Running a House in Multiple Occupation brings stricter fire safety obligations than a standard residential let. The Regulatory Reform (Fire Safety) Order 2005 places direct responsibility on the owner or managing agent to identify fire hazards and implement protective measures for occupants. Here is a practical breakdown of what your HMO fire risk assessment needs to cover to satisfy the law.
What Counts as an HMO?
An HMO is generally a property rented out to at least three people who are not from one household but share facilities like a bathroom or kitchen. Larger HMOs—those occupied by five or more people forming at least two separate households—must be licensed under mandatory HMO licensing rules. However, fire safety duties under the RRO apply to all HMOs, regardless of size or whether licensing is required.
The Legal Duty to Assess Fire Risk
Under the Regulatory Reform (Fire Safety) Order 2005, the Responsible Person must carry out a suitable and sufficient fire risk assessment of the premises. This applies to the common areas of HMOs, such as hallways, stairwells, shared kitchens, and entrance lobbies. The assessment must identify fire hazards, determine who might be at risk, and implement reasonable measures to reduce or remove those risks.
The Management of Health and Safety at Work Regulations 1999 (MHSWR) also requires a general risk assessment where the landlord or agent acts in a capacity similar to an employer managing a workplace. For HMOs, this means the common parts must be treated with the same rigour as a commercial premises when it comes to fire safety.
What the Fire Risk Assessment Should Cover
A proper HMO fire risk assessment should systematically examine the property and its fire safety provisions. Key areas include:
- Fire detection and warning systems – Are interlinked smoke alarms fitted in the correct locations, and do they function properly?
- Escape routes – Are hallways and stairwells kept clear of combustible materials and obstructions?
- Fire doors – Do doors protecting stairwells and individual rooms meet the required standard, and are they fitted with working self-closing devices?
- Emergency lighting – Is there adequate lighting on escape routes in case of a power failure?
- Firefighting equipment – Are suitable fire extinguishers and fire blankets provided and maintained?
- Tenant information – Are occupants given clear instructions on what to do in the event of a fire?
The assessment should be recorded, reviewed regularly, and updated whenever significant changes occur, such as a change in the number of tenants or alterations to the building layout. Following recognised guidance such as PAS 79 ensures the assessment is structured and thorough.
Common Fire Safety Failures in HMOs
HMOs present unique risks because tenants often live independently and may not coordinate on safety. Common failures include:
- Blocked escape routes caused by stored items or furniture in shared hallways.
- Missing or wedged-open fire doors, which compromise compartmentation.
- Inadequate smoke alarms or alarms with dead batteries.
- Lack of emergency lighting in internal staircases.
- Poor record-keeping, making it difficult to demonstrate compliance during an audit.
Local authorities and fire and rescue services have the power to inspect HMOs, issue enforcement notices, and, in serious cases, prosecute. Failing to meet your duties can result in substantial fines or even imprisonment.
Who Can Carry Out the Assessment?
The RRO does not specify a required qualification for the assessor, but it does require that the person conducting the assessment is competent. For simple, low-risk properties, a knowledgeable landlord may feel confident doing it themselves. However, for larger or more complex HMOs, professional help is strongly recommended.
A competent assessor will have a solid understanding of fire safety principles, British Standards such as BS 5839-1 (fire detection and warning systems) and BS 5266-1 (emergency lighting), and the specific risks associated with multi-occupied housing. Using a professional ensures the assessment is thorough, defensible, and aligned with current guidance.
How Often Should an HMO Fire Risk Assessment Be Reviewed?
There is no fixed statutory interval for reviewing a fire risk assessment, but best practice and government guidance suggest reviewing it regularly. A review is necessary when:
- There is a change in the layout or use of the property.
- The number of occupants changes significantly.
- Fire safety equipment is upgraded or replaced.
- There has been a fire or near-miss incident.
- New legislation or guidance is introduced.
Even if none of these occur, a periodic review—typically annually—helps ensure the assessment remains valid and the property stays safe.
Keeping Tenants Safe and Staying Compliant
Fire safety in an HMO is not a one-off task. It requires ongoing attention, clear communication with tenants, and accurate record-keeping. By understanding and fulfilling your HMO fire risk assessment duties, you protect both your tenants and your investment.
If you need support with your HMO fire safety obligations, HawkSwift Ltd provides professional fire risk assessments from £199 + VAT, carried out by NEBOSH-qualified assessors with reports delivered within 48 hours. To get started, book a fire risk assessment with our team today.
Quick answers
Q: Do I need a fire risk assessment if my HMO is small and doesn't need a licence?
Yes, fire safety duties under the Regulatory Reform (Fire Safety) Order 2005 apply to all HMOs regardless of size or licensing status. As the responsible person, you must carry out a suitable and sufficient fire risk assessment of the common areas.
Q: What areas of my HMO does the fire risk assessment need to cover?
The assessment must cover the common areas such as hallways, stairwells, shared kitchens, and entrance lobbies. It should examine fire detection systems, escape routes, fire doors, emergency lighting, firefighting equipment, and tenant information.
Q: How often should I review my HMO fire risk assessment?
The assessment should be reviewed regularly and updated whenever significant changes occur, such as a change in the number of tenants or alterations to the building layout. Following recognised guidance such as PAS 79 helps ensure the assessment remains structured and thorough.
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