A Guide to HMO Fire Risk Assessment Requirements

Fire safety failures are one of the most common reasons HMOs face enforcement action, licensing issues, and costly remedial works. HMO landlords and managing agents also face risks that are less common in single-household properties, including frequent occupancy changes, shared kitchens, communal escape routes, and local licensing conditions.

This guide explains when HMOs require a fire risk assessment, what assessors check, how HMO licensing affects fire safety responsibilities, and how landlords can manage compliance across individual properties and larger portfolios.

What Is a House in Multiple Occupation (HMO)?

In England, a property will generally be considered an HMO where at least three tenants forming more than one household live there and share facilities such as a kitchen, bathroom, or toilet. A household can be a single person or members of the same family living together.

Not every HMO requires mandatory licensing. Properties occupied by five or more people forming two or more households generally require a mandatory HMO licence, while smaller HMOs may require a licence where the local authority operates an additional licensing scheme.

What Is an HMO Fire Risk Assessment?

HMO landlords and managing agents use fire risk assessments to identify and manage the additional risks created by multiple households sharing the same property. Unlike many single-household properties, HMOs can experience frequent changes in occupancy, greater use of shared facilities, and increased reliance on communal escape routes and fire precautions.

A HMO fire risk assessment is a structured assessment of the fire risks within a property. Its purpose is to identify potential fire hazards, evaluate the risks to occupants, assess existing fire safety measures, and determine whether additional controls are required.

Assessors will typically pay particular attention to HMO-specific risks such as:

• Shared kitchens and cooking facilities
• Protection of escape routes
• Fire door provision and maintenance
• Fire alarm and detection systems
• Frequent changes in occupancy
• Storage within communal areas
• Housekeeping standards
• Whether residents understand the building’s fire safety arrangements
• Vulnerable occupants who may require additional support
• Any fire safety conditions attached to the property’s HMO licence

The significance of these issues will vary depending on the size, layout, occupancy profile, and licensing requirements of the property.

What Legislation Applies to HMO Fire Safety?

HMO landlords and managing agents must comply with both fire safety and housing legislation. The requirements that apply will depend on the property, its occupancy arrangements, licensing status, and location.

England and Wales

The main legislation includes:

• Regulatory Reform (Fire Safety) Order 2005
• Housing Act 2004
• Housing Health and Safety Rating System (HHSRS)
• Fire Safety Act 2021, where applicable

Under the Regulatory Reform (Fire Safety) Order 2005, the Responsible Person must carry out a suitable and sufficient fire risk assessment where the legislation applies and put appropriate fire precautions in place. For HMOs, the Fire Safety Order generally applies to the common parts rather than the individual domestic premises.

The Housing Act 2004 introduced the HMO licensing framework and the Housing Health and Safety Rating System (HHSRS). Local authorities use the HHSRS to assess hazards within residential properties, including fire hazards, while HMO licences can include conditions that landlords and managers must meet.

The Fire Safety Act 2021 is relevant where an HMO contains two or more sets of domestic premises. It clarified that the Fire Safety Order also applies to the building’s structure and external walls, as well as doors between domestic premises and common parts. Responsible Persons must consider these elements within the building’s fire risk assessment where the Act applies.

Together, these requirements mean HMO landlords and managing agents need to consider both their fire safety duties and any housing or licensing requirements that apply to each property.

Scotland

Fire safety duties in Scotland are governed by:

• Fire (Scotland) Act 2005
• Fire Safety (Scotland) Regulations 2006

Duty holders must assess fire risks, implement appropriate fire safety measures, and ensure those measures remain effective. The specific requirements will depend on the type of HMO, its occupancy, and the applicable licensing arrangements.

How Does HMO Licensing Affect Fire Safety Requirements?

Not every HMO is subject to the same licensing requirements. In England, landlords may encounter mandatory HMO licensing, additional HMO licensing, or selective licensing depending on the property and the local authority area.

Licensing type	What it means
Mandatory HMO licensing	Generally applies to HMOs occupied by five or more people forming two or more households.
Additional HMO licensing	Local authorities can extend HMO licensing to properties that fall outside the mandatory scheme, including some smaller HMOs.
Selective licensing	Local authorities can require certain privately rented properties within designated areas to be licensed; unlike additional licensing, this is not limited to HMOs.

Licensed HMOs must meet applicable licence conditions. These can include requirements relating to smoke alarms and other property safety measures, while local authorities can impose additional conditions depending on the property and licensing scheme.

Landlords and managing agents should therefore check the requirements of the local authority for each HMO they manage rather than assuming the same licensing and fire safety conditions apply across an entire portfolio.

Who Is Responsible for Fire Safety in an HMO?

Responsibility typically sits with the Responsible Person.

