HMO Fire Risk Assessment: Council Requirements Explained

If you run an HMO in London — whether a converted three-storey terrace in Tooting, a bedsit block in Walthamstow, or a six-bed shared house in Acton — the fire risk assessment is the document that sits at the centre of your licence. Without it the council will not grant. With a weak one the council will issue conditions, schedule a re-inspection, or refuse outright. Every borough has its own HMO standards leaflet, but the underlying legal test is the same across all 32: the assessment must be suitable and sufficient, written, kept under review, and able to stand up to a licensing officer who has seen a thousand of them and can spot a copy-paste template at twenty paces.

This guide is the long version of what we wish every landlord knew before they pick up the phone. It covers the legal framework, what councils actually look for line-by-line, the British Standards that get cited, the documentation pack you need on the day of inspection, and where the licensing officer is most likely to push back. Read it, then if you want us to do the assessment, book a survey or call 0207 046 1363.

The Legal Framework — What Triggers an HMO FRA

Three pieces of legislation interact on every London HMO and you need to understand all three before you book a fire risk assessment.

The Regulatory Reform (Fire Safety) Order 2005 (the "RRO" or "Fire Safety Order") is the primary law. Article 3 defines the "responsible person" — in an HMO this is the person who has control of the premises in connection with the carrying on of a trade or business, which in practice means the landlord or the managing agent. Article 9 requires that person to make a suitable and sufficient assessment of the fire risks to which relevant persons are exposed, and to record the significant findings in writing where five or more relevant persons are present or where the premises are licensable. Article 17 requires the assessor to be a "competent person". Article 31 gives the fire-and-rescue authority the power to issue a Prohibition Notice closing the building if conditions are unsafe.

The Housing Act 2004 sits alongside the RRO and is the licensing engine. Mandatory HMO licensing applies to any HMO occupied by five or more persons in two or more separate households. Additional licensing schemes (which a council can declare to cover smaller HMOs) and selective licensing schemes (which cover ordinary rented houses in designated areas) operate in over 25 London boroughs at the time of writing — Newham, Waltham Forest, Brent, Croydon, Tower Hamlets, Haringey, Enfield, Barking & Dagenham and others. The licence application form will ask, in terms, for a copy of the FRA.

The Building Safety Act 2022, and in particular Section 156, amended the RRO to require all responsible persons to record their FRA in writing regardless of size and to keep a record of co-operation with other duty holders. For higher-risk buildings (18m or seven storeys plus, with two or more residential units) much heavier duties apply under the Building Safety Regulator regime, but that is outside the scope of most HMOs.

The practical effect: if your property meets any one of mandatory, additional or selective licensing in your borough, you need an FRA. If it is over five occupants, the FRA must be written. If it has more than one storey of accommodation above ground level, the assessment will almost certainly conclude that mains-interlinked detection and emergency lighting are required.

What London Councils Actually Look For

Licensing officers across London work to slightly different HMO standards leaflets but the underlying checklist when they read an FRA is consistent. In rough order of importance:

• Competence of the assessor — name, company, registration with a recognised scheme (IFE, IFSM, FRACS, BAFE SP205), professional indemnity insurance, and a CV or statement of competence. A landlord-completed checklist downloaded from the internet will not pass.
• Methodology — explicit statement that the assessment follows PAS 79-1:2020 (non-residential parts) or PAS 79-2:2020 (housing including HMO common parts). This is the single fastest signal of competence.
• Premises description and plans — a floor-plan per storey showing escape routes, detector positions, fire doors, EL fittings, extinguishers (if provided), and the final exit. Hand-drawn is fine; it must match what is on the wall.
• Fire-hazard identification — sources of ignition, sources of fuel, sources of oxygen, structural deficiencies. Cooking facilities, electrical installation age, smoking policy, refuse storage, intumescent strips on doors, condition of escape-route surfaces.
• Persons at risk — number of bedrooms, sleeping risk, vulnerable occupants, lone occupants, visitors, contractors. HMOs are sleeping-risk premises and the assessment must treat them as such.
• Evaluation and existing controls — what is in place now: alarm grade, EL coverage, fire-door rating (FD30 / FD30S / FD60), compartmentation between bedsits, signage, extinguisher provision (usually not required in HMOs but if provided must be serviced).
• Significant findings and action plan — a numbered list of remedial actions with priorities (intolerable / substantial / moderate / tolerable / trivial) and target completion dates. Councils read this list line-by-line.
• Date of assessment, date of next review, signature.

If any of those is missing the licensing officer will request a revised report before progressing the application. That is a four-to-six week delay you do not need.

