The Complete HMO Fire Risk Assessment Guide 2025

Every HMO in England requires a written fire risk assessment. Under the Regulatory Reform (Fire Safety) Order 2005 (RRO 2005), the “responsible person” — typically the landlord or managing agent — must ensure the premises have a suitable and sufficient fire risk assessment and that it is reviewed regularly. Failure to do so is a criminal offence carrying unlimited fines and up to two years' imprisonment.

This guide explains exactly what a legally compliant HMO fire risk assessment must cover, who can carry one out, what councils look for when granting an HMO licence, and how to keep your assessment up to date.

Who Is Required to Have a Fire Risk Assessment?

Any HMO that is occupied by two or more households, or that has common areas (hallways, stairwells, shared kitchens), falls within the scope of the RRO 2005. The Order applies to the “non-domestic” parts of a building — meaning the common areas of an HMO are covered even though the individual bedrooms or flats are private dwellings.

In practice, this means virtually all HMOs require a fire risk assessment for their common areas. Many councils also require a full assessment covering the individual rooms as a condition of granting an HMO licence.

What Must a Fire Risk Assessment Cover?

Under BS 9792:2025 — the current British Standard for fire risk assessment — a compliant assessment must address five key areas:

1. Identify fire hazards — sources of ignition (electrical equipment, cooking appliances, heating), sources of fuel (furniture, bedding, stored materials), and sources of oxygen.
2. Identify people at risk — all occupants, including those who may need assistance to evacuate (mobility-impaired tenants, heavy sleepers).
3. Evaluate, remove or reduce risks — assess the adequacy of existing fire precautions and identify any gaps.
4. Record, plan, inform, instruct and train — document findings, prepare an emergency plan, brief tenants.
5. Review and update — reassess whenever significant changes occur, and at least annually.

Means of Escape

Means of escape is one of the most scrutinised areas in an HMO fire risk assessment. Assessors look at:

• Whether every bedroom has a protected escape route to the final exit
• The width and condition of corridors and stairwells
• Whether fire doors are correctly rated, fitted, and self-closing
• Whether escape routes are kept clear of obstructions
• Whether any inner rooms exist (rooms that can only be exited through another room)
• The provision of emergency lighting on escape routes

Fire Detection and Warning

The Smoke and Carbon Monoxide Alarm (Amendment) Regulations 2022 require smoke alarms on every floor of an HMO and carbon monoxide detectors in every room containing a fixed combustion appliance. However, most councils expect a more comprehensive system for licensable HMOs.

Interlinked Grade D alarms are the minimum standard for most HMOs. Larger or higher-risk properties may require a Grade A hardwired system with a central control panel. The appropriate grade and category is determined through the fire risk assessment, based on the size, layout, and occupancy of the property.

Fire-Fighting Equipment

Most HMOs require at least one multi-purpose (ABC) fire extinguisher in the kitchen area, and a fire blanket near the cooking area. Higher-risk kitchens may require additional extinguishers. The assessment should record what is provided, its condition, and when it was last serviced.

Fire Doors

Fire doors are a critical life-safety measure in HMOs. They protect escape routes by containing fire and smoke long enough for occupants to exit the building. A compliant fire door must be:

• Certified to FD30 or FD60 standard (30 or 60 minutes fire resistance)
• Fitted with an intumescent strip and smoke seal
• Self-closing with a properly calibrated closer
• Free from gaps greater than 3mm when closed
• Not propped open (unless fitted with an electromagnetic hold-open device linked to the fire alarm)

From January 2023, the Fire Safety (England) Regulations 2022 require landlords of buildings with three or more storeys to conduct quarterly checks of all flat entrance fire doors and annual checks of all communal fire doors.

Who Can Carry Out the Assessment?

The RRO 2005 requires assessments to be carried out by a “competent person” — someone with sufficient training, experience, knowledge, and ability to identify fire risks and the measures needed to control them. Crucially, the law does not require the assessor to hold any specific qualification.

This means an HMO landlord can carry out their own fire risk assessment, provided they are sufficiently competent to do so. Tools like FRASafe are designed to guide competent persons through a structured, BS 9792:2025-aligned assessment — ensuring nothing is missed.

For complex or higher-risk properties (larger HMOs, properties with unusual layouts, or those with a history of fire safety concerns), engaging a qualified fire risk assessor from a recognised body such as the IFE, IFSM, or BAFE is recommended.

What Councils Look For

Local authorities assess fire risk assessment documents as part of the HMO licensing process. A council will typically expect to see:

• The date of the assessment and the name of the assessor
• A description of the property and its occupancy
• A record of identified hazards and people at risk
• An evaluation of existing fire precautions
• A prioritised action plan for any identified deficiencies
• A signed declaration by the responsible person
• Evidence that the assessment has been reviewed within the last 12 months

Councils vary in how prescriptive they are about format, but the substance — the five steps above — must be demonstrably present. Assessments that are clearly templated with no property-specific detail are increasingly rejected.

Keeping Your Assessment Up to Date

The RRO 2005 requires the responsible person to review the fire risk assessment when they have reason to suspect it is no longer valid — for example, after a fire, after structural alterations, or after a change in occupancy. Most fire safety guidance, and most councils, also expect an annual review as a minimum.

FRASafe sends annual review reminders to ensure you never let your assessment lapse before your HMO licence renewal.

Summary

A legally compliant HMO fire risk assessment must address hazard identification, people at risk, existing precautions, an action plan for gaps, and a commitment to regular review. It must be produced by a competent person, recorded in writing, and kept up to date. Councils require this document as part of every HMO licensing application.

FRASafe guides you through every requirement of BS 9792:2025 in a structured online questionnaire — free to complete, with a council-ready PDF available for £45.