Fire Safety for an HMO You Have Just Bought: The First 30 Days

Buy an HMO and carry on operating under the seller's old licence, and you are committing a criminal offence from day one. HMO licences do not transfer with the property: the moment ownership changes, the previous licence becomes invalid, and running the property unlicensed can mean an unlimited fine, a civil penalty of up to £30,000, and a rent repayment order that can claw back rent already paid. The fire risk assessment you inherited with the sale paperwork is worth even less: it was written for the previous owner, not you, and it will not protect you if something goes wrong.

The licence does not come with the keys

Councils treat a change of ownership as a fresh start. Because the local authority has to satisfy itself that the new owner (or the most appropriate person, if you are using an agent) is fit and proper and capable of running a safe HMO, you have to apply for your own licence rather than simply notifying the council that the property has changed hands.

Do this in the first week, not the first month. Most councils expect an application to be submitted promptly after completion, and some will accept a temporary exemption notice while your application is processed, but that is not guaranteed and does not cover every situation. Check whether the property sits under mandatory licensing, or under your council's selective or additional licensing scheme, because the conditions attached (and the fire precautions the council expects to see) can differ from a neighbouring authority's rules.

Do not rely on the seller's fire risk assessment

The Regulatory Reform (Fire Safety) Order 2005 puts the duty to assess fire risk on the "responsible person", which from completion day is you. A fire risk assessment carried out for a previous owner, under a previous management arrangement, with previous tenants, is not a document you can simply relabel and file away. If you manage the property through a letting agent, check who actually holds that responsibility on paper, because liability does not automatically shift to the agent just because they collect the rent.

Commission your own assessment in the first 30 days, ideally before you accept your first new tenant into the property. If BS 9792:2025 applies to the type of assessment your HMO needs, make sure whoever you instruct is working to that standard, not an outdated template. Read the previous assessment if you have a copy, because it is a useful starting point for understanding the building's layout and known issues, but treat every finding in it as something to verify yourself.

This matters even more if the survey flagged nothing unusual. Surveys are not fire risk assessments, and a mortgage valuation is not a substitute for one either. A property can pass a standard survey and still have inadequate compartmentation, an alarm system that has never been serviced, or fire doors that were fitted years ago and have since dropped in their frames. None of that shows up unless someone is specifically looking for it.

Walk the building before you do anything else

Before you touch décor, furniture or lettings, spend a morning walking every room, corridor and stairwell with a fire safety checklist. Check that final exit doors open freely from the inside without a key, that escape routes are not blocked by furniture or bikes, and that any fire doors close fully into their frames and are not wedged open. Look for obvious compartmentation problems: gaps around pipework, damaged ceilings, or doors between rooms and communal areas that should have been upgraded when the property was converted.

Test every smoke alarm and heat detector in front of you, not from the paperwork. Under the Smoke and Carbon Monoxide Alarm (England) Regulations 2022, smoke alarms must be present on every storey used as living accommodation and working on the day you let the property, and a carbon monoxide alarm is required in any room with a solid fuel appliance and, since October 2022, also recommended wherever there is a gas appliance. In most HMOs this means an interlinked Grade D system at minimum, and larger or higher-risk HMOs may need a Grade A system with a control panel. Our guide to interlinked smoke alarms in HMOs and rented homes covers which grade applies to which property type.

While you are walking round, check the emergency lighting if the property has it, particularly on staircases without natural light or in basements. Emergency lighting installed to BS 5266 needs a functioning battery backup, and a unit that no longer illuminates when you cover the sensor or flick the test switch is a defect, not a detail to note for later. Check the kitchen too: shared kitchens are a common source of accidental fires in HMOs, so look at the condition of extractor fans, the state of any fire blanket, and whether cookers are positioned away from escape routes.

Get the paperwork in order from day one

Since 1 October 2023, section 156 of the Building Safety Act 2022 has removed the old exemption that let smaller premises get away without a written fire risk assessment. Every responsible person, regardless of how many people they employ, must now record the assessment and the fire safety arrangements in writing. For an HMO this record needs to sit alongside your gas safety certificate, electrical installation condition report (required at least every five years under the Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020), and any HMO management records the council expects you to keep under the Housing Act 2004.

Set up a simple file, physical or digital, on day one: the fire risk assessment, alarm test records, fire door inspection dates, and a copy of your licence application receipt. If the council inspects within your first few months, and for newly licensed HMOs that is common, having this ready is the difference between a quick sign-off and a list of remedial works with a deadline attached.

Know what you are actually liable for

Fire safety prosecutions against HMO landlords have resulted in five and six figure fines, and sentencing guidelines treat a lack of a written fire risk assessment as an aggravating factor, not a minor paperwork slip. Buying a property with tenants already in situ does not delay when your duties start. If you buy with sitting tenants, your obligations under the RRO 2005 and the Housing Act 2004 begin at completion, even if you have not yet met the people living there. Read up on what UK landlords have actually paid for fire safety failures before you decide any of this can wait until next month.

If the property needs compartmentation work, new fire doors, or an upgraded alarm system, get quotes in your first 30 days even if the work itself takes longer to schedule. Councils are generally willing to agree a reasonable timetable for remedial works if you can show you have identified the problem and are acting on it. What they are far less forgiving about is a landlord who bought a licensed HMO, assumed everything was fine, and did nothing.

Brief existing and new tenants early

If you have bought a tenanted HMO, introduce yourself in writing within the first week and confirm the basics: where the fire extinguishers and fire blanket are, what the escape route is from each room, and what to do if an alarm sounds. Do not assume the previous landlord covered this, and do not assume tenants who have lived there for years actually know where the final exit is if the main stairwell is blocked. A short written notice pinned in the communal hallway, alongside your fire action notice, costs nothing and closes an obvious gap.

For any new tenant moving in during your first month, build a fire safety induction into the check-in process rather than treating it as optional paperwork. Councils increasingly ask to see evidence of tenant fire safety information as part of licence conditions, and it is far easier to build the habit from your very first letting than to retrofit it once you have a dozen tenants across the building.

Next steps

Do not let a completed purchase lull you into thinking the hard part is over. In your first 30 days: apply for your own HMO licence, commission your own fire risk assessment, physically check every alarm and escape route, and start a compliance file that would satisfy a council inspector arriving unannounced. FRASafe guides you through a BS 9792:2025-aligned fire risk assessment, with a PDF report for £45, so you can get a proper written assessment in place before your first new tenant moves in. Start your HMO fire risk assessment today rather than waiting for an inspection to force the issue.