The 10 Most Common HMO Fire Risk Assessment Failings (and How to Fix Them)

A fire officer can close your HMO on the day of the visit. A prohibition notice stops you letting rooms until the danger is put right, and it can land the same afternoon an inspector finds a fire door wedged open or a dead smoke alarm on the landing. Get the fire risk assessment wrong and the fallout runs from an unlimited fine to a banning order that ends your time as a landlord, plus refused or invalidated insurance if a claim ever exposes the gap.

Most enforcement does not come from freak events. It comes from the same handful of HMO fire safety mistakes, repeated across thousands of properties. Below are the ten common fire risk assessment failings that most often get HMO landlords in trouble, and exactly how to fix each one before an inspector, or a fire, finds it first. This piece focuses on England, where the Regulatory Reform (Fire Safety) Order 2005 (the RRO 2005) governs the common parts of your HMO. Wales follows the same order, while Scotland and Northern Ireland run separate fire safety regimes, so check your nation's rules if you let outside England.

The most common fire risk assessment failings begin on paper

1. No written assessment at all. The RRO 2005 requires the responsible person to carry out a fire risk assessment and record the significant findings. In practice, if you cannot hand an inspector a written FRA on request, you are treated as having none. That is the quickest route to failing your HMO FRA inspection, and doing nothing is a criminal offence that can bring an unlimited fine on conviction. The fix is simple: produce a written assessment covering the shared hallways, stairs, kitchens and plant, and keep it where you or your agent can retrieve it in minutes.

2. Relying on a generic template. A downloaded PDF with your address typed at the top is not an assessment of your building. Officers spot boilerplate instantly because it names hazards your property does not have and misses the ones it does. Before you trust any pro forma, read what an HMO fire risk assessment template must include and where free ones fall short. The fix is to walk the actual premises, record the real construction, occupancy and escape arrangements, and tailor every finding to what is in front of you.

3. Never reviewing the assessment. An FRA is not a one-off certificate. It must be reviewed regularly and whenever something material changes: a new tenant profile, a loft conversion, a replaced boiler, or a near miss. A three-year-old assessment describing a layout you have since altered is worthless in court. The fix is to diarise a review at least annually, and to redo it after any change that affects fire risk or the escape route.

Fire doors and compartmentation: the failings inspectors photograph

4. Wedged or damaged fire doors. In a licensable HMO, bedroom and kitchen doors onto the escape route are normally FD30 fire doors fitted with intumescent strips, cold smoke seals and a working self-closing device. The classic failing is a door held open with a wedge or a fire extinguisher, or a self-closer that has been unscrewed because tenants found it annoying. A door propped open does nothing when a fire starts. The fix is to keep every fire door self-closing and unobstructed, replace damaged doors and seals, and inspect them on a set schedule rather than by chance.

5. Poor compartmentation. Fire doors only work if the walls, floors and ceilings around them hold fire back too. The silent killer here is unsealed service penetrations: waste pipes through party walls, cables through fire-stopping, downlighters punched through a protected ceiling. Each hole lets smoke and flame bypass the barrier you paid for. The fix is to check that the compartment lines are intact, fire-stop every penetration with the correct rated material, and record it. If you are unsure whether your layout needs 30 or 60 minutes of resistance, get a competent assessor to confirm the standard for your building.

Detection, lighting and signage

6. Missing, disabled or expired alarms. Detection is where the Smoke and Carbon Monoxide Alarm (England) Regulations 2022 and the Fire Safety (England) Regulations 2022 meet the design standard BS 5839-6. Many HMOs need a mains-powered, interlinked system: often Grade D Category LD2 as a minimum, and Grade A LD2 for larger or higher-risk houses of three or more storeys. Common failings include:

• Battery-only units where an interlinked mains system is required.
• Detectors past their ten-year replacement date, or with batteries removed by tenants.
• Heads missing entirely from a kitchen, cellar or top-floor escape route.

The fix is to specify the correct grade and category for your property, test the system on the schedule BS 5839-6 sets, and log every test. Knowing what an assessor actually checks, room by room, tells you exactly where detection is expected.

7. No emergency lighting. When the power fails during a fire, tenants need to see the way out. Internal stairs and windowless escape routes in most HMOs need emergency lighting that provides at least three hours of illumination on failure of the normal supply. The failing is either no emergency lighting where the escape route is enclosed, or fittings that have never been tested and no longer work. The fix is to install emergency lighting where the assessment calls for it, run the monthly and annual duration tests, and keep the results.

8. Missing signage. Fire action notices, exit signs on a route that is not obvious, and "fire door keep shut" markings are cheap and routinely absent. In a shared house where tenants may not know the layout, unmarked routes cost seconds that matter. The fix is to display clear fire action notices, sign escape routes that are not self-evident, and label fire doors correctly.

Escape routes must stay clear

9. Blocked escape routes. A protected route only works if people can actually use it. Bikes on the landing, a broken washing machine on the stairs, or prams in the hallway all narrow or block the path to the final exit. Inspectors treat a cluttered stairwell as a live danger, not a housekeeping quibble. The fix is a firm, enforced policy that shared escape routes stay clear, backed by regular checks rather than a note in the tenancy agreement nobody reads.

10. Combustible storage in escape routes. Worse than clutter is fuel. Stacked cardboard, stored paint, gas canisters or a chest freezer humming away in the hall under the stairs turn your escape route into the place a fire starts and spreads. Electrical items on the route add an ignition source to the fire load. The fix is to keep the escape route free of combustible storage and electrical equipment altogether, and to give tenants a proper place to store belongings away from the means of escape.

Fix these ten and you have removed the failings that account for the bulk of HMO enforcement. Miss even one and you are relying on luck, which is not a fire safety strategy and is no defence when a council officer, or a coroner, starts asking questions.

Next steps

Start by walking your property against this list today, fixing the quick wins (unwedging doors, clearing the stairwell, testing alarms) the same day, and booking in the larger jobs such as compartmentation or emergency lighting. Then get the assessment itself in writing and tailored to your building, because the paperwork failings are the ones that get punished first.

FRASafe guides you through a BS 9792:2025-aligned fire risk assessment, free to complete, with a council-ready PDF for £45. It prompts you on fire doors, detection grades, escape routes and compartmentation as you go, so the ten failings above are checked off before an inspector ever knocks.