Fire Risk Assessments for HMOs: What London Landlords Need

The duty comes from the **Regulatory Reform (Fire Safety) Order 2005**, which applies wherever there are common parts — shared hallways, stairwells, landings, shared kitchens.

In practice that means:

• **HMOs** of any size with shared facilities
• **Blocks of flats**, for the communal areas
• **Mixed-use buildings** with residential above commercial

A single-family house let to one household on one tenancy does not need one under the Order, though the property still has to be safe and fit for habitation.

The Order places the duty on the **"responsible person"**. For most HMOs that is the landlord or licence holder. Where an agent has full management control it can be the agent — but do not assume this has transferred without checking what your management agreement actually says. Responsibility sits with whoever has control, and more than one person can hold it.

The Order requires an assessment that is **"suitable and sufficient"**, carried out by a **competent person**. There is no official register of assessors, which places the burden on you to choose someone who can demonstrate relevant competence.

A proper assessment covers:

• **Escape routes** — width, protection, lighting, and whether they stay usable
• **Fire doors** — including whether self-closers actually close and latch
• **Detection and alarm** — grade and category appropriate to the building, assessed against BS 5839-6 for domestic premises
• **Emergency lighting** where escape routes have no reliable natural light, to BS 5266
• **Firefighting equipment** and its servicing
• **Compartmentation** — whether fire would be contained between units
• **Management arrangements** — testing routines, records, how tenants are informed

For HMOs the assessment should extend into the individual units, not stop at the communal doors. Most London boroughs follow LACORS housing fire safety guidance, and licensing conditions frequently reference it directly.

This is where landlords get caught out. The Order says the assessment must be reviewed **regularly** — it does not define "regularly", and no expiry date is printed on the document.

Accepted practice is:

• **At least annually**
• **On change of tenancy**, if that comes sooner
• **After any fire, near-miss or false alarm**
• **After layout changes** — converting a room, altering an escape route, changing the number of occupants

An assessment from four years ago for a property that now houses two more tenants is not a current assessment, whatever the date on it says.

Fire safety in HMOs is enforced by the **Fire and Rescue Authority**, and separately by your local authority through HMO licensing conditions and the HHSRS.

Enforcement ranges from an informal notice to prohibition — closing the property to occupation — and prosecution. Penalties under the Order are unlimited, and in serious cases carry custodial sentences.

For licensable HMOs, failing to produce a current fire risk assessment on request can also put your licence at risk, which is a faster and more disruptive consequence than a fine.

We carry out fire risk assessments across all 32 London boroughs and the M25 corridor:

• Fire Risk Assessment from £84 for HMOs, flats and communal areas
• Commercial Fire Risk Assessment from £159.99 for offices, shops and mixed-use buildings
• Written report with a prioritised action plan within 48 hours

Related work we can do in the same visit includes smoke and heat alarm testing to BS 5839-6 from £65, emergency lighting duration testing to BS 5266 from £65, and fire door inspection from £130.

All prices include VAT. Book online or call 07426 409342.