Fire Safety (England) Regulations 2022 — What HMO Landlords Must Do Now

The Fire Safety (England) Regulations 2022 came into force on 23 January 2023 and introduced a new set of obligations for landlords of multi-occupied residential buildings. While some provisions target high-rise buildings specifically, several requirements apply directly to HMOs — and many landlords are not yet aware of them.

This article sets out which requirements apply to HMOs, what landlords must have in place, and how the Regulations interact with the existing duties under the Regulatory Reform (Fire Safety) Order 2005.

Background: Why Were the Regulations Introduced?

The Regulations were introduced following the Grenfell Tower fire and the subsequent Hackitt Review, which identified significant gaps in fire safety compliance across the residential sector. They sit alongside the Fire Safety Act 2021, which extended the scope of the RRO 2005 to clarify that the structure, external walls, and flat entrance doors of multi-occupied residential buildings are within scope.

Together, the Fire Safety Act 2021 and the Fire Safety (England) Regulations 2022 represent the most significant legislative update to residential fire safety since the RRO 2005 itself.

Which Requirements Apply to HMOs?

Buildings with Three or More Storeys

For multi-occupied residential buildings with three or more storeys (including HMOs), the Regulations require the responsible person to:

• Conduct quarterly checks of all flat entrance fire doors — checking that self-closing devices work correctly, that there are no obvious defects, and that the door closes properly on its frame.
• Conduct annual checks of all communal area fire doors — a more thorough inspection covering intumescent strips, smoke seals, hinges, and closers.
• Display fire safety instructions in the communal areas of the building, including information about the evacuation strategy, how to report fire safety concerns, and the location of fire-fighting equipment.

All Multi-Occupied Residential Buildings

Regardless of height, the Regulations also require the responsible person to provide residents with relevant fire safety information, including:

• The building's evacuation strategy (simultaneous or stay-put)
• How to report a fire or fire safety concern
• Information about any fire safety features relevant to residents

This information must be provided to each resident when they move in and whenever it is updated. It must also be re-issued to all residents at least annually.

How This Interacts with Your Fire Risk Assessment

The fire door check requirements under the 2022 Regulations must be recorded as part of your fire safety management. BS 9792:2025 explicitly incorporates these duties — so a fire risk assessment produced to the 2025 standard will include a section documenting whether the required checks are in place and up to date.

If your fire risk assessment pre-dates January 2023, it will not reflect these new duties. A review and update is required.

What Are the Penalties for Non-Compliance?

Failure to comply with the Fire Safety (England) Regulations 2022 is a criminal offence under the RRO 2005, carrying the same penalties: unlimited fines and up to two years' imprisonment. Enforcement is carried out by local fire and rescue services, who have powers to inspect premises and issue enforcement notices.

Councils may also take the absence of compliant fire safety documentation into account when assessing HMO licence applications and renewals.

Practical Steps for HMO Landlords

1. Review your fire risk assessment — if it pre-dates January 2023, update it to reflect the Regulations' requirements.
2. Implement a fire door inspection schedule — quarterly for flat entrance doors (in three-storey+ buildings), annual for communal doors.
3. Prepare a fire safety information document for residents covering evacuation strategy, reporting procedures, and fire safety features.
4. Issue the information to residents on move-in and at least annually thereafter.
5. Display signage in communal areas if your building has three or more storeys.

Summary

The Fire Safety (England) Regulations 2022 introduced new fire door inspection duties for three-storey+ buildings and resident information requirements for all multi-occupied residential buildings. HMO landlords who have not updated their fire risk assessments and practices since January 2023 are likely non-compliant. FRASafe's assessment covers these duties as part of its BS 9792:2025-aligned questionnaire.