HMO Fire Risk Assessment: What to Cover

By Brian Crocker, Crocker Digital Ltd — researcher and builder

24 September 2026Last reviewed: 24 September 2026

If you are looking for an HMO fire risk assessment template, the useful thing to know first is that there is no statutory template. Councils publish their own forms, landlord associations publish theirs, and they differ from each other — because they are practical aids, not legal instruments.

What the law actually fixes is the outcome: a suitable and sufficient assessment, recorded in full, covering the risks to everyone in the building. The structure you present it in is a professional choice. So the genuinely useful thing is not another blank form but a clear account of the ground an HMO assessment has to cover — which is where generic templates fail, because they are written for a workplace and an HMO is not one.

This article summarises UK fire safety law for educational purposes and is not legal advice. The responsible person carries the legal liability for fire safety in the premises. For specific compliance questions, consult a competent fire risk assessor or your local housing authority.

Three Regimes, Three Enforcers

The reason HMO fire safety confuses people is that three separate legal frameworks apply to the same building, and they do not line up neatly.

The Fire Safety Order applies to the common parts. Under Article 6 the Order excludes domestic premises, but where a building contains two or more sets of domestic premises it applies to "the building's structure and external walls and any common parts" and "all doors between the domestic premises and common parts". Article 9(1) then requires the responsible person to "make a suitable and sufficient assessment of the risks to which relevant persons are exposed". Enforced by the fire and rescue authority.

The Housing Act 2004 gives the local housing authority its powers, and its reach is wider — it covers the whole property, including inside letting rooms. Section 1 provides:

"This Part provides—(a)for a new system of assessing the condition of residential premises, and (b)for that system to be used in the enforcement of housing standards in relation to such premises."

That is the Housing Health and Safety Rating System, which treats fire as a specific hazard and expressly extends to HMOs and to common areas in buildings containing flats. Enforced by the council.

Licensing, where it applies, adds a third layer. Under Article 4 of the Licensing of Houses in Multiple Occupation (Prescribed Description) (England) Order 2018, an HMO is licensable where it:

"(a) is occupied by five or more persons; (b) is occupied by persons living in two or more separate households; and (c) meets—(i) the standard test under section 254(2) of the Act; (ii) the self-contained flat test under section 254(3) of the Act but is not a purpose-built flat situated in a block comprising three or more self-contained flats; or (iii) the converted building test under section 254(4) of the Act."

All three limbs have to be met — the occupancy count on its own is not the test. Limb (c) is satisfied by most shared houses and converted properties, but it carries a carve-out worth knowing: a purpose-built flat in a block of three or more self-contained flats falls outside mandatory licensing even when five or more people in two or more households live in it.

The former three-storey condition was removed in 2018 — a two-storey house with five occupants in separate households, meeting the standard test, is now within mandatory licensing. Councils also operate additional and selective licensing schemes locally, so the only reliable answer on licensability comes from your own council.

Why this matters practically: these regimes have different enforcers with different powers. A property can be arguably fine under one and enforced against under another. An assessment that only addresses the common parts has covered the Fire Safety Order and left the council's HHSRS interest — which includes what is happening inside the letting rooms — entirely unaddressed.

Why a Generic Template Fails Here

Take a standard workplace fire risk assessment form and apply it to a six-bed shared house. Most of the questions still make sense. But the form quietly assumes several things that are all false in an HMO:

That occupants are awake. They are asleep, which changes everything about detection and escape.
That occupants know each other and the building. In an HMO with independent tenancies, people may be strangers who moved in at different times, and nobody has been given a fire drill.
That someone is in charge on site. In a workplace there are fire wardens and a management chain. In an HMO nobody is responsible for the shared areas unless the landlord actively makes it so — which is why hallway clutter, propped fire doors and blocked exits accumulate.
That the risk is in a plant room or a workshop. In an HMO the dominant ignition source is the kitchen, used unsupervised, often late at night, sometimes by several households, and frequently on the escape route.
That escape means walking out. In an HMO the escape route often runs past the highest-risk room in the building.

Those five assumptions are exactly what an HMO-specific assessment has to unpick.

The Ground to Cover

What follows is subject matter, not a methodology. Group and order it however your report is structured; the point is that none of it is left out. Depth scales with the property — a two-storey house share is not a five-storey converted terrace with bedsits.

The building and its occupation

Storeys, layout, and whether it is a shared house, bedsits with locks on room doors, or self-contained flats — the arrangement changes the escape strategy fundamentally.
Number of letting rooms, actual occupancy and maximum occupancy, and whether these match the licence if there is one.
Whether occupancy has crept beyond what the property was assessed for. This is the most common single reason an assessment stops being valid.
Who the occupants actually are: students, working professionals, families, people placed by the council, anyone whose circumstances mean they might need help to evacuate.

