HMO Licence Fire Risk Assessment Requirements by Council

Every HMO licence application in England requires a fire risk assessment. That's the legal baseline — no exceptions. But what the assessment needs to cover, and what format your council expects it in, varies from one local authority to the next. Some councils are relaxed about self-conducted assessments; others are much more prescriptive.

Important: council requirements change. Always check your local authority's current HMO licensing guidance before submitting an application — don't rely on what a fellow landlord told you a year ago.

The Legal Baseline — What Every Council Works From

All councils operate within the same statutory framework. Mandatory HMO licensing (under the Housing Act 2004) applies to properties with five or more people from two or more households sharing facilities across three or more storeys. But many councils have introduced additional and selective licensing schemes that pull smaller properties into scope too — so don't assume you're exempt just because your HMO is smaller.

Under the Housing Act 2004 and the Housing Health and Safety Rating System (HHSRS), a council has to be satisfied your HMO is safe before it hands over a licence. A written fire risk assessment — aligned with the RRO 2005 and ideally reflecting BS 9792:2025 — is the standard way of demonstrating that.

What Most Councils Want to See

The format varies, but a compliant fire risk assessment submitted for HMO 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, current occupancy
• A record of the fire hazards identified in the property
• Identification of who is at risk and any vulnerability factors you found
• An evaluation of the existing fire precautions — detection systems, escape routes, fire doors, fire-fighting equipment
• A risk rating (low, medium, or high) for the property and for specific hazards
• A prioritised action plan listing what needs fixing and by when
• A signed declaration from the responsible person confirming they've read and understood the findings

Watch out: assessments that are clearly generic — where it's obvious someone just downloaded a template and ticked some boxes — are increasingly being rejected. Councils want to see that the document actually reflects your specific property.

London

London has the highest concentration of HMOs in England, and licensing requirements vary significantly between boroughs. Most London boroughs run additional licensing schemes that extend mandatory requirements to smaller properties — if you're in London, assume you need a licence unless you've specifically confirmed otherwise.

Most boroughs expect a written FRA from a "competent person" aligned with BS 9792:2025 and the RRO 2005. Some — Tower Hamlets and Newham have historically been more prescriptive here — have stricter requirements around assessor qualifications. Check your specific borough's licensing conditions before you submit.

Manchester

Manchester City Council runs both mandatory and additional HMO licensing schemes. Their licensing guidance requires a fire risk assessment with every application, covering the common areas of the property. Manchester generally accepts self-conducted assessments from competent landlords, provided the document is comprehensive and property-specific — not a cut-and-paste job.

Birmingham

Birmingham is one of the largest HMO licensing authorities in England. The council runs mandatory licensing and has operated additional licensing schemes in high-density areas. Birmingham's licensing conditions require a written FRA following the standard five-step methodology. Their inspectors carry out HHSRS assessments alongside licensing inspections and will check that your actual fire precautions match what the FRA says.

Leeds

Leeds City Council runs mandatory HMO licensing and selective licensing schemes in several parts of the city. Leeds expects a written FRA produced in line with the RRO 2005. The council publishes guidance on minimum fire safety standards for licensed HMOs — covering interlinked alarms, fire doors, and means of escape — so it's worth reading that before you carry out or commission your assessment.

Bristol

Bristol City Council runs both mandatory and additional HMO licensing schemes and is one of the more proactive councils when it comes to enforcement. Their licensing conditions require a written fire risk assessment reviewed annually. Bristol's inspectors regularly visit licensed properties, and generic assessments that don't reflect the specific layout and condition of the property won't wash. Be property-specific.

Nottingham

Nottingham has one of the most extensive additional licensing schemes in England, covering much of the city. A fire risk assessment is required with every HMO licence application, and the council is explicit that assessments must be property-specific and kept up to date. Nottingham has a track record of prosecuting landlords for fire safety failures — this is not a council to be complacent about. See also: what happens if you don't have a fire risk assessment for your HMO.

Sheffield

Sheffield City Council runs mandatory HMO licensing and additional licensing in several areas. Their licensing conditions require a written FRA covering the common areas of the property, and for larger HMOs, individual rooms too. Sheffield's private housing team works closely with South Yorkshire Fire and Rescue Service, so fire safety inspections are taken seriously.

Will Councils Accept a FRASafe Report?

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

For the vast majority of HMO licensing applications, a FRASafe report provides exactly what's needed. If your council has specific additional requirements — for example, a requirement for a BAFE-registered assessor — check their guidance first. But for standard licensing applications, the format and substance is what councils expect.

The Bottom Line

Every English council requires a written fire risk assessment for HMO licence applications. 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 — and it's built to the current standard, not the one from three years ago.