Need this done properly? Call 0207 046 1363, WhatsApp 07456 975436, or email [email protected]. We assess, write, and stand behind the report at licensing committee if it comes to that.

Fire-Detection Grade — BS 5839-6 Decoded

The fire-detection system is the most-challenged single item in an HMO fire risk assessment and the area where the most money gets spent on remediation. BS 5839-6:2019+A1:2020 is the relevant code of practice. It defines six grades (A, B, C, D1, D2, F1, F2) and four categories of coverage (LD1, LD2, LD3, plus PD/M for property protection).

For a typical licensable London HMO the council will expect:

• Three storeys or more, or bedsit-type conversion with locked bedroom doors: Grade A LD2 — a BS EN 54 control panel with smoke detectors in the escape route and in every habitable room used for sleeping, plus a heat detector in the kitchen. Cabled, mains-wired, with battery back-up at the panel.
• Two-storey shared house, four to six occupants: Grade D1 LD2 or LD3 — mains-wired interlinked smoke detectors on every storey of the escape route and in every habitable sleeping room (LD2) or just the escape route (LD3), with sealed-in 10-year lithium back-up batteries.
• Single-storey shared flat: Grade D2 LD2 — similar specification with replaceable back-up batteries acceptable.

Heat detectors go in kitchens (smoke would false-alarm). Carbon monoxide alarms are a separate requirement under the Smoke and Carbon Monoxide Alarm (England) Regulations 2015 as amended — one in every room with a fixed combustion appliance other than a gas cooker.

The system needs a commissioning certificate from the installer, a six-monthly service certificate from a competent firm (BAFE SP203 accredited is the gold standard), and a logbook showing weekly call-point tests. If you are unsure which grade applies to your property our BS 5839-6 grades explainer walks through the decision tree in full. For ongoing servicing see fire alarm testing London.

Emergency Lighting — BS 5266 in HMOs

BS 5266-1:2016 is the code of practice for emergency lighting. The threshold question is whether the escape route can be navigated safely in a power-cut at night. If it cannot, EL is required. For HMOs that means almost any property with an internal stairwell, a basement bedroom, an inner room, or accommodation on a second storey or above.

The minimum illumination is 1 lux along the centre-line of the escape route, 0.5 lux in open areas, sustained for at least three hours from battery after mains failure. Fittings must be either maintained (on all the time) or non-maintained (only on in mains failure). Self-test fittings are increasingly common and remove most of the test burden, but they do not remove the monthly flick test and the annual three-hour duration drain — both must be logged.

The licensing officer will check that the FRA has identified each EL position, that the fittings are physically present, that the logbook shows up-to-date tests, and that the annual drain has been done in the last 12 months. The most common failures we see are missing EL at the final exit, missing EL on the half-landing of a converted three-storey terrace, and missing logbook tests for a system that is otherwise correctly installed.

Fire Doors and Compartmentation

Bedroom doors in an HMO are the primary protection between a fire in one occupant's room and the escape route used by the others. They are not optional and they are not negotiable.

For most licensable HMOs the council will require FD30S doors on every bedroom, every kitchen, and every door opening onto the protected escape route. The "30" is 30 minutes' integrity to BS 476-22 or BS EN 1634-1; the "S" is cold-smoke seals. Each door needs:

• A certified door blank with intumescent strips around three sides and cold-smoke seals integrated with or fitted to the strips
• A self-closer (perko-type concealed closers are acceptable; overhead closers more so) maintaining positive latching from any open position
• Hinges rated to the door's fire rating, normally three CE-marked hinges per leaf
• A working latch — letterbox plates, glazed apertures, and any other penetrations must be fire-rated to match

Section 156 of the Building Safety Act 2022 introduced specific fire-door inspection duties for the responsible persons of multi-occupied residential buildings — quarterly inspections of communal fire doors and annual inspections of flat entrance doors in higher-risk buildings. For the average three-storey HMO the obligation is captured under the general "suitable and sufficient" test in the RRO; in practice we recommend quarterly visual inspections logged in the fire logbook.

Compartmentation around service penetrations (waste pipes through party walls, heating pipes through ceilings, electrical cables through fire-stopping) is the silent killer of HMO FRAs. The licensing officer will not necessarily check this themselves, but a competent fire risk assessor will, and a failed penetration in the wrong place can downgrade an entire compartmentation strategy.

