What Does an HMO Fire Risk Assessor Actually Check? A Room-by-Room Walkthrough

An environmental health officer opens a bedroom door in your HMO, watches it swing loose instead of self-closing, and writes it down. That single fault can trigger an improvement notice, a prohibition notice that takes the room out of use, or a refused licence renewal, and breaches of the HMO management regulations under the Housing Act 2004 can carry an unlimited fine. So what does a fire risk assessment actually check when the assessor walks your property? Far more than a smoke alarm and an extinguisher, and this room by room hmo fire risk assessment checklist shows you exactly where they look.

A competent assessor does not wander. They work through the building in a set order, following the Regulatory Reform (Fire Safety) Order 2005 (the RRO 2005) and the newer housing fire risk assessment standard BS 9792:2025. Councils in England still lean on the older LACORS 2008 guidance when they inspect, so a good assessment reflects both. Here is what happens in each part of the house.

Your hmo fire risk assessment checklist starts at the front door

The first thing checked is the final exit: the door everyone leaves by in a fire. It must open from the inside without a key, so a thumb-turn lock or a simple nightlatch is fine, but a deadlock that needs a key on both sides is a serious defect. The assessor tests it.

Then the hallway itself, because it is almost always part of the protected escape route. They look for storage that should not be there: bikes, prams, stacked post, bin bags, anything that could catch fire or block the way out. They check the doors opening onto the hall. Every habitable room off an escape route needs a 30-minute fire door (FD30), ideally with a self-closer and intumescent strips that expand in heat to seal the gap. Gaps around the door should be tight, roughly 3mm, because a loose door lets smoke through in seconds. Mains-powered smoke detection in the hallway and emergency lighting near the exit both get tested here too. Our full guide to fire escape routes in HMOs explains how the protected route is meant to work.

The staircase and protected escape route

The stairwell is the spine of most HMOs and the part inspectors care about most. In a house of two or more storeys the staircase enclosure is expected to hold fire back for 30 minutes, giving people on the upper floors time to get down and out. The assessor checks the walls and ceiling for compartmentation, meaning fire-resisting construction with no holes where cables or pipes pass through, and they look for breaches such as a downlighter punched into a fire-rated ceiling.

Every door onto the staircase is checked as a fire door. Storage on the stairs is a straight fail, because a protected route has to stay completely clear. Emergency lighting is examined at each change of level and direction, since a power cut during a fire must not leave the stairs in darkness. On each landing they confirm linked smoke detection, so an alarm triggered on the ground floor sounds on the top floor. If the property has three or more storeys, expect the standard to be higher and the doors and detection to be looked at harder. Fire doors are a whole subject in themselves, and our guide to HMO fire door requirements covers what makes one compliant.

Kitchens: the highest-risk room in the house

Most accidental house fires start in the kitchen, so this is where the assessor slows down. They map the ignition sources: the hob, oven, grill, toaster and microwave, and they check the space around the cooker is clear of tea towels, packaging and anything that burns. Overloaded sockets and daisy-chained extension leads are noted, because a cluster of chargers and appliances behind the counter is a common cause of electrical fires.

Detection in a kitchen should be a heat detector, not a smoke alarm, because a smoke alarm over a cooker triggers constant false alarms and ends up disconnected. A fire blanket fixed near the exit route, not directly above the hob, is expected. If the kitchen sits on the escape route, and in a lot of HMOs it does, the door between it and the hallway must be a self-closing fire door, because a kitchen fire cannot be allowed to fill the only way out with smoke.

Bedrooms behind every door

In an HMO each let bedroom is treated as a separate fire risk, because the person inside may be asleep when a fire starts elsewhere. The assessor checks for a fire door on each bedroom, again a 30-minute door with a self-closer, so a fire in one room does not spread across the house while occupants sleep. They look at the door gaps and whether a self-closer has been removed or wedged open, which is one of the most common faults found.

Inside the room they check for a working smoke alarm, usually mains-powered and linked to the rest of the system, and they scan for the everyday ignition sources tenants bring in: portable heaters too close to bedding, candles, overloaded extension leads and phone chargers under pillows. Where landlords supply furniture, it must meet the Furniture and Furnishings (Fire) (Safety) Regulations 1988, so mattresses and upholstered chairs carry the correct fire labels. Windows are checked as a secondary means of escape, particularly on the ground and first floors, and any lock must open from inside without a key.

The communal lounge and shared spaces

Shared living rooms carry their own risks because they combine soft furnishings, multiple electrical devices and people relaxing off guard. The assessor checks detection in the room, the condition of sofas and their fire labels, and the electrics: television stacks, games consoles, chargers and multi-way adaptors all draw current and generate heat. They confirm the route out of the lounge is clear and that any door onto the escape route does its job. Clutter and combustible material stored in a shared space is flagged the same way it is in the hallway.

Cellars, lofts and the voids you forget

Cellars and lofts are where inspections quietly go wrong, because landlords rarely think of them as fire risks. A cellar is a known ignition point, often holding the electrical intake, a boiler, paint, fuel or gas cylinders, and a fire starting down there can climb the house unseen. The assessor checks the compartmentation between the cellar and the ground floor and expects a fire door at the top of the cellar stairs, plus detection in the cellar itself.

Lofts get checked for stored combustibles, for the state of any boiler or water tank, and for insulation packed over recessed downlighters, which is a genuine ignition hazard. If a loft or cellar has been converted into a habitable room, the standard jumps, because now it is an extra storey with people sleeping in it and the escape route below has to protect them.

Plant, meters and the electrical intake

The last stop is the services that power the house. The assessor looks at the consumer unit for age, damage and signs of overheating, and asks for the paperwork. Under the Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020 you need an Electrical Installation Condition Report (EICR) at least every five years, and any appliances you supply should be portable appliance tested. If there is a gas boiler, a current gas safety certificate is expected, along with a carbon monoxide alarm in any room with a fixed combustion appliance under the Smoke and Carbon Monoxide Alarm (England) Regulations 2015, as amended in 2022. Those alarm rules are the England version: Scotland works to its own tolerable standard and Wales to its own guidance, so check the rules for your nation.

Meter cupboards and service risers are checked for fire-stopping, because a gap where the gas or electricity supply enters the building is a hole straight through your compartmentation. Emergency lighting units are function-tested at the same time. Emergency lighting trips up a lot of landlords, so our guide to emergency lighting in HMOs sets out exactly where it is required and how it should be maintained.

Next steps

Walk your own property in this order before an inspector does. Start at the final exit, follow the escape route up the stairs, open every fire door and watch whether it closes on its own, then check the kitchen, the bedrooms, the shared rooms, and finally the cellar, loft and meters. Write down every fault and give each one a date to fix it, because an assessment without an action plan is only half a job.

If you would rather work through it properly with the standard built in, FRASafe guides you through a BS 9792:2025-aligned fire risk assessment, free to complete, with a council-ready PDF for £45. You answer the questions room by room, and you get a documented assessment and a prioritised action plan that stands up to a council inspection.