Do I need a fire risk assessment for my HMO?

The short answer

If you own or manage a house in multiple occupation (HMO) in England or Wales, the Regulatory Reform (Fire Safety) Order 2005 applies to the common parts: shared hallways, stairs, landings, kitchens and other areas used by more than one household. That means a fire risk assessment is needed.

Separately, the Housing Act 2004 lets your local council assess fire as a hazard across the whole property, including inside individual rooms. In practice, a good HMO fire risk assessment looks at the whole building, because fire doesn't stop at the bedroom door.

Who is responsible?

The "responsible person" is usually the landlord, or whoever has control of the property, such as a managing agent. Where more than one person has control, they each have duties and must cooperate. Using an agent doesn't remove your responsibility as the landlord, so make sure it's clear who is doing what.

What should the assessment cover?

• The escape route: whether there's a protected route out from every room, kept clear of storage, bikes and rubbish
• Fire doors: condition, fit and, where needed, self-closers, especially on bedrooms and kitchens
• Detection and alarms: interlinked smoke and heat alarms appropriate to the type and size of HMO, and how they're tested
• Emergency lighting where the escape route needs it
• Kitchens: often the most likely place for a fire to start
• Fire separation: walls, ceilings and gaps around pipes and cables
• Management: testing, maintenance, tenant information and how problems get reported

Councils and fire services commonly use the national LACORS "Housing – Fire Safety" guidance as the benchmark for fire safety standards in existing HMOs.

What changed in 2023?

Since 1 October 2023, changes made by the Building Safety Act 2022 mean that every responsible person must:

• record the full fire risk assessment in writing, not just the significant findings
• record their fire safety arrangements
• record the name of the person or organisation who carried out the assessment, if they used someone else
• for buildings with two or more sets of domestic premises, share relevant fire safety information with residents

Licensing and management duties

In England, an HMO with five or more people forming two or more households needs a mandatory licence from the council, and many councils run additional or selective licensing schemes too. Licence conditions often require evidence of fire safety measures and maintenance. Under the Management of HMOs (England) Regulations 2006, the manager must also keep escape routes clear and fire safety measures maintained.

You must also meet the smoke and carbon monoxide alarm rules for rented homes, and keep gas and electrical safety checks up to date.

How often should it be reviewed?

Regularly, and whenever something significant changes: new layout, building works, a change in the number or type of tenants, or after a fire or false alarm pattern. Many landlords review annually as good practice.

What if I don't have one?

The fire and rescue authority can issue enforcement notices and prosecute under the Fire Safety Order. The council can take action under the Housing Act, including civil penalties in England, and fire safety failings can affect your licence. Most importantly, your tenants could be at risk.

Properties in Wales

The Fire Safety Order also applies in Wales, but housing law is different, including the Renting Homes (Wales) Act 2016 and registration and licensing through Rent Smart Wales. Tell us where your properties are and we'll tailor our advice.

This guide is general information for England and Wales, current at the date of publication, and isn't a substitute for advice about your specific property.