Fire Risk Assessments for HMOs – A Complete Guide

Fire Risk Assessments for HMOs are a legal requirement in England, forming the cornerstone of fire safety compliance for landlords and property managers. Houses in Multiple Occupation (HMOs) present elevated fire risks due to higher occupancy, diverse tenant behaviours, and often complex internal layouts.

Under the Regulatory Reform (Fire Safety) Order 2005 (“Fire Safety Order”), the “responsible person” must ensure that a suitable and sufficient fire risk assessment (FRA) is carried out and kept up to date. The Fire Safety (England) Regulations 2022 further detail landlord duties for residential buildings with common parts, including specific obligations for fire doors, resident information, and maintenance records.

Failing to meet these requirements can result in enforcement action, substantial fines, and even prosecution.

What is a Fire Risk Assessment?

A Fire Risk Assessment is a systematic evaluation of a property to identify potential fire hazards, assess the likelihood of fire, determine the potential consequences, and establish measures to eliminate or reduce the risks.

In an HMO, an FRA must consider the building’s physical structure, the occupants’ needs, and the management arrangements for fire safety.

Article 9 of the Fire Safety Order mandates that this assessment must be “suitable and sufficient” and regularly reviewed.

Legal Framework - Fire Risk Assessments for HMOs

Regulatory Reform (Fire Safety) Order 2005

The Fire Safety Order applies to all non-domestic premises, including the common parts of HMOs.
Key points:

Article 3 defines the “responsible person” (usually the landlord or managing agent).

Article 8 places a duty to take general fire precautions.

Article 9 requires a fire risk assessment to be carried out and reviewed regularly.

Article 11–17 cover arrangements for fire safety, maintenance, training, and cooperation between responsible persons.

Fire Safety (England) Regulations 2022

Applicable from 23 January 2023, these regulations supplement the Fire Safety Order.
For HMOs with common parts:

Regulation 9: Duty to provide residents with fire safety instructions, including evacuation procedures and how to report a fire.

Regulation 10: Duty to provide residents with fire door information and, in buildings above 11 metres, undertake regular fire door checks.

Regulation 7: Duty to check essential firefighting equipment monthly and keep records.

Who is the Responsible Person in an HMO?

In most HMOs, the responsible person will be:

The landlord (if they retain control of common parts).

A managing agent (if delegated authority is given in writing).

A freeholder (in mixed-ownership HMOs).

The responsible person must ensure compliance with all fire safety duties, including commissioning and acting upon a fire risk assessment.

What a Fire Risk Assessment Must Cover in an HMO

A competent FRA for an HMO should include:

Identification of fire hazards – ignition sources, fuel sources, and oxygen supply.

People at risk – residents, visitors, maintenance staff, and vulnerable persons.

Evaluation of risks – likelihood and severity, including potential spread.

Fire safety measures – alarms, extinguishers, compartmentation, escape routes.

Emergency planning – evacuation strategies and resident communication.

Record of findings – documenting hazards, control measures, and responsible parties.

Review schedule – typically annually, or sooner after significant change.

Specific HMO Fire Safety Considerations

HMOs have unique risk factors compared to single-family dwellings:

Compartmentation & Escape Routes

Fire separation between units is essential. Partition walls, floors, and ceilings must meet required fire resistance standards. Escape routes should be kept clear, lit, and free from obstructions.

Fire Doors

Under Regulation 10:

All residents must be informed to keep fire doors shut and not to tamper with self-closing devices.

In HMOs above 11 metres, flat entrance doors must be checked annually and communal fire doors quarterly.

Fire Alarm and Detection Systems

Grade A LD2 systems (BS 5839-6) are common in larger HMOs, with detection in escape routes and high-risk rooms such as kitchens.

Emergency Lighting

Should be installed in all escape routes, tested monthly and serviced annually.

Resident Information

Regulation 9 requires clear instructions on evacuation and fire reporting. These must be displayed in communal areas and issued to each new tenant.

Record Keeping and Evidence of Compliance

Documentation is critical. The responsible person should:

Keep a written FRA.

Maintain logs of alarm tests, emergency lighting checks, and fire door inspections.

Record maintenance and repairs to firefighting equipment.

Retain records for inspection by the fire and rescue authority.

For certain high-rise HMOs, a secure information box containing key documents is mandatory under Regulation 4.

Enforcement and Penalties for Non-Compliance

Fire authorities can inspect HMOs at any time. If non-compliance is found, they can:

Issue alterations notices.

Serve enforcement notices.

Issue prohibition notices (restricting use of the building).

Prosecute for serious breaches — penalties can include unlimited fines and imprisonment.

Best Practice Tips for HMO Fire Risk Assessments

Use a competent assessor experienced with HMOs.

Review after any change to building layout, occupancy type, or fire safety systems.

Engage tenants — provide clear, multilingual instructions if necessary.

Integrate maintenance — link FRA findings to a planned maintenance schedule.

Stay informed — monitor changes to fire safety law and guidance.

Resources

What Is a Fire Risk Assessment? A Complete Guide for UK Property Owners

Who Is Legally Responsible for Fire Risk Assessments?

When Is a Fire Risk Assessment Required in the UK?

Understanding BS 9792:The New Standard for Fire Risk Assessments

FAQs – Fire Risk Assessments for HMOs

Q1. Are Fire Risk Assessments mandatory for all HMOs?
Yes. Under the Fire Safety Order, all HMOs with common parts require an FRA.

Q2. How often should an FRA be reviewed?
At least annually, or after significant changes to the building or occupancy.

Q3. Can I do my own FRA?
Landlords can complete their own FRA if competent, but professional assessors are recommended for complex HMOs.

Q4. What happens if I don’t have an FRA?
You risk enforcement action, fines, and prosecution.

Q5. What is a “suitable and sufficient” FRA?
One that identifies all relevant hazards, considers all people at risk, and prescribes effective control measures.

Q6. Do small HMOs need the same level of assessment?
Yes, but measures can be proportionate to the size and complexity of the property.

Q7. Are tenants responsible for fire safety?
Tenants must cooperate with the responsible person, but legal duty remains with the landlord/managing agent.

Conclusion & Next Steps - Fire Risk Assessments for HMOs

Fire Risk Assessments for HMOs are not just a legal obligation — they are a critical safeguard for tenant safety, asset protection, and landlord liability management. By understanding and meeting your duties under the Fire Safety Order 2005 and Fire Safety (England) Regulations 2022, you can ensure compliance, reduce risks, and protect lives.

For tailored advice and professional fire risk assessment services for HMOs, contact our expert team at Anstey Horne. We can help you meet legal requirements, implement best practices, and ensure your property remains safe and compliant.

Need help with your fire risk assessment?

Anstey Horne’s expert team of fire safety professionals are here to assist with legally compliant fire risk assessments, retrospective fire strategies, and FRAEW appraisals for residential buildings across the UK. Whether you manage a single block or a national portfolio, we can help you stay safe—and compliant.

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