Fire Risk Assessments for Holiday Lets

A holiday let needs a fire risk assessment. Your own home does not. It can be the same building.

That sounds like a contradiction until you look at how the Fire Safety Order defines what it excludes, which is the part most guidance skates over. The Order does not apply to "domestic premises" — but "domestic premises" means premises occupied as a private dwelling, and a cottage occupied by paying guests is not occupied as a private dwelling while they are in it. The scope test is about the character of the occupation, not the type of building. That single distinction is what puts self-catering lets, B&Bs, guest houses and short-term rentals inside a legal framework that many owners assume applies only to hotels.

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 fire and rescue authority.

Where the Scope Test Actually Turns

Article 6(1) of the Regulatory Reform (Fire Safety) Order 2005 opens with the exclusion:

"This Order does not apply in relation to — (a) domestic premises, except to the extent mentioned in paragraph (1A) or article 31(10)..."

(The remaining limbs of Article 6(1) cover offshore installations, ships, agricultural land, aircraft, mines and boreholes — none of which bear on a holiday let.)

Read alone, that looks like it takes any house out of scope. The work is done by the definition in Article 2, where "domestic premises" means:

"premises occupied as a private dwelling (including any garden, yard, garage, outhouse, or other appurtenance of such premises which is not used in common by the occupants of more than one such dwelling)"

Occupied as a private dwelling. Not "capable of being a dwelling", not "built as a house" — occupied as one. A property being let to paying guests is being used for the business of providing accommodation. It is not, during that use, occupied as somebody's private dwelling.

Article 2 also defines who the assessment has to protect. "Relevant persons" covers anyone lawfully on the premises, or in the immediate vicinity, who is at risk from fire — firefighters attending in the course of their duties under the Fire and Rescue Services Act 2004 are expressly excluded. For a holiday let that is your guests, their children, anyone they bring, and a neighbour in an attached property.

The government's own position matches this reading. GOV.UK publishes Making your small paying guest accommodation safe from fire — guidance issued under Article 50 of the Order, last updated 20 January 2025 — written for:

"people responsible for fire safety in paying guest accommodation that has: a simple layout, limited fire risks, a small number of bedrooms designated as guest sleeping accommodation for short-term lets"

with examples given as a small bed and breakfast, guest house, or self-catering accommodation. The government would not publish Article 50 guidance for responsible persons in self-catering accommodation if self-catering accommodation had no responsible person.

What this means for the common questions. Size does not decide it: a single let room engages the same framework as a six-bedroom cottage. Frequency does not decide it either — the character of the occupation while guests are in the property is what matters. What size and frequency do change is how much the assessment has to say, which is a genuine and significant difference. A simple one-bedroom flat let a few weekends a year does not need the assessment a large multi-storey property with year-round occupancy needs.

Who the Responsible Person Is

Under Article 3, where premises are not a workplace, the responsible person is:

"the person who has control of the premises (as occupier or otherwise) in connection with the carrying on by him of a trade, business or other undertaking"

For an owner who lets and manages the property, that is the owner. The arrangement worth thinking about carefully is the managed one. Where a letting agency handles bookings, changeovers, cleaning and maintenance, control is genuinely split — and the failure mode is both parties assuming the other holds the duty. The assessment should record who controls what: who holds the keys, who arranges gas and electrical safety checks, who tests the alarms between guests, who responds when a guest reports a fault.

Handing management to an agency does not automatically hand over the responsible-person duty. If you retain control of the property in connection with your letting business, you retain a duty. Our guide to who is responsible for a fire risk assessment works through the allocation test.

Why Guest Unfamiliarity Is the Whole Problem

Almost everything distinctive about holiday let fire safety comes from one fact: your occupants are asleep in a building they have never been in before.

Compare it to a workplace. Staff know where the exits are. They have had training. They have done a drill. Someone is nominated to sweep the building. None of that exists in a holiday let. Your guests arrived at four in the afternoon, found the fridge and the WiFi password, and by midnight they are asleep on the second floor of a converted barn with an unfamiliar stair, in the dark, possibly having had a drink, possibly with young children in a different room.

Every choice in the assessment should be tested against that scenario. Not "is there an escape route?" but "would somebody who arrived today find it at 2am?"

That reframing does real work. It is why written information in the property matters more than it would in an office. It is why a key-operated lock on a final exit door is a much more serious finding in a let than in a workplace where staff know where the key hangs. It is why an internal layout that makes sense once you know the building can still be a problem.

What the Assessment Needs to Cover

The framework is the same as any premises; the emphasis differs. Adapt depth to the property.

Detection and warning

Coverage on every level, positioned for the actual layout rather than the minimum. In a multi-storey property, interlinked detection so an alarm downstairs wakes someone on the top floor is the point of the exercise — a single isolated alarm can be sounding in an empty kitchen while the person at risk hears nothing. Also: how detection is tested between guests, who does it, and where that is recorded.

There is no single answer to "what detection does my holiday let need" that survives contact with real buildings, and anyone giving you one without seeing the property is guessing. What is consistent is that the assessment must reach a reasoned conclusion on detection and record it.

Escape routes

The route from every sleeping room to a final exit, considered in darkness by someone unfamiliar with the building. Whether the route passes through a higher-risk room — a kitchen or a room with a wood burner — which matters much more where the occupants are asleep and unfamiliar. Whether final exit doors open without a key from the inside, which is the single most common serious finding in this property type. Inner rooms with only one way out through another room. Whether escape from upper floors depends on a window, and if so whether it is openable and reachable.

