potential fire risks offers better value than a cheaper assessment that overlooks important issues.

What a suitable and sufficient HMO fire risk assessment template should cover

1. Property layout, number of storeys and escape routes
2. Fire doors: condition, self-closers, seals and gaps
3. Fire detection and alarm provision throughout the building
4. Emergency lighting, where escape routes need it
5. Kitchens, cooking risk and fire blankets
6. Electrical intake cupboards, meter cupboards and storage areas
7. Housekeeping, rubbish and combustible materials in common parts
8. Fire separation between rooms, bedrooms and escape routes
9. Resident fire safety information and notices
10. Records of testing, inspection and maintenance

Get A Free HMO Fire Safety Checklist

Want to do a quick safety check before booking a professional fire risk assessment? Download our free HMO fire safety checklist to review key areas like alarms, fire doors, escape routes and kitchen safety.

It won’t replace a full fire risk assessment. But it can help you spot common issues early and prepare your property for a professional assessment.

What If I Don’t Have a Fire Risk Assessment For an HMO?

If you ignore these rules, the consequences can be serious:

Prohibition notices: The fire service can close your HMO if it’s not safe.

Unlimited Fines: You could face an unlimited fine under the Regulatory Reform (Fire Safety) Order 2005 if you fail to meet your fire safety duties.

Up to two years in prison: Serious fire safety breaches can lead to a prison sentence.

Rent Repayment: Under the Housing Act 2004, you may have to repay rent to your tenants or the local council.

Banning Orders: If you repeatedly break the rules, you could be banned from renting out property. 

Here’s an example of a fire safety breach:

A landlord rents out an unlicensed HMO without a valid fire risk assessment. The smoke alarms haven’t been tested for years, and a fire door is wedged open in the shared hallway. One fire safety issue is serious. But these problems become much more serious when they happen together at the same property, and tenants are at greater risk. In this case, landlords are more likely to face prosecution rather than just a fine.

Fire Alarms: Does Your HMO Need Grade A or Grade D?

Two factors specify HMO fire alarm systems in the UK:

1. Grade (the type and power source of the system)
2. Category (how much of the building is covered)

Alarm Grade

The grade explains what type of alarm system is installed. 

Grade D systems: These are mains-powered alarms with battery backup. They are interlinked, so all alarms sound together, and they are easier to install in existing properties.

Grade A systems: These are more advanced systems with a central control panel. They require professional installation and regular servicing.

Alarm Category

The alarm category shows the level of coverage:

LD2: Covers escape routes and higher-risk areas, such as kitchens and living rooms.

LD1: Provides full coverage across the property, including bedrooms, and is generally used for higher-risk or more complex HMOs.

Your fire risk assessor will recommend the right category for your HMO.

Fire Doors, Escape Routes and Compartmentation

These three elements form the property’s first line of defence against a fire spreading. Here’s how each one contributes to keeping an HMO safe.

Fire Doors

Fire doors matter because they slow the spread of fire and smoke, buying time for people to escape and for the fire and rescue service to arrive.

Doors rated FD30 are designed to hold back fire for 30 minutes, and they’re expected on bedroom doors that open onto an escape route, kitchen doors, and any door enclosing a stairwell.

Fire Door Specifications

A genuine fire door requires more than just a heavy-looking slab of wood: 

• FD30-rated door leaf with a solid core to provide around 30 minutes of fire resistance.
• Fire-rated frame and architrave that match the door specification.
• Intumescent strips that expand when exposed to heat and seal gaps around the door.
• Smoke seals to help prevent smoke from passing through.
• A working self-closing device to ensure the door closes and latches properly after use.
• A suitable latch to keep the door securely closed.
• Small gaps around the door: gaps should generally be no more than 3mm when the door is closed. A £1 coin is roughly 3mm, so if it easily fits through the gap, it may be too wide.

Common Fire Door Failures

Fire door problems are one of the most common issues found during HMO inspections.

The most common failures inspectors find are simple to fix: 

Closers disconnected or removed, doors wedged open with a chair or fire extinguisher, gaps around the frame too wide (a rough rule of thumb some assessors use is that a £1 coin shouldn’t fit through the gap), and ordinary internal doors used where a fire door was required.

Fire Door Maintenance Checklist

Check your fire doors at least every three months to make sure they are working properly.

1. Does the door close fully and latch by itself?
2. Are the intumescent strips and smoke seals in good condition?
3. Are the gaps around the door no more than 3mm?
4. Is the self-closing device working properly?
5. Is the door free from damage, holes or warping?

Escape Routes

To allow tenants to leave safely in an emergency situation, escape routes also need to be protected, kept clear from any type of hurdle, and final exit doors must open without needing a key. 

• Bedrooms should not be too far from a storey exit. The distance should be shorter if there is only one escape route and can be longer if there are multiple escape routes.

Compartmentation

Compartmentation is another important part of fire safety. It means dividing the building into separate sections using fire-resistant walls, floors, and ceilings to stop fire and smoke from spreading between rooms. 

Common problems: damaged ceiling panels, unsealed gaps around cables or pipes and open spaces in loft areas, which can allow fire to spread quickly.

How to fix it: Check the building for gaps or damaged areas and seal them using approved fire-resistant materials. This is especially important in older or converted HMOs.

Emergency Lighting, Extinguishers and Fire Blankets: What’s Actually Required

Not every HMO needs all three: emergency lighting, extinguishers and fire blankets. Before spending money, understand that to choose the right fire safety equipment, you have to look at the property’s layout and findings of your fire risk assessment. 

You need emergency lighting if escape routes are long, internal, poorly lit by daylight or used by people who are unfamiliar with the multi-storey layouts. It should: 

• Provide at least  3 hours of backup
• Light up escape routes so people can leave the building safely during a power cut.
• Turn on automatically if the mains power fails.
• Be tested regularly, with a monthly function test and a full three-hour test every year.

Fire extinguishers aren’t automatically required in every HMO’s common areas the way they might be in a commercial building. But local licensing conditions sometimes specify them. A fire blanket is recommended in every shared kitchen, even if it isn’t a legal requirement.

HMO Licensing and Council Fire Safety Standards

Properties occupied by five or more people from two or more households under the Housing Act 2004 must have a mandatory HMO licence. Otherwise, running a licensable property without the correct licence is a criminal offence in the UK.

Some councils also have additional or selective licensing schemes that apply to smaller HMOs or specific areas. These schemes can have their own fire safety requirements, so it’s important to check your local council’s rules. 

If you manage HMOs in different areas, remember that licensing requirements can vary between councils. So, if you need help with HMO licensing and daily property management, our HMO management service can support you with both.

Main Fire Safety Laws for HMOs

There isn’t just one law that covers HMO fire safety. Several laws work together, and each one covers a different part of your legal responsibilities.

What to Do If a Fire Starts in Your HMO

Fire safety in an HMO is a shared responsibility. Landlords carry the legal duty, while tenants follow the basic fire rules to keep the building safe day to day. If a fire starts:

• Raise the alarm if it hasn’t gone off automatically.
• Use the nearest safe escape route to leave the building immediately.
• If it’s safe, close doors behind you to slow the spread of fire.
• Call 999 once you’re safely outside.
• Never go back inside to collect your belongings.

Not Sure If Your HMO Meets Current Fire Safety Standards? Let’s Help You Find Out.

Whether it’s fire risk assessments, licensing, or day-to-day compliance checks, our Real Estate Agents London team can guide you through it with confidence.

Frequently Asked Questions