How to Do Your Own HMO Fire Risk Assessment
The RRO 2005 allows a competent person to carry out their own fire risk assessment. Here's what self-assessment involves, and when you should bring in a qualified assessor.
Can you do your own HMO fire risk assessment, or do you have to pay someone hundreds of pounds? The honest answer is: yes, you can do it yourself — if you're genuinely competent to do so. The law doesn't require a certificate or a professional qualification. But "I watched a YouTube video" won't cut it either. Here's what you actually need to know.
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Start Your AssessmentWhat Does the Law Actually Say?
The Regulatory Reform (Fire Safety) Order 2005 (RRO 2005) requires fire risk assessments to be carried out by a "competent person" — someone with sufficient training, experience, knowledge, and ability to identify fire risks and know what to do about them. Crucially, there is no requirement for any specific qualification, registration, or certification.
So yes, an HMO landlord can legally carry out their own fire risk assessment. Plenty of experienced landlords do. The key word is "competent" — you have to approach it methodically, and your findings have to reflect what's actually happening in the property.
What Does Competence Actually Look Like?
There's no official checklist, but a competent self-assessor for an HMO would typically be able to tick all of these:
- They understand the key requirements of the RRO 2005 and BS 9792:2025 (the current British Standard for fire risk assessment)
- They know what fire hazards to look for and where to find them
- They can assess whether existing precautions — fire doors, alarms, escape routes — are actually adequate
- They can identify tenants who may be at particular risk and think through what that means in practice
- They know the property well — its layout, construction, how many people are in it and where they sleep
- They can produce a clear written record of findings and a prioritised action plan
An experienced HMO landlord who's managed multiple properties and engaged with fire safety training? Probably competent. A first-time landlord with one property and no fire safety background at all? Worth being honest with yourself about whether you're there yet.
The Five-Step Process
Whether you do the assessment yourself or use FRASafe to guide you through it, the methodology is the same. BS 9792:2025 follows five steps:
- Step 1 — Identify fire hazards. Walk through the property and look for sources of ignition (electrical appliances, smoking, cooking), sources of fuel (furniture, stored items, bedding), and sources of oxygen. Pay close attention to the kitchen, the boiler area, and anywhere materials get stacked up.
- Step 2 — Identify people at risk. Think about every occupant, where they sleep, and whether anything about them — mobility issues, sensory impairments, language barriers, heavy sleeping — might affect their ability to respond to an alarm and get out safely.
- Step 3 — Evaluate and reduce risks. Look honestly at your existing precautions: fire detection, escape routes, fire doors, emergency lighting, fire-fighting equipment. Where are the gaps? How serious are they?
- Step 4 — Record your findings and produce an action plan. Write it all down. A written record is a legal requirement, and your council will want to see it when you apply for your HMO licence. Prioritise actions by severity — don't just list problems, say when you're going to fix them.
- Step 5 — Review regularly. Reassess after significant changes — new tenants, building work, change in layout — and do a full review at least once a year.
This Is Where FRASafe Genuinely Helps
FRASafe walks you through every one of these steps in a structured online questionnaire built specifically to BS 9792:2025. It asks the right questions in the right order — which means you won't miss a category, you won't forget to check something, and you won't produce a document that looks like you just filled in a generic template.
At the end, it produces a properly structured PDF report with your findings, risk ratings, and action plan in exactly the format councils expect. You complete the assessment for free — the PDF costs £45. For a competent landlord with a straightforward HMO, that's a significant saving over the £200–500 a professional assessor would charge, with the same legal outcome.
To be clear: FRASafe doesn't make you competent. It's a tool for someone who already is. But it ensures a competent person applies the correct methodology consistently and produces a document that reflects the full current legal standard.
When to Use a Professional Assessor Instead
Self-assessment is right for many HMOs — but not all. You should get a qualified assessor from a body like the IFE, IFSM, or BAFE if:
- Your HMO is large or complex — many rooms, multiple stairwells, unusual layouts, basement areas. These present assessment challenges that benefit from professional experience.
- There's been a fire or a near-miss at the property, or a fire service enforcement notice has been issued. An independent professional assessment is the right response.
- Your tenants have significant disabilities or complex care needs. Higher-risk occupancy warrants a more thorough assessment.
- Your council's HMO licensing conditions specifically require the assessor to hold a recognised qualification. Check this before you start — requirements vary by council.
- You're genuinely not confident in your own competence. The cost of a professional (£200–500 typically) is a fraction of the cost of getting it wrong.
Not sure which type of assessment your property needs? Our guide to BS 9792:2025 assessment types explains the difference between a Type 1 self-assessment and a Type 2, 3, or 4 inspection — and which scenarios need which.
The Bottom Line
The law allows competent HMO landlords to do their own fire risk assessment. If you genuinely know your stuff, FRASafe gives you the structure and methodology to do it correctly — producing a BS 9792:2025-aligned report that's ready for your council licence application, for £45. For complex or high-risk properties, spend the money on a qualified professional. But for a straightforward HMO with a competent, experienced landlord behind it, this is genuinely the smartest way to get it done.
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