The Documentation Pack a Licensing Officer Expects

Bring all of this to the inspection (or upload it with the licence application — most boroughs now take electronic submission):

• The written fire risk assessment, signed and dated, with floor plans
• The fire-alarm system design certificate (BS 5839-6 Section 25)
• The fire-alarm installation and commissioning certificate (Section 26 and 27)
• The most recent six-monthly service certificate (Section 28)
• The on-site fire logbook with weekly call-point tests for the past 12 months
• The emergency-lighting commissioning certificate and three-hour test log
• The current Electrical Installation Condition Report (EICR), valid five years
• PAT certificates for any landlord-supplied appliances (kettles, microwaves, white goods in shared kitchens)
• The current Landlord Gas Safety Record (CP12), valid 12 months
• Fire-door inspection records (quarterly minimum)
• The HMO management regulations notice displayed on site (manager's name and 24-hour contact)

Most refusals or conditional grants come from a gap in this list rather than a physical defect in the building. Get the pack together before you submit, not after the inspecting officer asks for it. See our landlord compliance hub for the full annual compliance calendar.

PAS 79 — Why the Methodology Header Matters

PAS 79-1:2020 (non-residential) and PAS 79-2:2020 (housing) are the publicly available specifications produced by BSI that set out a recognised methodology for conducting and recording fire risk assessments. They are not law, but they are referenced by the National Fire Chiefs Council, by most enforcing authorities, and by the courts.

Putting the words "this assessment has been carried out in accordance with the methodology of PAS 79-2:2020" at the top of the report is the single fastest credibility signal you can give a licensing officer. It tells them that the assessor knows the document exists, has the nine-step methodology in mind (acquire information; identify hazards; identify people at risk; evaluate the risk; consider compartmentation and means of escape; record significant findings; prepare action plan; review periodically; revise as needed), and has structured the report accordingly.

If the methodology header is missing the officer will read more sceptically. If it is present but the report doesn't follow through on it, the officer will catch that too. The header is a promise; the body has to deliver.

Licensing Implications if the FRA Fails

If the council judges the FRA not suitable and sufficient — or if the FRA itself flags significant findings the landlord has not actioned — the available enforcement routes are:

• Conditional licence grant with a schedule of works and completion dates (the most common outcome)
• Refusal of licence under Schedule 4 of the Housing Act 2004
• Improvement Notice under Sections 11 (Category 1 hazard) or 12 (Category 2 hazard) of the Housing Act
• Prohibition Notice under Article 31 of the RRO 2005 — issued by the fire-and-rescue authority, closes part or all of the building immediately
• Rent Repayment Order against the landlord (up to 12 months' rent, payable to tenants or to the council if Housing Benefit was paid) if the property was operated unlicensed
• Banning Order or entry on the Database of Rogue Landlords for repeat or serious offences

All notices are appealable to the First-tier Tribunal (Property Chamber) within 28 days. The tribunal will look hard at whether the responsible person took reasonable steps — and a properly written, properly executed FRA from a competent assessor is the single strongest piece of evidence you can put before it. Commission one before the council asks; don't wait until they have.

Borough-Level Variation Across London

Every London council has its own HMO standards document. They are mostly aligned with the LACORS national guidance ("Housing — Fire Safety: Guidance on fire safety provisions for certain types of existing housing") but they vary at the margins. A few practical examples we see across our caseload:

• Newham, Waltham Forest, Croydon — selective licensing is borough-wide or near-borough-wide; an FRA may be requested even on single-family lets in designated areas
• Camden, Westminster, Kensington & Chelsea — period properties and listed buildings dominate; fire-door upgrades and EL retrofits often require listed-building consent that adds weeks to the timetable
• Tower Hamlets, Hackney — additional licensing in named wards covers HMOs from three occupants upwards; the licensing standards documents are unusually detailed and the inspections are unusually thorough
• Brent, Ealing, Hounslow — long-running additional licensing schemes; the HMO standards leaflet is detailed and Grade A alarm systems are routinely required even on smaller properties
• Barnet, Bromley, Bexley — only mandatory licensing applies in most areas at the time of writing; but a competent FRA is still expected with any application

Before booking the assessment, download your council's current HMO standards document and have it open when the assessor walks the building. The cost of compliance varies more by borough policy than by building condition — for an indicative cost range across boroughs see our 2026 fire risk assessment price guide.

Ready to book? Call 0207 046 1363, WhatsApp 07456 975436, or email [email protected]. We turn surveys around in five working days for single HMOs and same-week for portfolios.

FAQs

The FAQ section at the foot of this page (rendered from the schema above) answers the questions we get most often from landlords starting a licence application: whether an FRA is legally required, what alarm grade applies, when emergency lighting is needed, how often the assessment must be reviewed, what the council will inspect, and what happens if the FRA fails scrutiny.

If your licence application is pending or your renewal is approaching, do not leave it. A good FRA takes a week to commission, a few days to write, and any remedial works will add another two to six weeks depending on what is needed. Start now.

John Alexander N. - Emergency Repairs London