Does a London HMO need a fire risk assessment?
Start with the building and its use. The Regulatory Reform (Fire Safety) Order 2005 applies in England and Wales, including relevant shared areas of multi-occupied residential buildings. It is not a single UK-wide rule covering every part of every home. Individual domestic premises have a different scope from common parts; a shared house and a building divided into bedsits or flats should not be treated as interchangeable.
The London Fire Brigade's landlord guidance explains the duty to have an assessment and maintain suitable precautions. Identify who controls the premises and who is the Responsible Person. A managing agent can have duties alongside an owner; appointing an assessor does not transfer the Responsible Person's obligations.
Check the London borough's HMO licensing conditions as well. Housing standards, planning permission and fire-safety duties are separate checks. Use the HMO licence evidence pre-check to record the council and property evidence, rather than treating a licence as proof that all fire-safety work is complete.
Record the full assessment and close the actions
Since 1 October 2023, all Responsible Persons for premises regulated by the Fire Safety Order must record the assessment in full and record their fire-safety arrangements. This is a requirement even where there are fewer than five employees. Record who carried out or reviewed the assessment, and maintain the required contact and handover information. See the Home Office's Section 156 guidance.
For a purchase review, request the assessment itself, its action plan and evidence that actions have been completed. A certificate saying an assessment occurred does not establish that the building is safe or that recommendations were implemented. Record unresolved actions with a responsible contractor, cost and completion date.
What should the assessment cover?
The assessor needs the actual occupancy, layout and use, including any commercial premises below the accommodation. Relevant checks include ignition sources, escape routes, compartmentation, doors, detection, warning arrangements and the needs of residents who may need assistance. Use a competent assessor with experience of the relevant residential building type.
An alarm grade, door specification or extinguisher list copied from another HMO is not a design. The measures must suit this property and its risks. London Fire Brigade's private rented sector guidance also explains the need to assess changes involving refurbishment and the common parts. Keep evacuation instructions consistent with the building's assessed strategy.
The Fire Safety Act 2021 clarified that, where the Order applies to a building containing two or more domestic premises, its scope includes the structure, external walls and doors between homes and common parts. The government's enforcement guidance explains this distinction.
How often must an HMO fire risk assessment be reviewed?
The assessment must be reviewed regularly and when there is reason to think it is no longer valid, or a significant relevant change occurs. Article 9 of the Fire Safety Order does not impose a universal annual replacement assessment for every HMO.
Set the review programme with the assessor, accounting for risks, licence conditions and any specific requirements. Review sooner after changes to layout, occupancy or use, or evidence that precautions are inadequate. Routine alarm testing, equipment servicing and door inspections are separate tasks: a current assessment does not replace them.
Check additional duties for the building type
The Fire Safety (England) Regulations 2022 add requirements for relevant buildings containing two or more domestic premises and common evacuation routes. Duties vary with building height. For relevant buildings above 11 metres, these include quarterly checks of communal fire doors and best endeavours to check flat entrance doors annually. Do not apply those height-specific rules indiscriminately to every shared house.
From 6 April 2026, Residential Personal Emergency Evacuation Plan duties also apply to specified multi-residential buildings: those at least 18 metres high or with at least seven storeys, and those over 11 metres using simultaneous evacuation. These include identifying residents who may need assistance and offering person-centred assessments, with consent requirements. Check the current government scope and guidance if the HMO sits within such a building.
Worked example: put identified works into the purchase budget
This is a hypothetical budgeting example, not a quote or a fire-safety specification. Suppose an assessment and contractor quotations identify £4,000 of door work, £2,000 of detection work and £1,000 of other remedials. The assessment itself costs £500. A 15% contingency on the £7,000 works adds £1,050:
assessment + quoted works + contingency = £500 + £7,000 + £1,050 = £8,550
If completion of the work also delays letting by one month at a modelled £3,000 rent, the combined initial cost and lost-rent effect is £11,550, before finance and other holding costs. Replace every assumption with evidence for the property and confirm VAT treatment in the quotations.
Keep initial works in the acquisition/refurbishment budget. Put recurring inspections, maintenance and testing into operating expenses in the gross and net yield calculator. Do not count the same cost twice or use a yield result as a compliance decision.
Reviewed 28 October 2026. England-focused guidance for London property screening; the property assessment and applicable borough conditions determine the required measures.
