Fire Risk Assessments for HMO Landlords: London Guide 2026

Houses in Multiple Occupation (HMOs) face stricter fire safety requirements than standard single-let properties, and for good reason: multiple unrelated occupants sharing a building creates specific fire hazards that are not present in single-family homes. A fire that starts in one occupant's room in the early hours can spread unseen to other bedrooms before anyone wakes up.

The Regulatory Reform (Fire Safety) Order 2005 (RRO) imposes a legal duty on the "responsible person" — in most cases the HMO landlord — to carry out a suitable and sufficient fire risk assessment and implement appropriate fire precautions. This is not a checkbox that can be skipped.

Why HMOs Have Stricter Fire Safety Requirements

HMOs present elevated fire risks compared to single-family rental properties for several reasons:

Multiple occupants: More people means more potential ignition sources — unattended cooking, charging devices, smoking, candles — and more people who may not know where the fire escape routes are.

Communal areas: Hallways and stairwells in HMOs serve as the means of escape for all occupants. If fire or smoke fills these areas, everyone is affected simultaneously.

Unfamiliarity with the building: In a shared house, occupants may be recent arrivals who do not know where fire exits are or what to do in an emergency.

Higher-risk activities: Communal kitchens are statistically the most common source of house fires. In an HMO, the kitchen is used by multiple tenants with different levels of care and attention.

These factors mean that fire safety systems that might be adequate in a single-let property — a few smoke alarms — are typically not sufficient in an HMO.

When Is a Fire Risk Assessment Legally Required?

The Regulatory Reform (Fire Safety) Order 2005 applies to all non-domestic premises and the communal areas of multi-occupied residential buildings. This means:

• Any HMO with a shared hallway, staircase, kitchen, or living room
• Purpose-built blocks of flats (communal areas)
• Bedsit-style HMOs
• Large student houses

For small HMOs that are owner-occupied (where the landlord lives on the premises), different rules may apply. For any HMO let to unrelated tenants where the landlord does not live there, the RRO applies and a fire risk assessment is required.

Local authority HMO licensing also typically imposes a fire risk assessment requirement as a condition of the licence, so HMO landlords in London — where mandatory licensing requirements vary by borough — face the requirement from two directions.

Who Can Carry Out an FRA?

The RRO requires the fire risk assessment to be carried out by a "competent person". The regulations do not specify a formal qualification, but in practice for an HMO the competent person should be:

• A qualified fire risk assessor with specific training in residential risk assessment
• Accredited by a recognised body such as the Institute of Fire Safety Managers (IFSM), the Institution of Fire Engineers (IFE), or listed on the BAFE SP205 register

Self-assessment by the landlord is technically permitted for very small, low-risk premises, but is not appropriate for most HMOs. The fire authority and local housing authority both expect a professional assessment for any HMO subject to licensing, and a self-assessment that misses a serious risk will not be a defence if a fire occurs.

What an FRA Covers in an HMO

A professional fire risk assessment for an HMO covers:

Hazard identification:

• Potential sources of ignition (electrical equipment, cooking, heating)
• Potential fuel sources (furniture, bedding, accumulated rubbish)
• Oxygen sources (ventilation, open windows)

People at risk:

• Number of occupants and their relative vulnerability
• Occupants who may be asleep or impaired during a fire
• Any occupants with disabilities affecting their ability to evacuate

Existing fire precautions:

• Fire detection and alarm system — type, coverage, condition
• Emergency lighting
• Fire doors — specification, self-closing mechanisms, condition
• Means of escape — staircases, final exits, signage
• Fire-fighting equipment (extinguishers, fire blankets)

Evaluation of risk:

• Is the existing level of precaution adequate for the risk?
• What actions are needed to reduce the risk to acceptable levels?

