HMO Licence Fire Risk Assessment Requirements by Council

Every HMO licence application in England requires a fire risk assessment. But what that assessment must cover — and the format councils expect — varies from one local authority to the next. This guide summarises how major UK councils approach fire risk assessment requirements for HMO licensing and what landlords need to provide.

Note: Council requirements change. Always check your local authority's current HMO licensing guidance before submitting an application.

The Legal Baseline

All councils operate within the same statutory framework. Mandatory HMO licensing applies to properties occupied by five or more people forming two or more households, with shared facilities, over three or more storeys. Many councils have also introduced additional and selective licensing schemes that extend these requirements to smaller properties.

Under the Housing Act 2004 and the Housing Health and Safety Rating System (HHSRS), councils must satisfy themselves that an HMO is safe before granting a licence. A written fire risk assessment — aligned with the RRO 2005 and typically BS 9792:2025 — is the standard way of demonstrating fire safety compliance.

What Most Councils Expect

Regardless of the specific council, a compliant HMO fire risk assessment submitted for licensing purposes will generally need to include:

• The date of assessment and the name and contact details of the assessor
• A description of the property: address, number of floors, number of rooms, and current occupancy
• An identification of fire hazards found in the property
• An identification of people at risk and any vulnerability considerations
• An evaluation of the existing fire precautions — detection systems, escape routes, fire doors, extinguishers
• A risk rating (low, medium, high) for the property overall and for specific hazards
• A prioritised action plan listing deficiencies and remediation steps
• A signed declaration by the responsible person confirming they have read and understood the findings

London

London has the highest concentration of HMOs in England, and licensing requirements vary significantly between boroughs. Many London boroughs operate additional licensing schemes that extend mandatory licensing requirements to smaller properties.

Most London boroughs expect a written FRA produced by a “competent person” aligned with BS 9792:2025 and the RRO 2005. Some boroughs — including Tower Hamlets and Newham — have historically been more prescriptive about assessor qualifications. Landlords in London should check their specific borough's licensing conditions.

Manchester

Manchester City Council operates both mandatory and additional HMO licensing schemes. The council's licensing guidance specifies that a fire risk assessment must be provided with the licence application and must cover the common areas of the property. Manchester generally accepts self-conducted assessments from competent landlords, provided the document is comprehensive and property-specific.

Birmingham

Birmingham City Council is one of the largest HMO licensing authorities in England. The council operates a mandatory licensing scheme and has historically run additional licensing schemes in high-density areas. Birmingham's licensing conditions require a written FRA that addresses the standard five-step methodology. The council's inspectors carry out HHSRS assessments alongside licensing inspections and will check that fire precautions are consistent with the FRA findings.

Leeds

Leeds City Council operates mandatory HMO licensing and has run selective licensing schemes in several areas of the city. Leeds expects a written FRA produced in accordance with the RRO 2005. The council provides guidance for landlords on its website covering the minimum fire safety standards expected for licensed HMOs, including requirements for interlinked alarms, fire doors, and means of escape.

Bristol

Bristol City Council operates mandatory and additional HMO licensing schemes. The council's licensing conditions require a written fire risk assessment that is reviewed annually. Bristol has been proactive in enforcing fire safety in HMOs and regularly inspects licensed properties. Assessments that are clearly generic or that do not reflect the specific layout and condition of the property are unlikely to satisfy Bristol's inspectors.

Nottingham

Nottingham City Council has one of the most extensive additional licensing schemes in England, covering much of the city. The council requires a fire risk assessment with every HMO licence application. Nottingham's guidance makes clear that assessments must be property-specific and kept up to date. The council has been active in prosecuting landlords for fire safety failures.

Sheffield

Sheffield City Council operates mandatory HMO licensing and additional licensing in several areas. Sheffield's licensing conditions require a written FRA covering the common areas and, for larger HMOs, the individual rooms. The council's private housing team works closely with South Yorkshire Fire and Rescue Service.

Does Your Council Accept FRASafe Reports?

FRASafe produces a written fire risk assessment document that meets the requirements of the RRO 2005 and BS 9792:2025. The report includes all of the elements that councils routinely require: assessor details, property description, hazard identification, risk evaluation, action plan, and a signed declaration.

The format is the standard format that local authorities accept as a written fire risk assessment. If your council has any specific additional requirements, check their guidance — but for the vast majority of HMO licensing applications, a FRASafe report provides exactly what is needed.

Summary

All English councils require a written FRA for HMO licence applications. While the specific format varies, a document that follows the five-step RRO 2005 methodology and reflects BS 9792:2025 will satisfy the requirements of most councils. FRASafe produces exactly this — free to complete, £45 for the PDF.