Escape

The route from every letting room to a final exit, and whether it is protected — meaning fire-resisting construction and doors separating the route from the accommodation and risk rooms.
Whether the route passes through or beside the kitchen, and if so what compensates for that.
Inner rooms, where escape depends on passing through another room.
Final exits: openable from the inside without a key, at all times. Key-operated deadlocks on the front door of an HMO are a serious finding, and one that recurs.
Escape from upper floors, and any reliance on windows.
Whether the route is actually clear — bikes, bin bags, furniture and deliveries in the hallway are the normal state of many HMOs, not the exception.

Detection and warning

The Smoke and Carbon Monoxide Alarm (England) Regulations 2015, as amended in 2022, set the baseline for rented homes. The landlord must ensure:

"a smoke alarm is equipped on each storey of the premises on which there is a room used wholly or partly as living accommodation"

and:

"a carbon monoxide alarm is equipped in any room of the premises which is used wholly or partly as living accommodation and contains a fixed combustion appliance other than a gas cooker"

Since 1 October 2022 there is also a repair duty:

"where, following a report made on or after 1st October 2022 by a tenant or by their nominated representative to the landlord, a prescribed alarm is found not to be in proper working order, the alarm is repaired or replaced."

Treat that as a floor, not a specification. These Regulations apply to rented homes generally; they are not an HMO detection design. The assessment has to reach its own reasoned conclusion about what the layout, the escape strategy and the occupancy actually require — including whether detection needs to be interlinked so that an alarm in one part of the house wakes someone asleep elsewhere, whether the shared areas and individual rooms are both covered, and how a warning reaches someone behind a closed, locked room door. Councils commonly have published expectations for licensable HMOs; where they do, check them, because the licence inspection will.

Also record how alarms are tested, by whom, and where that is logged — see the fire safety log book.

Fire doors and separation

Doors to letting rooms and to risk rooms (kitchen, boiler room, any room with a solid-fuel appliance).
Self-closing devices present and working, not removed or disabled — endemic, because tenants find self-closers annoying.
Intumescent strips and cold smoke seals intact.
Gaps around the leaf within tolerance.
Doors not wedged or propped, which is a management finding as much as a physical one.
Compartmentation integrity, especially where services and cabling have been run through walls and ceilings during conversion work. Older conversions are where this most often fails.

Our fire door inspection guide covers door checks in detail, and the free fire door checklist works through them systematically on site.

The kitchen and other ignition sources

Cooking arrangements: shared kitchen, kitchenettes in rooms, or both. Unsupervised cooking is the leading cause of fires in this property type.
Whether the kitchen sits on the escape route and what mitigates that.
Condition of appliances, extraction and cleanliness.
Portable heaters, which appear whenever heating is inadequate and are a genuine indicator worth recording.
Electrical installation condition, and multi-way adaptor use — a strong proxy for insufficient sockets.
Charging: phones, laptops, and increasingly e-bikes and e-scooters, sometimes charged in bedrooms or hallways on the escape route. This deserves an explicit position rather than silence.
Smoking arrangements, including where people actually smoke as opposed to where they are told to.
Any solid fuel appliance, with the CO alarm duty above.
Arson risk: external bin storage, letterbox exposure, and how secure the property is out of hours.

Management

This is where HMO assessments most often go thin, and it is arguably the most important part, because in a building with no staff the management arrangements are the fire safety system.

Who is responsible for keeping shared areas clear, and how that is actually achieved rather than merely stated in a tenancy agreement.
What tenants are told on moving in about the alarm, the escape route, and what to do — and whether new tenants joining mid-tenancy get the same.
Testing regime for alarms and emergency lighting, and where records live.
How faults get reported and how quickly they are fixed.
How often anyone actually walks the property.
Whether the "stay put or evacuate" position is decided, appropriate to the construction, and communicated. In most shared houses the answer is simultaneous evacuation, but it must be a decision rather than an assumption.

Occupants who need assistance

If any occupant could not evacuate unaided, the general arrangements are not sufficient and an individual plan is needed. In an HMO this changes over time as tenancies change, which is precisely why it belongs in the review triggers. Our guide to PEEPs and who needs one covers individual planning.

Recording and Reviewing

Under section 156 of the Building Safety Act 2022, GOV.UK guidance states:

"You must now record the fire risk assessment in full (including all the findings) and the fire safety arrangements for your premises in all circumstances."

No employee threshold, no small-landlord exemption.

Article 9(3) requires review "regularly ... and particularly if— (a) there is reason to suspect that it is no longer valid; or (b) there has been a significant change". HMOs generate those changes faster than most premises: a room converted or subdivided, occupancy increased, a change in the type of occupant, a new cooking arrangement, works to the layout, or a change of managing agent. Our guide to how often a fire risk assessment should be reviewed covers the triggers and the free FRA review date calculator sets the next date.

