How Often Does an HMO Need a Fire Risk Assessment?

The Regulatory Reform (Fire Safety) Order 2005 (RRO 2005) does not specify a fixed interval for reviewing a fire risk assessment. Instead, it requires the responsible person to ensure the assessment is “kept up to date” and reviewed whenever there is reason to believe it may no longer be valid. In practice, this creates confusion — and, for many landlords, a false sense of security.

This article explains what “kept up to date” means in practice, what triggers a mandatory review, and what most councils expect when renewing an HMO licence.

The Legal Position

Article 9(3) of the RRO 2005 states that the responsible person must review the risk assessment “if there is reason to suspect that it is no longer valid or there has been a significant change in the matters to which it relates.” This is a minimum — not a cap. It means you must review whenever something changes; it doesn't mean you can go indefinitely without reviewing if nothing obviously changes.

BS 9792:2025 — the relevant British Standard — recommends that fire risk assessments are reviewed at least annually, even if no significant changes have occurred. This annual review recommendation is reflected in most council HMO licensing conditions.

What Triggers a Mandatory Review?

Regardless of how recently the assessment was produced, a review is required when:

• There has been a fire or near-miss — any fire incident should prompt an immediate review to understand whether the risk assessment identified the hazard and whether the precautions were adequate.
• There have been structural changes to the property — extension works, loft conversions, internal reconfigurations, new door or window openings, or any alteration that affects means of escape or fire compartmentation.
• There has been a change in occupancy — a significant increase in the number of occupants, a change in the vulnerability profile of occupants (for example, a new occupant with mobility needs), or a change in how rooms are used.
• New fire precautions have been installed or existing ones have failed— installation of a new alarm system, replacement of fire doors, or failure of emergency lighting.
• You have received an enforcement notice or inspection report — any formal communication from a fire service or council that identifies fire safety concerns.
• Legislation or standards have changed — for example, the introduction of new duties under the Fire Safety (England) Regulations 2022, or publication of a new British Standard.

What Most Councils Expect

For HMO licensing purposes, most councils operate on an annual review expectation. When you apply to renew an HMO licence, inspectors will check that your fire risk assessment has been reviewed within the last 12 months. An assessment that is more than a year old without any record of review is likely to be flagged.

Some councils are explicit about this in their licensing conditions — requiring landlords to confirm that the FRA has been reviewed annually and to provide an updated document at renewal. Others simply require a “current” assessment, leaving it to the inspector's judgement whether a two-year-old assessment meets that standard.

What Does a Review Involve?

A review is not necessarily a full reassessment from scratch. It involves:

1. Revisiting the property and checking whether the conditions recorded in the original assessment still apply
2. Confirming that the fire precautions identified as adequate are still in place and functioning
3. Checking that action plan items from the previous assessment have been completed
4. Identifying any new hazards, changes to the building, or changes in occupancy
5. Updating the assessment document to reflect the date of review and any findings

If nothing significant has changed, the review may be brief. But it must be documented — a record of “reviewed on [date], no significant changes found” is far better than no record at all.

HMO Licence Renewal and Your FRA

HMO licences typically run for five years, though councils can issue shorter licences where there are concerns. At renewal, your FRA must reflect the current state of the property. An assessment produced five years ago without any documented reviews is unlikely to satisfy an inspector — both because the property may have changed and because the legal standards and guidance have evolved.

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

Summary

The RRO 2005 requires your FRA to be reviewed whenever there is reason to believe it is no longer valid. BS 9792:2025 recommends annual reviews as a minimum — and most councils expect this for HMO licensing. Review triggers include fires, structural changes, occupancy changes, and legislative updates. Keep a written record of every review, even if findings are minimal. FRASafe makes the annual review process straightforward — and reminds you when it's due.