How Often Does an HMO Need a Fire Risk Assessment?

Right, let's be straight about this. The law doesn't say "get a new fire risk assessment every year." What it actually says is a bit more nuanced — and that's where a lot of HMO landlords either get confused, or use the ambiguity as an excuse to do nothing. Neither is a good position.

Here's what you actually need to know about how often your HMO (House in Multiple Occupation) fire risk assessment needs to be updated — and what your council is likely to expect when your licence comes up for renewal.

What the Law Actually Says

Article 9(3) of the Regulatory Reform (Fire Safety) Order 2005 — the RRO 2005, the main fire safety law for HMO landlords — says the responsible person (that's you) must review the risk assessment "if there is reason to suspect that it is no longer valid or there has been a significant change in the matters to which it relates."

So the law sets a floor, not a ceiling. You must review when something changes. But it doesn't give you a free pass to ignore the assessment for years just because nothing obvious has happened.

BS 9792:2025 — the British Standard for fire risk assessments — goes further and recommends annual reviews as a minimum, even when nothing has changed. Most councils have picked this up and built it into their HMO licensing conditions. In practice, that means annual is the expected standard.

What Triggers a Mandatory Review?

Don't wait for your annual check if any of these things happen. A review is required straight away when:

• There's been a fire or near-miss — any fire incident needs an immediate review to check whether your assessment spotted the hazard and whether your precautions held up.
• You've made structural changes — extensions, loft conversions, internal reconfigurations, new doors or windows, anything that affects escape routes or fire compartmentation.
• Your occupancy has changed — more tenants than before, or a tenant with mobility needs who'd need extra help evacuating, or rooms being used differently.
• You've installed new fire safety kit — or existing kit has failed — a new alarm system, replacement fire doors, or emergency lighting that's stopped working.
• You've had an enforcement notice or inspection report — any formal communication from the fire service or your council raising fire safety concerns.
• The law or standards have changed — for example, new duties under the Fire Safety (England) Regulations 2022, or a new British Standard being published.

What Do Councils Actually Expect at Licence Renewal?

HMO licences typically run for five years. When you renew, councils will look at your fire risk assessment — and an assessment that's more than a year old without any documented reviews is going to raise questions.

Some councils are explicit: their licensing conditions literally require you to confirm the FRA has been reviewed annually and to provide an updated document at renewal. Others just require a "current" assessment and leave it to the inspector to decide whether a two-year-old document cuts it. Spoiler: it often doesn't.

The honest answer is: assume annual reviews are required. If your council turns out to be more relaxed, great. But going into a licence renewal with a stale, unreviewed assessment is a completely avoidable risk.

What Does a Review Actually Involve?

A review isn't necessarily a full reassessment from scratch. It's a structured check:

1. Walk through the property and check whether the conditions recorded in the original assessment still match reality
2. Confirm that the fire precautions identified as adequate are still in place and working
3. Check that any action plan items from the previous assessment have been completed
4. Look for new hazards, building changes, or occupancy changes
5. Update the assessment document with the date of review and any findings

If nothing significant has changed, the review may be brief. But it must be documented. A record saying "reviewed on [date], no significant changes found" is infinitely better than no record at all — especially if you ever face an inspection.

HMO Licence Renewal and Your FRA

This is genuinely important — don't skip this bit. An assessment produced five years ago with no documented reviews is unlikely to satisfy an inspector at renewal. The property may have changed, the tenants have certainly changed, and the legal standards have evolved since the document was written.

FRASafe sends annual review reminders to licensed users, so you never miss a review ahead of an HMO licence renewal.

The Bottom Line

The RRO 2005 says review your FRA whenever something changes. BS 9792:2025 says review it at least annually regardless. Most councils expect annual reviews for HMO licensing. Review triggers include fires, structural changes, occupancy changes, and legislative updates. Keep a written record of every review — even if the outcome is "nothing significant has changed." Don't let this one catch you out at licence renewal time.