Depending on the property and management arrangements, this may be:

• The landlord
• The property owner
• A managing agent
• A housing provider
• An organisation operating supported accommodation

Although specialist fire risk assessors may be appointed to complete the fire risk assessment, the Responsible Person has a legal obligation to ensure a suitable and sufficient assessment is carried out and that appropriate fire safety measures remain in place. 

Which HMOs Require a Fire Risk Assessment?

For many landlords and managing agents, the key question is not whether a fire risk assessment is needed, but where their legal duties begin. Where the Fire Safety Order applies to the common parts of an HMO, the Responsible Person must ensure a suitable and sufficient fire risk assessment is carried out and kept under review.

Examples include:

• Shared houses
• Shared flats occupied by multiple households
• Student accommodation
• Professional house shares
• Licensed HMOs
• Larger HMOs occupied by multiple households
• Supported housing with communal areas

The exact scope of the assessment will depend on the property’s layout, occupancy profile, fire safety measures, and management arrangements.

What Should an HMO Fire Risk Assessment Include?

A suitable and sufficient fire risk assessment should provide a clear picture of the property’s fire risks and the effectiveness of the measures in place to manage them.

Areas typically assessed include:

Assessment Area	Examples
Fire hazards	Electrical equipment, cooking facilities, smoking materials, storage arrangements
Means of escape	Escape routes, final exits, travel distances
Fire detection systems	Smoke alarms, heat detectors, fire alarm systems
Fire doors and compartmentation	Protection of escape routes and fire separation
Emergency lighting	Provision and maintenance where required
Firefighting equipment	Extinguishers and associated arrangements
Occupancy risks	Sleeping accommodation, vulnerable residents, occupancy levels
Fire safety management	Testing records, maintenance arrangements, resident information

The assessor should record all findings, identify deficiencies, and prioritise any remedial actions required. HMO landlords and managing agents can then use the findings to address higher-risk issues, plan remedial works, and keep fire safety arrangements aligned with changes in occupancy or property use.

For a more detailed breakdown of what assessors examine during an assessment, read our guide to What Should a Fire Risk Assessment Include?

Common Fire Safety Issues Identified in HMOs

Fire risk assessments frequently identify recurring issues within HMOs that can affect both tenant safety and compliance.

Common examples include:

• Inadequate fire alarm coverage
• Missing or poorly maintained fire doors
• Defects in compartmentation
• Obstructed escape routes
• Inadequate emergency lighting
• Poor fire safety record-keeping
• Inadequate maintenance arrangements
• Unauthorised alterations affecting fire precautions

Identifying and addressing these issues promptly helps reduce the risks to residents, maintain compliance, and demonstrate that fire safety is being actively managed. 

How Fire Risk Assessments Support HMO Compliance

A fire risk assessment is one of the primary tools used to demonstrate that fire safety risks are being identified, managed, and reviewed appropriately.

A suitable and sufficient assessment can help organisations:

• Support HMO licensing requirements
• Prioritise fire safety improvements
• Demonstrate compliance during inspections
• Manage remedial works
• Maintain an audit trail of fire safety decisions

This is particularly important where properties are subject to local authority scrutiny, licensing reviews, enforcement activity, or where evidence of fire safety management may be requested by the Fire and Rescue Service or other regulators. 

Managing Fire Safety Across HMO Portfolios

For landlords and managing agents responsible for multiple HMOs, the challenge is often less about completing individual assessments and more about maintaining consistent oversight across an entire portfolio.

A structured fire risk assessment programme helps organisations prioritise higher-risk properties, track remedial actions, support HMO licensing requirements, and maintain a clear audit trail of fire safety decisions.

This approach makes it easier to demonstrate compliance during inspections, evidence effective fire safety management, and ensure resources are directed towards the areas of greatest risk.

What Happens if Fire Safety Requirements Are Not Met?

Failure to manage fire safety risks appropriately can result in enforcement action under both fire safety and housing legislation.

Depending on the circumstances, this may include:

• Improvement notices
• Prohibition notices
• HMO licensing issues
• Civil penalties or fines
• Criminal prosecution
• Increased liability following a fire

Beyond regulatory action, deficiencies identified during inspections can also lead to costly remediation works and increased scrutiny from local authorities and other stakeholders.

Meeting Your HMO Fire Safety Responsibilities 

A suitable and sufficient fire risk assessment helps HMO landlords and managing agents identify risks, prioritise improvements, and demonstrate compliance with their fire safety responsibilities.

If you are responsible for fire safety compliance across a residential portfolio and need a trusted, BAFE SP205-accredited provider, Osterna can help.

We work with housing associations, managing agents, and large private landlords across the UK, delivering Fire Risk Assessments, asset testing, fire door inspections, and building compliance services.

Get in touch with the Osterna team today.