Do I Need a Fire Risk Assessment for My HMO?

The short answer

Yes. If you let a House in Multiple Occupation (HMO) — three or more unrelated occupants sharing facilities — you are required to have a fire risk assessment under the Regulatory Reform (Fire Safety) Order 2005.

You are also subject to:

• Housing Act 2004 — for HMO licensing
• Smoke and Carbon Monoxide Alarm Regulations 2015 (amended 2022) — for alarm provision
• Electrical Safety Standards Regulations 2020 — for EICR
• Local authority HMO licence conditions — these vary borough by borough

What "HMO" means for fire safety law

The Fire Safety Order applies to the common parts — staircase, hallway, kitchen if shared, garden access. It does NOT apply to the inside of a tenant's room.

The Housing Act 2004 applies to the building as a whole and is enforced by the Local Authority Housing Standards Team.

What an HMO FRA must cover

A competent HMO FRA covers:

• Means of escape — direct, protected, unobstructed
• Compartmentation — every tenant room as a 30-minute fire compartment minimum
• Fire detection — typically a BS 5839-6 Grade A LD2 system for medium-sized HMOs; Grade A LD1 for larger or higher-risk
• Means of giving warning
• Emergency lighting (BS 5266 if the escape is internal and complex)
• Fire fighting equipment (extinguishers in kitchens, fire blankets)
• Fire safety information for tenants
• Tenant management arrangements

How often the FRA must be reviewed

There is no statutory frequency — but industry good practice is:

• Annually for active reviews
• Whenever a tenant moves in or out
• After any building modification
• After any fire safety incident or false alarm cluster

HMO licensing requirements

Larger HMOs (5+ tenants forming 2+ households) require a Mandatory HMO Licence. Smaller HMOs may require an Additional or Selective Licence depending on the borough.

Most licence conditions require:

• A current FRA on file with the LA
• Compliant fire alarm system (typically BS 5839-6 Grade A LD2 or LD1)
• Fire doors at every habitable room and kitchen
• Emergency lighting where required
• Annual EICR

Common HMO FRA findings

Walking HMOs across London, MetroFire engineers consistently find:

• Modified flat entrance doors that no longer achieve 30-minute resistance
• Combustible storage on escape routes
• Smoke alarms in habitable rooms but no kitchen heat detector
• Missing emergency lighting on internal staircases
• Tenant-installed locks that prevent escape

Penalties

LAs are enforcing HMO fire safety more aggressively than ever. Civil penalties up to £30,000 per offence can be issued. Criminal prosecutions under the Fire Safety Order carry unlimited fines and up to two years' imprisonment.

MetroFire delivers HMO Fire Risk Assessments and compliant BS 5839-6 alarm installations across London and Essex. Book yours.