Higher-risk features

Holiday lets concentrate exactly the features guests are least equipped to use safely, because these are the features that sell the booking:

• Open fires and wood burners. Guest instructions, a guard, a hearth, safe ash disposal (a bucket of "cold" ash on a wooden deck is a recognised ignition scenario), and whether the flue is swept on a recorded schedule.
• Barbecues, fire pits and pizza ovens, and their proximity to the building, fencing and stored fuel.
• Hot tubs and saunas — electrical supply, RCD protection, and the enclosure they sit in.
• LPG and oil, cylinder storage and appliance servicing.
• Candles and decorative fires, which guests will use whatever the house rules say.
• Charging. Guests arrive with phones, laptops, e-bikes and e-scooters. Lithium-battery charging in a sleeping-risk property with unfamiliar occupants deserves an explicit position in the assessment and in the guest information, not silence.
• Multi-way adaptors and extension leads, especially in older properties with few sockets.

Information for guests

This is the control that substitutes for the training and drills a workplace has, and it is usually the weakest part of a holiday let's arrangements. What guests are told, where, and whether they will actually read it:

• A clear notice of what to do on discovering a fire and on hearing the alarm, positioned where it will be seen rather than filed in a welcome folder on a shelf.
• The escape route and the final exit to use, and where to assemble.
• Where the alarm points and extinguishers are, if provided.
• Instructions for the wood burner, barbecue, hot tub and any other higher-risk feature.
• The property address, because a guest calling 999 in an unfamiliar rural location frequently cannot say where they are. This is a small detail that matters disproportionately.

Management

Who checks what between guests and where it is recorded — alarm tests, escape route clear, exit doors operable, extinguisher in place. What happens when a guest reports a fault mid-stay: who they call, and how quickly someone can attend, which is a real constraint for a remotely-managed rural property. Whether larger groups than the property was assessed for are being accepted, which quietly invalidates the assessment.

Guests Who Cannot Evacuate Unaided

If the property is marketed as accessible, or you accept bookings from guests who would need assistance to evacuate, the general arrangements are not enough on their own. The duty to assess risk to all relevant persons does not soften because the occupant is a guest rather than an employee.

The practical difficulty in a holiday let is real and worth naming: you will often not know until arrival, and there may be no staff on site at all. That is a reason to think about it at the booking stage — asking, and being ready to say honestly what the property can and cannot accommodate — rather than a reason to leave it out of the assessment. Our guide to PEEPs and who needs one covers individual planning.

Recording and Reviewing

The recording position is not discretionary. 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."

There is no employee threshold and no small-property exemption. A sole owner letting one cottage records the assessment in full.

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". In a holiday let the significant changes are recognisable: a loft or garage conversion creating a new sleeping room, installing a wood burner or hot tub, accepting larger groups, a change in guest profile, a change of managing agent, or a neighbouring property changing use where it is attached.

Our guide to how often a fire risk assessment should be reviewed covers the triggers, the free FRA review date calculator sets the next date, and what a fire evacuation plan must contain covers the written arrangements. For the records side, see the fire safety log book.

If You Are Commissioning One

Holiday lets are small premises with sleeping risk, which is an unusual combination — small enough that owners assume it is trivial, risky enough that it is not. When appointing an assessor, ask about experience with sleeping accommodation specifically rather than general commercial work, and about the property type: a converted barn with a galleried landing raises different questions from a terraced town flat.

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. If you are considering doing it yourself, the GOV.UK paying-guest-accommodation guide above is written for exactly that, and our 30-point checklist is a general working list to adapt — but be honest about whether the property is simple enough. A single-storey flat is a different proposition from a three-storey conversion with an inner room.

Summary

The Fire Safety Order excludes domestic premises, but "domestic premises" means premises occupied as a private dwelling — and a property occupied by paying guests is not. That is why the same cottage is outside the Order when you live in it and inside it when you let it, and why GOV.UK publishes Article 50 guidance for responsible persons in self-catering accommodation. Size and letting frequency change how much the assessment must say, not whether one is required.

Build the assessment around guest unfamiliarity, because that is what genuinely distinguishes this property type: unfamiliar people, asleep, in the dark, with no training and no drill. Cover detection on every level and interlinked in multi-storey properties, escape routes tested against the 2am scenario, keyless exit doors, the higher-risk features that sell the booking (wood burners, hot tubs, barbecues, e-bike charging), and the guest information that substitutes for staff training — including the property address. Record it in full, and review it whenever the building, the features or the guest profile changes.

For assessors covering portfolios of small sleeping-risk premises, AssessKit structures every assessment to a recognised methodology (PAS 79-1 for non-domestic premises, BS 9792:2025 for housing), tracks remedial actions to completion, and holds review dates per site so annual cycles across many small properties do not depend on memory. Start free — the Free plan covers two assessments a month, no card required. See pricing or read about who is building it.

Sources

• Regulatory Reform (Fire Safety) Order 2005 (legislation.gov.uk)
• Article 2 — Interpretation, including "domestic premises" and "relevant persons" (legislation.gov.uk)
• Article 3 — Meaning of "responsible person" (legislation.gov.uk)
• Article 6 — Application to premises (legislation.gov.uk)
• Article 9 — Risk assessment (legislation.gov.uk)
• Article 50 — Guidance (legislation.gov.uk)
• Making your small paying guest accommodation safe from fire (GOV.UK, updated 20 January 2025)
• Fire safety responsibilities under section 156 of the Building Safety Act 2022 (GOV.UK)