HMO Fire Risk Assessment in London

What is an HMO fire risk assessment?

An HMO fire risk assessment is the formal, written record that the responsible person — the landlord, managing agent or operator of a House in Multiple Occupation — has identified every fire hazard in the building, assessed who is at risk, and put proportionate measures in place to remove or control those risks. It is mandatory under Article 9 of the Regulatory Reform (Fire Safety) Order 2005 for every HMO with shared escape routes, and a current copy is a condition of every borough HMO licence in London.

Our assessor follows the PAS 79-1:2020 methodology — Fire risk assessment in premises other than housing — Code of practice. PAS 79 sets out the five-step structure used by every reputable risk assessor in the UK: identify the hazards, identify people at risk, evaluate and act, record and inform, and review. The assessment is benchmarked against the LACORS National Fire Safety Guidance for HMOs, which every London borough environmental health team uses as the working compliance standard.

The output is a written report lodged in the borough HMO licensing portal — a significant findings log, a priority-rated remedial action plan with statutory deadlines, drawings of the escape route and a clear statement of compliance status. It is the single most scrutinised document in an HMO licence renewal, and the most common reason for a renewal to be refused or delayed.

When an HMO needs a fire risk assessment

HMO fire safety duty is triggered by occupancy, not by licence type. The duty applies to every HMO under the Housing Act 2004 — a property with three or more occupants from two or more households sharing kitchen, bathroom or living facilities — regardless of whether it is mandatorily licensed, additionally licensed or selectively licensed.

• Mandatory licensed HMOs — five or more occupants from two or more households. Annual fire risk assessment required as a condition of licensing in every London borough, reviewed every 12 months, re-done in full on any layout change.
• Additionally licensed HMOs — three or four occupants in boroughs operating an additional licensing scheme (Camden, Tower Hamlets, Hackney, Brent and others). Same annual FRA duty as a mandatory licence.
• Selective licensing properties — any rented property in a designated selective licensing area (Newham, Croydon, Waltham Forest, Enfield, parts of Tower Hamlets). The borough licence conditions require a written fire risk assessment regardless of HMO status.
• Unlicensed HMOs with shared common parts — the Regulatory Reform (Fire Safety) Order 2005 still applies. The landlord is the responsible person and a written FRA is required for any HMO with five or more occupants by Article 9(7).
• Material changes — any change of layout, new kitchen, loft conversion, change of tenant cohort or fire incident triggers a re-assessment under PAS 79 Step 5. Combined with the EICR and smoke alarm installation on the same visit for portfolio efficiency.

HMO fire risk assessment cost — transparent pricing

Pricing is by HMO size, banded against the LACORS HMO categories. A fixed figure is confirmed on the call based on the bedroom count, the number of storeys, the presence of a basement, and whether the property is a single-let HMO or a converted block. No VAT add-ons, no parking charges, no premium for borough-specific licensing portals.

* Prices include VAT. Larger HMOs (7+ bedrooms) and purpose-built HMO blocks are quoted on the call.

What's included in every HMO FRA

• PAS 79-format five-step fire risk assessment for the Regulatory Reform (Fire Safety) Order 2005
• Compliance check against the LACORS National Fire Safety Guidance for HMOs
• Fire door inspection — intumescent strips, smoke seals, self-closers, gaps and integrity
• Escape route audit — width, lighting, signage, travel distance from furthest bedroom
• Compartmentation review — 30 or 60 minute separation between bedsits, kitchens and stairs
• Detection and alarm grading check against BS 5839-6 (LD1/LD2/LD3 system for HMOs)
• Emergency lighting check against BS 5266-1 in stairwells and internal corridors
• Kitchen fire safety — fire blankets, extinguishers, gas isolation, cooker provision
• Significant findings log with priority risk ratings and remedial action plan
• Digital PDF report formatted for borough HMO licensing submission within 48 hours

The four highest-risk HMO hazards we check

HMO fires have a different risk profile to single-family lets. Shared kitchens, longer travel distances, multiple sleeping risks behind individual lockable doors and post-conversion compartmentation breaches dominate the picture. Every PAS 79 assessment focuses scrutiny on four core areas before moving to secondary risks.

