The Renters' Rights Act 2025: What HMO Landlords Need to Know About Fire Safety

If you have been waiting for the Renters' Rights Act 2025 to settle before making decisions about your HMO, here is what you need to know. The Act does not add new fire safety duties. It does not create a new fire risk assessment requirement. What it does do is make the enforcement machinery around existing fire safety law considerably sharper, and that changes the risk calculation for every landlord who has been putting their FRA off.

The Regulatory Reform (Fire Safety) Order 2005 already required you to carry out and maintain a fire risk assessment. That obligation has not changed. What has changed is how councils can pursue you when they find you have not complied, and how easily they can find you in the first place.

Three Changes That Affect Fire Safety Enforcement

1. Civil penalties are now significantly higher

Under the Renters' Rights Act 2025, civil penalties for repeated or continued housing breaches rise to a maximum of £40,000. For most single offences the ceiling is £7,000. For unlicensed HMOs specifically, the starting point for a civil penalty is £17,000.

These figures sit alongside the penalties already available under the Fire Safety Act 2021, which allows magistrates' courts to impose up to £30,000 per fire safety offence, with Crown Court proceedings carrying unlimited fines and up to two years' imprisonment. Councils now have two parallel penalty frameworks to draw on. The combined exposure for a landlord with fire safety deficiencies and an unlicensed HMO is substantial.

The full picture of what enforcement looks like in practice is covered in our post on what happens when you fail HMO fire safety requirements.

2. The Private Rented Sector database gives councils a new tool

Sections 73 to 94 of the Act create a mandatory Private Rented Sector (PRS) database. All landlords in England must register their properties. The database is not primarily a fire safety tool, but its implications for fire safety compliance are real.

Until now, councils have had incomplete visibility of rented properties in their area. The PRS database changes that. Once a property is registered, it can be cross-referenced against HMO licensing records, fire safety enforcement histories, and complaint logs. A landlord who registers a property that lacks a valid licence or has outstanding enforcement notices is effectively flagging themselves to the council.

For landlords who are already compliant, the database is a non-issue. For those who have been operating without a current fire risk assessment or a valid HMO licence, registration creates a material new risk.

3. Awaab's Law is coming to the private rented sector

Awaab's Law was introduced following the death of Awaab Ishak, a two-year-old who died from prolonged exposure to mould in a social housing property. It requires landlords to address serious hazards within legally enforceable timeframes: investigate within 14 days, begin repairs within a further 7 days, complete emergency repairs within 24 hours.

The Renters' Rights Act 2025 extends this framework to private landlords. The implementation date has not been confirmed and will follow consultation, with 2027 the likely earliest commencement for the private sector. When it arrives, the timeframes will apply to all Category 1 hazards under the Housing Health and Safety Rating System (HHSRS).

Fire is a Category 1 HHSRS hazard. That means when Awaab's Law reaches private landlords, a tenant who reports a fire safety deficiency — a blocked escape route, a missing smoke alarm, a broken self-closer on a fire door — will be able to compel action within a legally defined timeframe. Failure to comply will be an enforceable breach, not grounds for a complaint that gets ignored.

This is not yet law for private landlords. But a landlord who waits for the commencement date to start addressing fire safety deficiencies will be scrambling to catch up.

What the HHSRS Update Means for Fire Safety

Separately from the Act itself, the government has confirmed it will publish an update to the Housing Health and Safety Rating System, the framework councils use to assess hazard severity in rented homes. The revised system is expected to reflect how hazard profiles in rented housing have changed since the original HHSRS was published in 2006.

Fire remains one of the most commonly identified Category 1 hazards in HMO inspections. If the update revises how fire risk is scored or which deficiencies are classified as Category 1, the practical threshold for enforcement action could shift. A fire risk assessment completed to the current framework may need revisiting once the update is published.

What a Current Fire Risk Assessment Protects You From

A documented, up-to-date fire risk assessment does several things in this enforcement environment. It demonstrates to a council inspector that you have discharged your duty under the RRO 2005. It identifies deficiencies before an inspector does, giving you time to address them on your own terms rather than under an enforcement notice. And it creates a written record of your fire safety management, which is relevant to both civil penalty decisions and HMO licence applications.

Under the RRO 2005, you must not only carry out the assessment but keep it under review and update it when circumstances change. A one-off assessment completed three years ago and never revisited does not satisfy this obligation. Councils inspecting under the Renters' Rights Act enforcement powers will look at whether your assessment is current, not just whether one exists.

One of the most frequently cited deficiencies in enforcement cases is escape routes that were compliant on assessment day but have since been obstructed. Our guide to fire escape route requirements in HMOs covers the ongoing maintenance obligation and a quarterly inspection routine.

Next Steps

Three things worth doing before the enforcement environment tightens further:

1. Check whether your fire risk assessment is current and was carried out to BS 9792:2025. If it predates 2025, it may not reflect the updated standard.
2. Make sure your HMO licence and fire safety records are in order before you register on the PRS database. Registration gives councils a cross-reference point they did not previously have.
3. Walk your escape routes and check your fire doors now. Do not wait for an inspector to find what a quarterly check would have caught.

FRASafe guides you through a BS 9792:2025-aligned assessment — free to complete, £45 for the council-ready PDF. Start your HMO fire risk assessment here.