The Complete HMO Fire Risk Assessment Guide 2025

Right, let's be straight about this. If you own an HMO — a House in Multiple Occupation — you are legally required to have a written fire risk assessment. Full stop. Under the Regulatory Reform (Fire Safety) Order 2005 (RRO 2005), you are the "responsible person," and if you don't have one, you're committing a criminal offence. We're talking unlimited fines and up to two years in prison. Not a letter from the council. Prison.

So here's what you actually need to know: what the assessment must cover, who can do it, what your council is looking for when you apply for your HMO licence, and how to make sure it stays valid year after year.

Do You Actually Need One?

Almost certainly yes. If your HMO has two or more households living in it, or has any shared areas — a hallway, stairwell, shared kitchen — it falls within the scope of the RRO 2005. The law covers the "non-domestic" parts of the building, which in practice means all the common areas of your HMO are covered, even though the individual bedrooms are private.

And don't think you can get away with a bare-minimum common-areas-only assessment. Many councils require a full assessment covering individual rooms too, as a condition of granting your HMO licence. Check what your local authority expects — the requirements vary.

What Must the Assessment Actually Cover?

Under BS 9792:2025 — the current British Standard for fire risk assessment — there are five things your assessment must address. Get all five right and you're in good shape. Miss one and you've got a problem.

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, but especially anyone who might need help evacuating: tenants with mobility issues, heavy sleepers, anyone who might not hear an alarm.
3. Evaluate and reduce risks — look honestly at what fire precautions you already have and where the gaps are.
4. Record, plan, inform and train — write it all down, create an emergency plan, and make sure your tenants know what to do.
5. Review and update — reassess after significant changes, and as a minimum once a year.

Means of Escape — This Is Where Most HMOs Fall Short

Means of escape is the thing councils scrutinise most closely, and it's where a lot of HMOs have genuine problems. Your assessor — whether that's you or someone you hire — needs to look at:

• Whether every bedroom has a protected escape route that leads to the final exit without passing through a high-risk area like a kitchen
• The width and condition of corridors and stairwells — are they clear, are they wide enough?
• Whether your fire doors are properly rated, fitted, and self-closing (more on this below)
• Whether escape routes are kept clear — no bikes in the hallway, no boxes on the stairs
• Whether any "inner rooms" exist — rooms you can only exit through another room, which is a serious problem in a fire
• Whether there's emergency lighting on escape routes so tenants can find their way out at 3am in smoke

Fire Detection — the Legal Minimum Isn't Always Enough

The Smoke and Carbon Monoxide Alarm (Amendment) Regulations 2022 require smoke alarms on every floor and carbon monoxide detectors in every room with a fixed combustion appliance. That's the legal minimum — but for most licensable HMOs, councils expect more.

Interlinked Grade D alarms are the standard most councils want for smaller HMOs. Larger or higher-risk properties will likely need a Grade A hardwired system with a central control panel. The right grade and category for your property should come out of the fire risk assessment itself — it's not a one-size-fits-all answer.

Fire-Fighting Equipment

Most HMOs need at least one multi-purpose (ABC) fire extinguisher in the kitchen area and a fire blanket near the hob. Higher-risk kitchens may need more. Your assessment should record what you've got, its condition, and the last service date. Don't forget — extinguishers need annual servicing.

Fire Doors — Non-Negotiable

Fire doors are genuinely life-saving. They keep fire and smoke contained long enough for your tenants to get out. A compliant fire door must be:

• Certified to FD30 or FD60 standard — that means 30 or 60 minutes of fire resistance
• Fitted with an intumescent strip and smoke seal around the frame
• Self-closing, with a properly adjusted closer that actually pulls the door shut
• Free from gaps greater than 3mm when closed — even small gaps let smoke through fast
• Never propped open, unless it has an electromagnetic hold-open device linked to the fire alarm

From January 2023, the Fire Safety (England) Regulations 2022 added a new requirement: landlords of buildings with three or more storeys must do quarterly checks on all flat entrance fire doors and annual checks on all communal fire doors. If that's your property, make sure you're documenting these checks.

Who Can Carry Out the Assessment?

Here's the honest answer: the RRO 2005 requires a "competent person" — but crucially, the law does not require any specific qualification. Competence means having sufficient training, experience, knowledge and ability to identify fire risks and know what to do about them.

That means you, as an HMO landlord, can legally carry out your own fire risk assessment — provided you genuinely know what you're doing. Before you decide whether to DIY it or hire someone, it's worth understanding which of the four BS 9792:2025 assessment types your HMO actually needs. That determines whether a visual inspection is sufficient or whether an in-person expert is required.

For complex or higher-risk properties — bigger HMOs, unusual layouts, properties with a history of fire safety issues — get a qualified assessor from a recognised body like the IFE, IFSM, or BAFE. Don't cut corners where lives are at stake.

What Councils Look For When You Apply for Your Licence

Your council will want to see the actual fire risk assessment document when you apply for your HMO licence. Here's what they expect it to contain:

• The date of the assessment and the name of the assessor
• A description of the property and its occupancy
• A record of the hazards you identified and who is at risk
• An evaluation of your existing fire precautions
• A prioritised action plan for any gaps — with realistic timescales
• A signed declaration from the responsible person (that's you)
• Evidence it's been reviewed within the last 12 months

Watch out: councils are increasingly rejecting templated assessments that have no property-specific detail. If it looks like you just downloaded a generic form and ticked some boxes, expect it to be sent back. The substance has to be there.

Keeping It Up to Date

Your assessment isn't a one-off tick-box exercise. Under the RRO 2005, you must review it whenever you have reason to think it's no longer valid — after a fire, after structural alterations, after a change in occupancy. Most councils and most fire safety guidance also expect an annual review as a minimum.

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

The Bottom Line

A legally compliant HMO fire risk assessment must cover hazard identification, who's at risk, your existing precautions, an action plan for anything that needs fixing, and a commitment to review it regularly. It must be done by a competent person, written down, and kept current. Your council needs it for your HMO licence. Your tenants need it for their safety.

Also own a holiday let or Airbnb? The RRO 2005 applies there too — read our holiday let fire risk assessment guide.

If you want to do your own assessment and get it right first time, FRASafe walks you through every requirement of BS 9792:2025 in a structured online questionnaire — free to complete, with a council-ready PDF for £45. It's genuinely the smartest way to do it properly without paying hundreds for a consultant. Want to see what the finished report looks like before you start? View a sample FRASafe fire risk assessment report.