What Fire Safety Records Must an HMO Landlord Keep?

A fire officer or a council licensing inspector can arrive at your HMO and ask to see your paperwork on the spot. If you cannot produce a written fire risk assessment and the logs that sit behind it, you are exposed fast: an enforcement or improvement notice, a prohibition notice that stops you letting rooms, or a prosecution that carries an unlimited fine for the most serious breaches. When it comes to fire safety records, a landlord who has no documents is usually treated as a landlord who has done nothing, even if the building is actually safe.

That is why record keeping is not admin you can leave for later. Since a change in the law in October 2023, keeping written fire safety records is a duty in its own right, not just good practice. This guide lists exactly which records to hold, how long to keep them, and who is allowed to demand them.

Why fire safety records became a legal duty for landlords

The core duty comes from the Regulatory Reform (Fire Safety) Order 2005 (the RRO 2005), which applies to the common parts of every HMO: shared halls, stairs, landings, kitchens and any shared living space. As the "responsible person" you must carry out a fire risk assessment and act on what it finds.

What changed on 1 October 2023 was the recording rule. Section 156 of the Building Safety Act 2022 amended the RRO 2005 so that every responsible person must now record their completed fire risk assessment in full, whatever the size of the premises. Before that date, only larger or licensed premises had to write down the significant findings, and plenty of small landlords relied on a mental checklist. That gap is gone. If your assessment is not written down, you are in breach regardless of how safe the property is.

This sits alongside the Fire Safety (England) Regulations 2022, which added duties around resident information and fire doors in multi-occupied residential buildings, and the Fire Safety Act 2021, which confirmed that structure, external walls and flat entrance doors fall within the assessment.

Fire risk assessment record keeping: the documents to hold

Good fire risk assessment record keeping means holding a linked set of documents that together prove the property is managed, not just assessed once and forgotten. Here is what an HMO landlord should keep.

The written fire risk assessment

This is the foundation. It must record the hazards, the people at risk, the control measures already in place, and an action plan for anything outstanding, with dates. Keep every version, not just the latest one. When you review and update it, the old copy shows the history of decisions and demonstrates you reviewed it after a change of tenants, a refurbishment or an incident. If you want a fuller picture of what happens when this document is missing, read our guide on the consequences of having no HMO fire risk assessment.

Alarm and emergency lighting test logs

A fire alarm system to BS 5839-6 needs regular testing, and the value is in the log, not the memory. For a shared HMO that usually means a weekly user test of a call point, plus a professional service, typically every six months. Emergency lighting to BS 5266 needs a short monthly function test and an annual full-duration discharge test. Write down the date, what you tested, the result and who did it. A fire officer will often ask for the logbook before anything else, because a maintained log is quick proof the systems actually work. Our guide to emergency lighting in HMOs explains the test regime in detail.

Fire door check records

Fire doors are a standard control in HMOs, protecting escape routes and buying tenants time. You should record routine checks of the doors and their components: gaps, seals, self-closers, hinges and glazing. In buildings with storeys above 11 metres the Fire Safety (England) Regulations 2022 make quarterly checks of common-part fire doors and annual checks of flat entrance doors a legal duty, but for any HMO a written check record is the evidence that the doors are being maintained. See our guide on how often to check HMO fire doors and what to look for.

EICR and any PAT records

Electrical faults are a leading cause of fires, so your electrical paperwork is part of your fire safety file. Under the Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020, you must have the fixed wiring inspected and tested at least every five years and hold the Electrical Installation Condition Report (EICR). You must give a copy to existing tenants within 28 days of the test and to new tenants before they move in. If you supply appliances, keep any portable appliance testing (PAT) records with the EICR. Where the report flags remedial work, keep the written confirmation it was completed within 28 days, or within the period the report specifies.

Gas safety certificates

If there is any gas in the property, you must arrange an annual gas safety check by a Gas Safe registered engineer and hold the Landlord Gas Safety Record (the CP12). You must give tenants a copy within 28 days of the check, give new tenants a copy before they move in, and keep each record for at least two years. Gas is not part of the fire risk assessment itself, but inspectors expect the certificate to be current and filed with the rest.

Evidence you gave tenants fire safety information

This is the record landlords most often miss. The Fire Safety (England) Regulations 2022 require the responsible person in a multi-occupied residential building to give residents clear fire safety information: what to do if a fire starts, and, where relevant, instructions on fire doors. Keep proof you provided it. A signed tenant acknowledgement at the start of a tenancy, a copy of the fire action notice displayed in the hallway, or a dated email all count. Smoke and carbon monoxide alarm provision under the Smoke and Carbon Monoxide Alarm (England) Regulations 2015, updated in 2022, should be logged the same way, including the check that alarms were working on the day the tenancy began.

How long to keep fire safety records

There is no single retention period written into the RRO 2005 for the fire risk assessment, but treat these documents as long-life records rather than something to bin each year. Keep the current fire risk assessment for as long as it is in force, and hold the previous versions too, so you can show how the property has been managed over time.

For the supporting paperwork, sensible minimums apply. Keep gas safety records for at least two years, as the regulations require. Keep each EICR until it is replaced by the next one, and give tenants their copies within the deadlines above. Keep alarm, emergency lighting and fire door logs for the life of the system, because their whole purpose is to show an unbroken maintenance history. If a fire ever happens, or a tenant brings a claim, the records you can produce for the years beforehand are what protect you, so err on the side of keeping more for longer.

Who can demand to see your records

More people can ask for these documents than most landlords realise, and you generally cannot refuse.

• The fire and rescue authority. Fire safety inspectors enforce the RRO 2005 and can inspect at any reasonable time, ask for your fire risk assessment and logs, and issue enforcement, alteration or prohibition notices if they are not satisfied.
• The local housing authority. Council environmental health and HMO licensing officers assess hazards under the Housing Act 2004 and the Housing Health and Safety Rating System (HHSRS). At licence renewal, or after a complaint, they will expect to see the same fire safety file, and a mandatory HMO licence can carry conditions requiring it.
• Your insurer. After a fire, an insurer will ask for your fire risk assessment and maintenance records before paying out. Missing or out-of-date documents give them a reason to reduce or refuse a claim, which can leave you personally liable for the loss.
• Tenants and prospective tenants. They have a legal right to specific documents, including the gas safety record and the EICR, within set timescales.

Because the same file is demanded by different bodies for different reasons, keep one organised set, digital and backed up, that you can hand over in minutes rather than hunting through drawers while an inspector waits in your hallway.

Next steps

Start by writing down the fire risk assessment itself, because since October 2023 that is the record the law now insists on, and everything else hangs off it. Then build the file around it: alarm and emergency lighting logs, fire door checks, the EICR, the gas certificate and dated proof you gave tenants their fire safety information.

If you have never produced a written assessment, or yours predates the current standard, this is the moment to fix it. FRASafe guides you through a BS 9792:2025-aligned fire risk assessment, free to complete, with a council-ready PDF for £45. That gives you the one document every inspector, insurer and licensing officer will ask for first, and a clear plan for the records you still need to put in place.