Does an HMO need a fire risk assessment?
Matt McAllen, CMIOSH
Last reviewed: June 2026 Yes. The common parts of every HMO must have a fire risk assessment under the Fire Safety Order — that duty applies whether or not the property is licensed. And if you're applying for or renewing an HMO licence, your council will expect to see one as part of the application. The duty sits with the landlord or managing agent.
Is a fire risk assessment a legal requirement for an HMO?
Yes — for the common parts. The shared areas of an HMO (hallways, stairs, landings and escape routes) are covered by the Regulatory Reform (Fire Safety) Order 2005, the same law that applies to commercial premises. Whoever controls those common parts must ensure a "suitable and sufficient" fire risk assessment is carried out and kept under review.
This applies regardless of whether the HMO needs a licence. Licensing is a separate housing-law requirement on top — but the fire-risk-assessment duty for the common parts exists either way.
What counts as an HMO?
Broadly, a property rented to three or more people who form more than one household and share facilities such as a kitchen or bathroom. A "household" is a single person or members of one family living together. Three friends sharing, or several unrelated tenants in a shared house, will typically make the property an HMO.
A large HMO — generally five or more people forming two or more households — falls under mandatory licensing everywhere in England. Some councils also run additional licensing that catches smaller HMOs in designated areas. Either way, the fire-risk-assessment duty for the common parts is the same; licensing just adds a documentation expectation on top (see below).
If you're genuinely unsure whether your property is an HMO, that's worth confirming before anything else — tell me about it and I'll give you a straight answer.
Whose duty is it — landlord or tenant?
The landlord, or the managing agent with control of the common parts. You don't live there, but the shared parts of the building are yours to keep safe under the law. The tenants are responsible for living safely within their own rooms; the structural and shared fire safety — the protected staircase, the fire doors onto it, detection and lighting in the common areas — is the landlord's or agent's responsibility.
That duty can't be passed to the tenants, and it isn't discharged by the alarm company that services the system. The legal responsibility for a suitable and sufficient assessment stays with whoever controls the premises.
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How does HMO licensing fit in?
Where a licence is required, the council expects a fire risk assessment as part of the application. In Hampshire and Dorset, Portsmouth and Southampton run additional licensing schemes where an FRA is a required document with the application. In Portsmouth, if you don't have a current one when you apply, you may be issued a one-year licence with a condition to get it — rather than the full five-year term.
Most other councils across Hampshire and Dorset run mandatory licensing only (large HMOs of five or more people). But even where no licence is needed, the Fire Safety Order duty for the common parts still applies. Licensing changes the paperwork expectation; it doesn't create the underlying duty — that's always there.
What standard is an HMO assessment done to?
BS 9792:2025 — the British Standard code of practice for fire risk assessment in housing — with the LACORS housing fire safety guidance as the practical benchmark. BS 9792:2025 replaced the older PAS 79-2 in 2025 and is the current methodology for HMOs, blocks of flats and similar housing.
An HMO is judged from two directions at once — the fire and rescue service and the local housing authority — so the assessment has to satisfy both. LACORS is the guidance councils and fire services have long used to judge practical fire precautions in shared and rented housing.
What does an HMO fire risk assessment cover?
The common parts in full, and — in a Type 3 — a sample of the individual rooms. In plain terms, it looks at the things that decide whether everyone gets out safely:
- The protected staircase and the route to the exit — the single escape path most HMOs depend on.
- Fire doors and compartmentation — whether the protection between rooms and the escape route actually holds.
- Detection and alarm — the right coverage for a building where people sleep.
- Emergency lighting on the escape route.
- Management — testing, maintenance, and how fire safety is kept up day to day.
Most HMOs need a Type 1 (common parts) or Type 3 (common parts plus a sample of rooms) — the two I carry out. For the difference between them, see the guide to the four types of fire risk assessment.
People also ask
Does a small HMO that doesn't need a licence still need a fire risk assessment?
Yes. The Fire Safety Order duty for the common parts applies to all HMOs, licensed or not. Licensing is a separate requirement that adds a documentation expectation where it applies.
Is the landlord or the tenant responsible?
The landlord, or the managing agent with control of the common parts. The duty for the shared areas and the building's fire safety can't be passed to tenants.
Will the assessment cover the tenants' rooms?
In a Type 1, no — it covers the common parts. In a Type 3, a representative sample of rooms is included. I'll advise which fits your property.
How often does an HMO fire risk assessment need reviewing?
At least every twelve months, and sooner if anything significant changes — a new room, conversion works, or a change in how the property is used.
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