Can I Complete My Fire Risk Assessment Online? What HMO Landlords Need to Know

Yes, you can complete your fire risk assessment online — and the result is every bit as legally valid as one produced after an in-person visit. The Regulatory Reform (Fire Safety) Order 2005 does not specify how an assessment must be conducted. It specifies what the outcome must be. If an online fire risk assessment covers the right areas, produces a written record, and is completed by someone with sufficient knowledge of the property, it satisfies the law.

This post explains exactly what makes any fire risk assessment legally valid, what a compliant online tool must cover, and how to tell the difference between a tool that produces a council-ready document and a blank template that will get you nowhere.

What the law actually requires

The legal obligation comes from Article 9 of the RRO 2005: the responsible person — in an HMO, almost always the landlord — must carry out a "suitable and sufficient" fire risk assessment and record the findings in writing. That phrase, "suitable and sufficient," is deliberately outcome-based. The legislation does not prescribe the method, the format, or the delivery channel.

Since 1 October 2023, under Section 156 of the Building Safety Act 2022, all fire risk assessments must record the full findings in writing — including identified hazards, people at risk, existing precautions, and any actions required. A summary or a mental walkthrough is no longer sufficient regardless of property size.

The assessment must also be completed by a competent person. The RRO 2005 does not require a third-party professional. A landlord or manager who has sufficient knowledge of the property and fire safety principles qualifies. An online tool that guides that person through every relevant question — and produces a document reflecting their specific property — satisfies the competency test. For a broader look at how self-assessment works in practice, see our guide to whether you can do your own HMO fire risk assessment.

What makes an online fire risk assessment legally valid

Three things determine whether any fire risk assessment — online or otherwise — meets the legal standard:

1. Coverage. It must address all the areas required by BS 9792:2025, the British Standard for fire risk assessments in housing including HMOs. A tool that skips escape routes, or ignores fire detection grades, does not produce a suitable and sufficient assessment.
2. Property-specificity. The document must reflect the actual condition of your specific HMO — not a hypothetical property. Generic tick-box templates that produce identical outputs regardless of what you enter do not meet this standard.
3. Written record. The output must be a dated, signed document that records findings, identifies risks, and sets out the actions required. A completed online assessment that produces this document satisfies the written record requirement.

If an online tool delivers all three, the resulting document is legally equivalent to one produced after a physical site visit by a professional assessor.

What your online fire risk assessment must cover

Under BS 9792:2025, a fire risk assessment for an HMO must address the following areas without exception:

• Fire hazards and ignition sources — electrical equipment, cooking appliances, smoking materials, arson risk
• People at risk — number of occupants, any vulnerabilities, sleeping arrangements
• Means of escape — corridors, stairwells, final exits, travel distances, escape route condition
• Structural fire protection — fire doors, compartmentation, wall and ceiling integrity
• Fire detection and warning systems — alarm grade (D1 or A), interconnection, heat alarms in kitchens, CO detectors
• Firefighting equipment — extinguisher type and placement
• Emergency lighting — coverage of escape routes and stairwells
• Management procedures — testing records, tenant briefing, review schedule
• Action plan — prioritised list of deficiencies with remediation steps

If the tool you are using does not ask about all of these areas, the document it produces will not be suitable and sufficient. This matters because a council licensing officer reviewing your FRA will check for coverage — and gaps will result in the document being rejected. For a detailed breakdown of the standard behind these requirements, see our guide to BS 9792:2025 fire risk assessment types for HMOs.

Online tool vs. blank template: how to tell the difference

Not everything marketed as an online fire risk assessment produces a legally valid document. Here is how to distinguish a proper tool from an inadequate template:

A compliant online tool will:

• Ask questions specific to your property — number of storeys, occupancy, building age, heating type
• Apply logic to your answers — flagging higher-risk configurations automatically
• Cover all BS 9792:2025 areas with no option to skip
• Produce a dated, signed PDF with findings and an action plan specific to your answers
• Reflect the current standard — BS 9792:2025, not the 2020 or earlier version

An inadequate template will:

• Produce the same document regardless of what you enter
• Use generic commercial premises language not written for HMOs
• Leave large sections blank for you to fill in without guidance
• Have no logic or risk weighting behind the questions
• Not reference BS 9792:2025 or the RRO 2005 in its output

Many of the free council templates fall into the second category. They exist to give landlords a starting point — not to produce a council-ready document on their own.

FRASafe is built specifically for HMO landlords. Every question maps to a requirement under BS 9792:2025 or the RRO 2005. The output is a property-specific PDF accepted for mandatory, additional, and selective HMO licensing applications. You can start your assessment here — it is free to complete, £45 for the PDF.

What about complex or large HMOs?

For most HMOs — including converted terraces, purpose-built blocks up to four storeys, and bedsit-style properties — an online assessment completed by a knowledgeable landlord or manager is entirely appropriate. The law does not require a professional visit for these properties.

There are situations where bringing in a third-party assessor is the right call: very large or high-rise HMOs, properties with complex compartmentation or non-standard layouts, buildings that have recently undergone structural changes, or cases where a previous assessment identified serious failings that require independent verification. If your property falls into one of these categories, use an online tool to identify the gaps first, then engage a professional to verify and sign off.

Not sure which situation applies to your HMO? The complete HMO fire risk assessment guide sets out what a full assessment involves and when professional input is advisable.

How FRASafe works

FRASafe walks you through a structured questionnaire covering every area required by BS 9792:2025. It is built for HMO landlords — not adapted from a generic workplace template.

The process takes 30 to 45 minutes for a typical HMO. You answer questions about your specific property: its layout, occupancy, fire detection, escape routes, fire doors, and management arrangements. The tool applies risk logic to your answers and flags areas of concern as you go.

At the end, you receive a written fire risk assessment specific to your property — dated, structured, and covering all areas required for HMO licensing. The document includes a prioritised action plan for any deficiencies identified. It is accepted by local authorities for mandatory, additional, and selective licensing applications across England.

The assessment is free to complete. The council-ready PDF is £45. There is no subscription, no recurring fee, and no requirement to use FRASafe again until your next review — though best practice under BS 9792:2025 is an annual reassessment. For context on how often your HMO legally requires a new assessment, see our guide to how often an HMO needs a fire risk assessment.

Not having a written FRA at all carries serious consequences — unlimited fines, licence revocation, and the risk of rent repayment orders. Our post on what happens if you don't have a fire risk assessment for your HMO sets out exactly what enforcement looks like.

Next steps

An online fire risk assessment is legally valid. It is practical. And for the vast majority of HMO landlords, it is the right way to get compliant without paying hundreds of pounds for a professional visit to a standard property.

The only question that matters is whether the tool you use covers what the law requires. FRASafe does — aligned to BS 9792:2025, accepted for council licensing, and built specifically for HMOs.

Start your online fire risk assessment on FRASafe — free to complete, £45 for the council-ready PDF.