Secondary risks — electrical (cross-checked against the property's current EICR), gas appliances, smoking management, refuse storage, external means of escape and arson protection — are recorded in the significant findings log with their own priority ratings.

What "council-approved" actually means

There is no statutory accreditation scheme called "council-approved" — but every London borough has a documented standard for what an HMO fire risk assessment must contain to be accepted at licence renewal. The shorthand "council-approved" means a report that meets all of those standards and is routinely accepted without challenge.

In practical terms that requires four things: a PAS 79-1:2020 structured methodology, a clear reference to the LACORS National Fire Safety Guidance, a competent assessor (third-party certified on a UKAS-accredited register such as IFE, FPA, BAFE SP205 or IFSM), and a significant findings log with priority ratings and timeframes. Reports missing any of those four elements are commonly rejected by Camden, Hackney, Tower Hamlets, Newham, Brent and Waltham Forest licensing teams.

Beyond the licensing portal, the report has to stand up to scrutiny from the London Fire Brigade. The LFB has prosecutorial powers under Article 32 of the Regulatory Reform (Fire Safety) Order 2005 and routinely audits HMO FRAs after every reportable incident. A weak risk assessment is the single most common evidential lever in Fire Order prosecutions in London.

Penalties for HMO fire safety breaches

Enforcement is shared between the borough housing standards team (Housing Act 2004) and the London Fire Brigade (Regulatory Reform (Fire Safety) Order 2005). Both can prosecute, both can issue unlimited fines on conviction, and both routinely do across London every year.

• Unlimited fines on conviction under Article 32 of the Regulatory Reform (Fire Safety) Order 2005 for failing to make a suitable and sufficient fire risk assessment. Recent London prosecutions routinely reach £30,000–£150,000 per HMO.
• Civil penalties up to £30,000 per offence under the Housing and Planning Act 2016 for breach of HMO management regulations — issued by the borough without going to court.
• Rent Repayment Orders at First-tier Tribunal — tenants can recover up to 12 months of rent where the HMO was operating without a valid licence, and a missing or expired FRA is the most common trigger.
• Banning orders and the rogue landlord database under the Housing and Planning Act 2016 for repeat or serious HMO breaches.
• Insurance void — every commercial landlord policy requires a current FRA as a policy condition. A fire claim on an HMO with an expired or absent FRA is commonly refused.
• Loss of HMO licence — licence revocation by the borough means the property can no longer be operated as an HMO, with rent loss running into tens of thousands per year per property.

What we check on every HMO visit

A working tick list runs through the five PAS 79 steps in order. Every item is photographed, measured and recorded in the significant findings log. Nothing is judged by sight alone — door gaps are measured with a feeler gauge, alarm sounders are decibel-tested at the head of every bedroom, emergency lighting is illuminance-checked at the floor.

• Fire detection grade against BS 5839-6 (LD1 / LD2 / LD3)
• Emergency lighting against BS 5266-1 in every common area
• FD30 / FD60 fire door survey — every door, every component
• Travel distance from furthest bedroom to final exit
• Compartmentation integrity — bedsit walls, ceilings, service penetrations
• Kitchen fire safety — fire blanket, CO2 extinguisher, gas isolation
• Means of escape signage and pictograms
• Fire safety information — notices in every bedroom and common area
• Refuse storage, smoking management, external means of escape
• Recent fire incidents, log book and tenant complaints review

Areas covered

HMO fire risk assessments are carried out across all 32 London boroughs. Heaviest HMO licensing volumes come from Camden, Hackney, Tower Hamlets, Newham, Brent, Waltham Forest, Southwark, Lambeth, Lewisham, Haringey, Islington and Westminster.

Frequently Asked Questions