Fire Risk Assessment Requirements for HMOs

What is a Fire Risk Assessment (FRA)?

A Fire Risk Assessment is a structured inspection that identifies fire hazards within a property, evaluates the risk to residents, and sets out actions needed to reduce or eliminate those risks.

For HMOs, this goes beyond basic fire safety because individual tenants do not tend to know each other or operate as a household, which increases risk by law.

The purpose of an FRA is to ensure the property:

• Prevents fires from starting

• Detects fire early using alarms and monitoring

• Supports safe escape routes

• Protects tenants and emergency responders

Why HMO Fire Risk Assessments Are Mandatory

HMOs are regulated under several overlapping laws:

• Legislation Requirement

• Regulatory Reform (Fire Safety) Order 2005 FRA legally required in communal areas of any residential property

• Housing Act 2004 Defines HMO compliance standards for housing safety

• Management of Houses in Multiple Occupation (England) Regulations 2006 Requires landlords to manage fire safety measures

• Fire Safety (England) Regulations 2022 Increased obligations for multi occupied residential buildings

In simple terms:

1. FRA is legally required for all HMOs.

2. Failure to comply qualifies as a criminal offence.

Who is Responsible for Carrying Out the FRA?

The Responsible Person, usually the landlord or managing agent, must ensure the FRA is completed and kept up to date.

You can carry out a low risk FRA yourself if you are competent, but for HMOs the safest option is to use a qualified fire risk assessor, especially if the property includes:

• Three or more storeys

• Five or more tenants

• Multiple escape routes

• Fire engineered systems

• Vulnerable occupants

A professional FRA also protects you if there is ever a dispute, a fire event, an insurance claim or a local council investigation.

What Does the FRA Cover Inside an HMO?

Here are the main areas an assessor reviews:

• Smoke alarms, heat alarms and detectors

• Fire doors and closing mechanisms

• Emergency lighting

• Escape routes and protected stairways

• Fire rated partitions and ceilings

• Fire blankets and extinguishers if installed

• Gas safety and electrical safety interaction

• Kitchen risks in shared cooking spaces

• Fire stopping and compartmentation

• Signage and tenant instructions

• Arson prevention and building security

• High risk behaviour such as smoking or overloaded sockets

A quality FRA includes photos, risk ratings and a clear schedule of actions.

How Often Should an FRA Be Reviewed?

There is no fixed renewal period written into law, but guidance from fire authorities and licensing bodies is clear:

• Scenario Recommended Update

• No changes to building and no fire related events Every 12 months

• Building layout changes or tenant turnover Immediately

• Installation or upgrade of fire safety equipment Immediately

• After a fire or near miss Immediately

• Many councils request an up to date FRA during licensing or compliance audits, so yearly review is best practice.

Fire Safety Equipment Expectations in HMOs

Although the requirements vary by property size and local licensing conditions, most HMOs should include:

• Grade A fire alarm system with control panel

• Interlinked smoke and heat detectors in all rooms

• FD30 or FD60 fire doors with self closers

• Emergency lighting in escape routes

• Fire resistant signage for exits and routes

• Fire rated partitions protecting escape routes

If the FRA identifies equipment that is missing or inadequate, improvements must be completed in reasonable time.

Documentation You Must Keep

Landlords should maintain a compliance folder, digital or printed, including:

• Fire Risk Assessment report and review logs

• Fire alarm servicing records

• Emergency lighting testing

• Fire extinguisher servicing where applicable

• Electrical installation report EICR

• Gas Safety certificate

• PAT records for supplied appliances

• HMO licence and council conditions

Councils can request this documentation at any time.

Penalties for Non Compliance

Failure to provide a valid FRA or maintain fire safety measures can result in:

• HMO licence refusal

• Financial penalties up to 30,000 pounds per breach

• Rent Repayment Orders

• Criminal prosecution

• Imprisonment in cases of severe negligence

If a fire causes injury or death and the landlord failed to comply with FRA duties, liability becomes criminal and insurance may not pay out.

Best Practices for HMO Landlords

To stay compliant and protected:

• Arrange a professional FRA annually

• Complete remedial actions quickly

• Train tenants on fire safety from day one

• Display fire instructions on each floor and escape route

• Maintain a compliance folder ready for inspection

• Request post works sign off when upgrades are completed

• Align FRA dates with your EICR, Gas Safety, and Fire Alarm service schedule

Fire safety in HMOs is about protecting lives and protecting landlords from legal and financial consequences. A valid and frequently updated Fire Risk Assessment is central to HMO compliance and provides confidence that the property meets the standards expected by councils, insurers and fire authorities.