Before you start on site, the free HMO fire safety requirements checker helps calibrate what applies to the property's size and occupancy, and our 30-point fire risk assessment checklist covers the general on-site ground. For the wider HMO picture see our HMO assessor guide.

Doing It Yourself, or Not

A competent landlord with a simple two-storey shared house may reasonably carry out the assessment themselves. The honest markers that you should not are: a property of three or more storeys, bedsit-style occupation with locks on room doors, any occupant who would need help evacuating, uncertainty about whether the escape route is properly protected, or a conversion whose compartmentation you cannot verify.

The Order requires the responsible person to appoint a competent person where they lack the competence themselves, and the judgement of competence sits with you. Our guide to how to choose a fire risk assessor sets out what to check, and the fire risk assessment cost guide gives realistic fee ranges for HMOs.

Summary

There is no statutory HMO fire risk assessment template, and the council forms and association forms that exist are practical aids rather than legal instruments. What is fixed is the outcome: a suitable and sufficient assessment, recorded in full.

Three regimes overlap on the same building — the Fire Safety Order over the common parts, the Housing Act 2004 HHSRS over the whole property including inside letting rooms, and licensing conditions where the property is licensable — which needs five or more occupants in two or more households and one of the section 254 occupancy tests, not the headcount alone. They have different enforcers, so covering only the common parts leaves a real gap.

Cover the building and its actual occupation, escape from every letting room including whether the route passes the kitchen, detection that goes beyond the statutory alarm floor, fire doors and compartmentation, the kitchen and the other ignition sources including charging, and management — which in a building with no staff is the fire safety system rather than an afterthought. Then review it whenever the property, its occupancy or its occupants change, which in an HMO is often.

For assessors working HMO portfolios, AssessKit structures every assessment to a recognised methodology (PAS 79-1 for non-domestic premises, BS 9792:2025 for housing), tracks remedial actions through to completion, and holds review dates per site so a portfolio of small properties with frequent tenancy changes stays current. Start free — the Free plan covers two assessments a month, no card required. See pricing or read about who is building it.

Sources

Frequently asked questions

Is there an official HMO fire risk assessment template?

There is no statutory template. Councils publish their own forms and landlord associations publish theirs, which is why they differ — they are practical aids, not legal instruments. What the law fixes is the outcome: a suitable and sufficient assessment, recorded in full, covering the risks to everyone in the building. The structure you present it in is a professional choice, and a form that leaves out the HMO-specific ground is worse than no form at all.

What must an HMO fire risk assessment cover?

The general fire risk assessment ground plus the things specific to shared occupation: the escape route from every letting room and whether it is protected, the detection arrangement across shared and private areas, fire doors to letting rooms and risk rooms, the kitchen as the dominant ignition source, cooking and smoking arrangements, occupancy and who the occupants actually are, and management — because in an HMO nobody is in charge of the shared areas unless the landlord makes it so.

Which laws apply to an HMO fire risk assessment?

Three regimes overlap. The Fire Safety Order applies to the common parts and requires the fire risk assessment. The Housing Act 2004 gives the council its HHSRS powers over the whole property including inside letting rooms, with fire as a specific hazard. And if the property is licensable, the licence conditions add their own requirements. They have different enforcers, so a property can satisfy one and be enforced against under another.

Does a smoke alarm on each floor satisfy an HMO?

Not necessarily, and treating it as the standard is a common error. The Smoke and Carbon Monoxide Alarm (England) Regulations 2015 set a floor — an alarm on each storey with living accommodation, and a CO alarm in any room with a fixed combustion appliance other than a gas cooker. That is a minimum applying to rented homes generally, not a considered HMO detection design. The assessment has to reach its own conclusion about what the layout, occupancy and escape strategy require.

Do I need a licence for my HMO, and does it change the assessment?

Mandatory licensing applies where an HMO is occupied by five or more persons living in two or more separate households AND meets one of the three occupancy tests in section 254 of the Housing Act 2004 — the standard test, the self-contained flat test (which excludes a purpose-built flat in a block of three or more self-contained flats), or the converted building test. All three limbs of Article 4 have to be met, not just the headcount. The old three-storey condition was removed in 2018. Councils also run additional and selective licensing schemes locally, so check with yours. Licensing does not change the fire risk assessment duty, but licence conditions can impose specific requirements, and the licensing inspection is often where fire safety failings surface.

How often should an HMO fire risk assessment be reviewed?

The Order requires review regularly and particularly where there is reason to suspect it is no longer valid or there has been a significant change. HMOs change more often than most premises: tenant turnover, a room converted, occupancy increased, a new cooking arrangement, or a tenant whose circumstances mean they would need help evacuating. An annual review is the common baseline, with a review triggered by any of those changes in between.

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