Can I Do My Own Fire Risk Assessment for an HMO?

If you own or manage a House in Multiple Occupation, you already know you need a fire risk assessment. But before you call a professional assessor, you might be wondering: can I just do this myself? The short answer is yes — in most cases, the law permits a landlord to carry out their own fire risk assessment for an HMO. But there are conditions, and getting it wrong carries serious consequences.

This guide explains exactly what the law requires, what "competent" actually means, what your fire risk assessment needs to cover, and how a structured tool like FRASafe makes self-assessment both practical and defensible.

What the Law Actually Says

The Regulatory Reform (Fire Safety) Order 2005 (RRO 2005) is the primary legislation governing fire safety in HMOs. Under Article 9, the "Responsible Person" — typically the landlord or managing agent — must ensure a suitable and sufficient fire risk assessment is carried out and that its findings are recorded.

Crucially, the RRO 2005 does not say the assessment must be carried out by an external professional. What it does require, under Article 18, is that whoever carries it out must be a competent person:

"A person is to be regarded as competent… where the person has sufficient training and experience or knowledge and other qualities to enable the person properly to assist in making or reviewing the assessment."

There is no prescribed qualification, no mandatory accreditation, and no legal bar on a landlord completing the assessment themselves — provided they can demonstrate competence.

What Does "Competent" Mean for an HMO Landlord?

The government's guidance is intentionally non-prescriptive: the level of competence required is proportional to the complexity of the premises. An HMO — with shared escape routes, multiple occupants, fire doors, and detection systems — sits at the more complex end of the residential spectrum.

In practice, this means a competent HMO landlord needs to understand:

• How fire spreads through a building and what slows it down
• What constitutes an adequate means of escape
• The required standards for fire doors, detection systems, and emergency lighting
• How to identify hazards and assess risk from them
• What actions need to be taken and by when

The new British Standard BS 9792:2025 — the current code of practice for residential fire risk assessments — places particular emphasis on competence, stating that no assessment can be considered suitable or sufficient unless carried out by someone with the appropriate level of knowledge and judgement. Following a structured, BS 9792:2025-aligned framework is the clearest way to demonstrate you've met that bar.

Is a Fire Risk Assessment Required for an HMO Licence?

Yes — and this is non-negotiable. Under the Housing Act 2004, mandatory HMO licensing applies to properties occupied by five or more people forming two or more households. Local authorities can also extend licensing to smaller HMOs through Additional Licensing schemes.

While the Housing Act 2004 does not contain a single provision that reads "submit a fire risk assessment", virtually every local authority in England requires a current written FRA as part of the licence application or as an ongoing licence condition. Our council-by-council guide to HMO licence fire risk assessment requirements shows just how consistent this expectation is across England.

In short: no fire risk assessment means no licence. No licence means you cannot lawfully let the property to the required number of tenants.

What Does an HMO Fire Risk Assessment Need to Cover?

A suitable and sufficient FRA for an HMO must assess all of the following areas. This is what local authorities and fire services will expect to see documented. For a deeper breakdown, see our complete HMO fire risk assessment guide.

• Means of escape — staircases, corridors, landings, and final exits leading to a place of safety
• Fire doors — FD30 self-closing doors with intumescent strips, smoke seals, and correct ironmongery on all rooms leading onto the escape route
• Fire detection and alarm system — interlinked smoke and heat detectors meeting the required grade and category for the property
• Emergency lighting — required in most converted HMOs of three or more storeys, or where there is no effective borrowed light
• Fire-fighting equipment — fire extinguishers, including type, location, and maintenance records
• Compartmentation — floors, walls, and ceilings that contain fire spread between units
• Hazard identification — sources of ignition, combustible materials in escape routes, electrical installations, gas appliances
• Management and procedures — fire action notices, evacuation strategy, tenant information, record-keeping
• Individual rooms — BS 9792:2025 and most local authorities require the assessment to extend into each unit, not just the common parts

The assessment must also set out what actions are required, who is responsible for them, and a timescale for completion. It needs to be reviewed regularly — most HMO licences make annual review a formal condition. See our guide on how often an HMO fire risk assessment needs to be done for the full picture.

What Happens If You Don't Have One?

The consequences of failing to carry out a suitable fire risk assessment are serious. Under the RRO 2005, fire and rescue authorities can prosecute the Responsible Person. The maximum penalty at Crown Court is an unlimited fine and up to two years' imprisonment.

Under the Housing Act 2004, local authorities can impose civil penalties of up to £30,000 per breach, revoke your HMO licence, and — in persistent cases — seek a banning order preventing you from letting or managing property altogether. Tenants in an unlicensed HMO can also apply to a Tribunal to reclaim up to 12 months' rent. For a full breakdown of what enforcement looks like in practice, read our guide to failing an HMO fire risk assessment inspection.

These are not theoretical risks. Fire and rescue services recorded over 10,000 fire door violations in their 2024–25 audit cycle, with fewer than 60% of audited premises passing as satisfactory.

A Note on the Fire Safety (England) Regulations 2022

In force since January 2023, the Fire Safety (England) Regulations 2022 introduced additional duties for all multi-occupied residential buildings with two or more sets of domestic premises. For most HMOs this means providing fire safety instructions to residents, conducting regular fire door checks, and keeping maintenance records. These duties sit alongside — not instead of — your fire risk assessment obligations under the RRO 2005.

DIY vs Professional Assessor: When Does Each Make Sense?

A self-completed assessment is a legitimate and cost-effective option for many HMO landlords — particularly those with smaller, straightforward properties and the time to work through the process carefully. It is your responsibility as the Responsible Person, and using a guided tool designed around BS 9792:2025 means your assessment follows the same framework a professional would use.

There are situations where a professional third-party assessor is the better choice: very large or complex HMOs, properties above 11 metres in height, buildings with unusual construction or significant fire safety concerns, or where a local authority has specifically required an accredited assessment as a licence condition. If you are unsure, check with your local council before proceeding.

How FRASafe Makes Self-Assessment Practical

The barrier for most landlords is not legal — it is knowing exactly what to look for, room by room, and how to record it in a format that satisfies the council. FRASafe guides you through a BS 9792:2025-aligned assessment covering every area listed above, asking the right questions in the right order so nothing is missed.

You do not need to be a fire safety professional. You need to be systematic, thorough, and able to demonstrate that you assessed the right things. FRASafe provides the structure — you provide the knowledge of your property. For a step-by-step walkthrough of the process itself, see our guide on how to do your own HMO fire risk assessment.

FRASafe guides you through a BS 9792:2025-aligned assessment — free to complete, £45 for the council-ready PDF.

Summary

• The RRO 2005 does not prohibit landlords from completing their own fire risk assessment — it requires the assessor to be a competent person
• HMOs are complex premises; competence means understanding fire spread, escape routes, detection standards, fire doors, and risk management
• A written FRA is required for HMO licensing in virtually every local authority in England
• The assessment must cover common parts and individual rooms, be recorded in writing, and reviewed annually
• Non-compliance can result in unlimited fines, imprisonment, licence revocation, and rent repayment orders
• A guided tool aligned to BS 9792:2025 is the most practical way for a landlord to self-assess with confidence