A fire risk assessment is only as good as the person who carried it out. Hire the wrong fire risk assessor for your HMO and you can end up holding a smart-looking PDF that still fails a council inspection, still triggers an enforcement notice, and still leaves you exposed to an unlimited fine under the Regulatory Reform (Fire Safety) Order 2005 (the RRO 2005). Worse, if a fire happens and the assessment missed something obvious, your insurer can decline the claim and the blame lands on you as the responsible person.
So the real question is not just whether you hold a fire risk assessment. It is whether the person who produced it counts as a competent person in the eyes of the law, and whether that person needed to be a paid consultant at all. For a lot of smaller HMOs, the honest answer is that a diligent landlord using a structured tool can do the job properly. For others, paying a professional is the only sensible call. This guide shows you how to tell the two apart, what accreditation actually means, and the exact questions to ask before you hand over money.
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The law: your FRA must be done by a competent person
In England and Wales, the RRO 2005 covers the common parts and shared areas of your HMO: the hallways, stairs, kitchens and escape routes. The individual let bedrooms fall under the Housing Act 2004 and the Housing Health and Safety Rating System (HHSRS), which your council also enforces. The two regimes overlap, and the council can act under either.
Article 9 of the Order says your assessment must be "suitable and sufficient". Nowhere does it demand a licence, a named qualification, or an outside consultant. What it requires is that the assessment be made by a competent person: someone with enough training, experience and knowledge to spot the fire hazards in your building and judge whether the precautions are adequate. You can read more about the duty in our guide to the RRO 2005 for HMO landlords.
Two things follow from this. First, competence is a test of ability, not a certificate you can buy. Second, if you delegate the work, you still carry the legal responsibility as the responsible person, so choosing a poor assessor does not shift the liability off you. Scotland and Northern Ireland run their own regimes (the Fire (Scotland) Act 2005 and the Fire and Rescue Services (Northern Ireland) Order 2006), but the competent person principle is the same across all three.
How to choose a fire risk assessor for your HMO: accreditation that means something
There is no single legal register of fire risk assessors, so accreditation is your best proxy for competence. When you choose a fire risk assessor, look for one or more of these:
- BAFE SP205. This is a UKAS-accredited, third-party certification scheme, audited by bodies such as NSI or SSAIB. It certifies the firm rather than the individual, which tells you the business has quality control, internal training and external auditing behind it. The scheme is being aligned with BS 8674, the framework for the competence of individual fire risk assessors.
- The IFE register. The Institution of Fire Engineers runs a register of Fire Risk Assessors who have proven their competence to a recognised standard. This one is about the individual doing your assessment.
- NAFRAR. The Nationally Accredited Fire Risk Assessors Register, run by the Institution of Fire Safety Managers, lists individuals who have been through an independently accredited process, tiered by the complexity of building they are cleared to assess.
None of these are legally required, but enforcing authorities and insurers recognise them, and since the Grenfell Inquiry the whole sector is moving towards UKAS-accredited certification. One practical point: a standard shared house does not need an advanced-tier assessor built for high-rise blocks. You need someone competent for sleeping accommodation of your size, and paying for more than that is money wasted.
Red flags that tell you to walk away
Cost alone is a poor filter, but a suspiciously cheap quote often signals a template job. Here is what should make you stop:
- The finished report reads as a generic template with your address dropped in, with no detail specific to your property.
- No professional indemnity insurance. Ask for the certificate. If the assessor hesitates or cannot produce one, walk away, because if they get it wrong you have nothing to fall back on.
- The report lists hazards but gives you no prioritised action plan with timescales. A list of problems and no roadmap is not a usable assessment.
- No photographs, and no reference to fire doors, compartmentation, the grade of alarm system or the condition of escape routes.
- The "assessor" is really a handyman, letting agent or general maintenance contractor with no fire safety training. Managing a property is not the same as being competent to assess its fire risk.
- They promise you a "pass" or a "fire safety certificate". No such certificate exists for an HMO, and anyone who offers one does not understand the law.
Questions to ask before you hire
A short phone call sorts the professionals from the chancers. Ask these, and listen for specifics rather than reassurance:
- Can you show me your BAFE SP205 certificate, or your entry on the IFE or NAFRAR register?
- Have you assessed HMOs of this size and storey height before? Describe one.
- What professional indemnity insurance cover do you carry?
- Will the report give me a prioritised action plan with timescales, or just a list of observations?
- Will you reference the current guidance and tell me the grade of alarm system and the fire door standard my property needs?
When you can competently do your own HMO FRA
Here is the position most consultants will not tell you: for a simpler HMO, you can carry out a proper fire risk assessment yourself, and the law backs this up. The government guidance for premises providing sleeping accommodation is written so that a responsible person can complete the assessment in less complex buildings without hiring anyone.
If your HMO is a lower-rise shared house, say two storeys, a handful of sharers, a straightforward single staircase, no basement bedsits and no complicated mixed use, you can self-assess competently. This is far easier with a structured tool that walks you through each area, prompts you on the risks that matter and produces a written record at the end. The RRO 2005 rewards an assessment that is suitable and sufficient, not one that is expensive. If you want the legal detail on this, read our guide on whether you can legally do your own HMO fire risk assessment.
Competent self-assessment means you understand the alarm and fire door standard for your property type, you can identify a fire door and recognise where compartmentation matters, you record your findings in writing, and you produce a dated action plan for anything that needs fixing. Meet that bar honestly and you satisfy the competent person test as well as any consultant would.
When you should not DIY and pay a professional instead
Self-assessment has clear limits. Bring in an accredited professional when any of these apply:
- The building is three or more storeys, or any form of high-rise.
- The layout is complex or unusual: inner rooms, long escape distances, basement or loft sleeping rooms, or a shared staircase serving many units.
- The property is mixed use, for example flats above a shop or commercial unit.
- There has been a fire, a serious near miss, or a major refurbishment that changed the layout since the last assessment.
- Your HMO licence conditions or the council specifically require a third-party assessment.
- You have read the government guide and cannot confidently apply it. That uncertainty is itself the answer.
Price should inform this decision, not drive it. It helps to know what a professional HMO fire risk assessment actually costs before you choose, but a cheap and shoddy assessment is more dangerous than none at all, because it hands you false confidence while the real risks sit unaddressed. If a proper assessment is beyond your knowledge, pay for competence and treat it as insurance.
Next steps
Start by being honest about which category your property falls into. If your HMO is a straightforward shared house, you can produce a proper written assessment yourself today. FRASafe guides you through a BS 9792:2025-aligned fire risk assessment, free to complete, with a council-ready PDF for £45.
If your building is larger, taller or more complex, use the accreditation checks and the five questions above to hire a genuinely competent assessor, and ask to see the certificate or register entry before you commit. Either way, keep the written record, because the RRO 2005 requires it and your council will ask for it first.