Recommendations:

• Categorised by urgency (immediate action, within one month, within three months, general improvement)
• Practical, specific, and costed where possible

The Regulatory Reform (Fire Safety) Order 2005

The RRO replaced more than 70 pieces of fire safety legislation when it came into force in 2006. It places a duty on the "responsible person" — the landlord or managing agent — to:

1. Carry out a suitable and sufficient fire risk assessment
2. Implement the fire safety measures identified in the assessment
3. Record the findings of the assessment (required where 5 or more people are employed, but also strongly recommended for HMOs)
4. Review the assessment when there is reason to suspect it is no longer valid

Non-compliance with the RRO is a criminal offence. The fire authority has powers to serve enforcement notices, prohibition notices (which can prevent the property from being used), and prosecute responsible persons. Fines are unlimited and imprisonment of up to two years is possible for serious offences.

Fire Safety (England) Regulations 2022 — What Changed

The Fire Safety (England) Regulations 2022 came into force on 23 January 2023 and introduced new requirements for multi-occupied residential buildings. Key changes relevant to HMO landlords:

Buildings under 11 metres: The responsible person must ensure that residents can report fire doors in communal areas as defective, and provide residents with fire safety instructions and information.

Buildings 11–18 metres: Additional requirements including inspection of flat entrance doors and quarterly checks of communal fire doors.

Buildings over 18 metres: Most extensive requirements, primarily aimed at high-rise blocks rather than typical London HMOs.

For most HMO landlords with standard terraced or semi-detached houses, the 2022 regulations primarily require providing tenants with fire safety information and maintaining a clear process for reporting defective fire doors.

Fire Doors in HMOs — What Is Required

Fire doors are one of the most frequently cited deficiencies in HMO fire risk assessments. The requirements are:

FD30S standard for bedroom doors in most HMOs: Bedroom doors in an HMO should provide at least 30 minutes of fire resistance (FD30) with intumescent strips and smoke seals (the "S" designation) to prevent smoke from travelling under and around the door.

Self-closing mechanisms: All fire doors must be fitted with a self-closing device that ensures the door returns to the closed position from any open position. Propped-open fire doors — a common sight in shared houses — eliminate the protection the door provides.

Condition and maintenance: Fire doors must be in good condition. Damaged intumescent strips, missing smoke seals, and doors that do not close properly must be rectified. Tenants must be instructed not to wedge them open.

Communal area doors: Doors to communal areas — kitchen, living room, utility room — are often required to be fire doors in assessed HMOs. The fire risk assessor will specify which doors need upgrading.

Smoke Alarm Requirements by HMO Type

Minimum legal requirement (Housing Act 2004 / Smoke and Carbon Monoxide Alarm Regulations 2022):

• A working smoke alarm on every storey of the property
• A working carbon monoxide alarm in any room with a solid fuel-burning appliance
• Landlords must test alarms at the start of each tenancy

For licensed HMOs (typically higher-risk):

• A Grade D interlinked smoke alarm system covering all rooms and common areas
• Heat detector in the kitchen (smoke detectors over hobs generate false alarms)
• Carbon monoxide detectors where required
• Alarms should be BS 5839-6 compliant

For larger HMOs (six or more occupants, three or more storeys):

• A more comprehensive Grade A addressable fire alarm system may be required
• Emergency lighting for means of escape
• The fire risk assessment will specify the required category

How Often to Review the FRA

The RRO requires the assessment to be kept under review. For HMOs, review should occur:

• Annually — as a matter of good practice and typically required by the licensing authority
• After any significant change — change of occupancy, refurbishment, installation of new equipment
• After an incident — any fire, near-miss, or activation of the fire alarm
• When the assessment is more than three to five years old — even without changes, a full reassessment should be carried out

How Much Does an FRA Cost for an HMO in London?

At My Landlord Certificate, fire risk assessment pricing starts from £74.99 for a studio or small flat:

| Property type | Price | |---|---| | Studio Apartment | £74.99 | | Communal Area (1–3 floors) | £129.99 | | Communal Area (3–6 floors) | £149.99 | | 1–3 Bedrooms | £139.99 | | Up to 4 Bedrooms | £179.99 | | Up to 5 Bedrooms | £189.99 | | Up to 6 Bedrooms | £249.99 | | Up to 7 Bedrooms | £299.99 | | Up to 8 Bedrooms | £349.99 |

All fire risk assessments are carried out by competent assessors with HMO experience. The written report is emailed within 48 hours of the assessment and includes a prioritised action plan.