Fire Safety in HMOs - Landlord Requirements

Houses in Multiple Occupation (HMOs) have some of the most stringent fire safety requirements of any residential property type. This isn't bureaucracy — it's because HMOs present genuinely higher fire risks than standard housing, and fire safety failures in HMOs have led to tragic loss of life.

If you're a landlord or managing agent responsible for an HMO, understanding and implementing proper fire safety measures isn't optional. It's a legal requirement, and enforcement has intensified significantly in recent years.

What is an HMO?

A House in Multiple Occupation (HMO) is defined under the Housing Act 2004. A property is an HMO if:

• Three or more people live there who form more than one household
• Toilet, bathroom, or kitchen facilities are shared

The most common types are:

Standard shared house HMO — Multiple tenants with individual tenancy agreements sharing a kitchen and bathroom. This is the "classic" student house or young professional share.

Bedsit HMO — Self-contained rooms with individual facilities, but some amenities are shared (e.g., shared bathroom or kitchen).

Converted building HMO — An entire building or part of a building converted into individual units, with some shared facilities.

HMO in a building with other uses — Part of a building used as an HMO while other parts have different uses (e.g., flat above a shop).

Mandatory licensing

If your HMO meets any of these criteria, you need a mandatory HMO licence from your local council:

• 5+ people forming 2+ households
• Building of 3+ storeys (including basements and converted lofts)

Many councils also have additional licensing or selective licensing schemes covering smaller HMOs. Check with your local authority.

Operating an unlicensed HMO is a criminal offence with penalties up to £30,000, rent repayment orders, and banning orders preventing you from letting property.

Why HMO fire safety is different

HMOs present higher fire risks than standard single-occupancy homes for several reasons:

1. Sleeping risk is multiplied

People are most vulnerable to fire when asleep. In an HMO, multiple households are sleeping in the same building, often unfamiliar with each other's routines. A fire starting in one tenant's room at 3am puts everyone else at immediate risk.

2. Multiple ignition sources

More occupants means more cooking, more electrical appliances, more potential ignition sources. Each tenant's behavior contributes to the overall fire risk, but no single tenant has full visibility or control.

3. Shared escape routes

If the only escape route from an upstairs bedroom is through a shared hallway, and that hallway fills with smoke from a kitchen fire, occupants are trapped. Compartmentation and protected escape routes become critical.

4. Diverse occupant profiles

Unlike a family home where everyone knows the evacuation plan, HMO tenants may have varying levels of fire awareness, language barriers, or mobility issues. Turnover is often high, meaning the tenant population changes frequently.

5. Landlord control is limited

Once you've handed over keys, you have limited control over tenant behavior — overloaded sockets, blocked fire escapes, disabled smoke alarms. But the legal responsibility for fire safety remains with you, the landlord.

HMO fire safety requirements

Fire safety in HMOs is governed by two main pieces of legislation:

1. The Regulatory Reform (Fire Safety) Order 2005 (FSO) — covers fire risk assessment and general fire precautions in the common areas
2. The Housing Act 2004 and associated regulations — sets specific standards for fire detection, emergency lighting, fire doors, and escape routes

You must comply with both.

Fire risk assessment (FSO 2005)

You must have a written fire risk assessment covering:

• Common areas (hallways, stairs, shared kitchen, shared bathrooms)
• Fire hazards and ignition sources
• People at risk (all tenants, visitors, anyone who might need assistance)
• Existing fire precautions
• Identified improvements needed

Fire detection and alarm systems

Minimum standard for all HMOs:

• Mains-powered smoke alarms on each floor
• Heat detectors in the kitchen (not smoke alarms, which cause false alarms)
• All alarms interconnected (when one sounds, they all sound)

For licensed HMOs, the standard is higher:

• Grade D LD2 system (minimum) — mains-powered with battery backup, smoke alarms in escape routes and circulation spaces, heat detector in kitchen
• Grade A LD2 system (often required) — full fire alarm system with break glass call points, sounders, and control panel

The grading and category depend on the HMO size, layout, and risk level. Your local authority or fire risk assessor will specify what's needed.

Emergency lighting

If natural light is insufficient to illuminate escape routes at all times, you need emergency escape lighting:

• Illuminates escape routes if the power fails
• Must operate for at least 3 hours
• Tested monthly (function test) and annually (full discharge test)

Typically required in:

• Internal hallways and corridors
• Stairwells without adequate windows
• Any area that would be dark in a power cut

Fire doors

Fire doors are one of the most critical — and most commonly deficient — elements of HMO fire safety.

30-minute fire doors required for:

• Doors opening onto escape routes (bedroom doors in most HMOs)
• Doors separating different parts of the building
• Kitchen doors (to contain a fire in the highest-risk room)

Fire door requirements:

• FD30 specification (30-minute fire resistance)
• Intumescent strips around the door frame (expand in heat to seal gaps)
• Smoke seals (often combined with intumescent strips)
• Self-closing device — usually a rising butt hinge or door closer
• Correct latch — must be able to close fully and hold closed
• No gaps — maximum 3mm gap around the door when closed

Means of escape

All tenants must be able to escape safely in the event of fire:

• Travel distance — bedrooms should be within 18m of a storey exit (can be reduced to 7.5m in single-direction escape)
• Protected routes — escape routes separated from fire risks by fire-resistant construction and fire doors
• Alternative escape — where possible, two means of escape should be available
• Clear and unobstructed — escape routes kept free of stored items, bikes, rubbish

External escape:

• Final exit doors must be easily openable from the inside without a key
• Escape routes must lead to a safe place (usually the street)

Firefighting equipment

In most HMOs, you're not required to provide fire extinguishers in common areas (though some licensing conditions do require them). However:

• If you do provide extinguishers, they must be the correct type and serviced annually
• Fire blankets in shared kitchens are recommended but not always mandatory

Fire safety information for tenants

You must provide tenants with:

• Fire action notice — what to do if they discover a fire or hear the alarm
• Escape routes — how to exit the building safely
• Location of fire alarm call points (if applicable)
• Fire door policy — emphasizing that fire doors must not be wedged open

This is often provided in a tenant fire safety guide at move-in.

Mandatory licensing vs additional licensing

The fire safety requirements vary depending on whether your HMO requires a licence and what type of licence applies.

Mandatory licensing (larger HMOs)

For HMOs requiring mandatory licensing:

• Full compliance with The Management of Houses in Multiple Occupation (England) Regulations 2006
• Often higher fire safety standards specified in the licence conditions
• Regular inspections by local authority
• Licence holder must be "fit and proper" and demonstrate management competence

Additional and selective licensing

Many councils have additional licensing schemes covering smaller HMOs or selective licensing covering all private rented properties in certain areas.

Even if your HMO doesn't need mandatory licensing:

• You still have fire safety duties under the FSO and Housing Act
• Check if additional/selective licensing applies in your area
• Standards may be similar even without formal licensing

Fire risk assessment for HMOs

Your fire risk assessment should be comprehensive and specific to your property. Generic templates won't suffice.

What the assessment should cover

Premises information:

• Number of storeys and floor layout
• Number of tenants and bedroom locations
• Construction type and age of building
• Any vulnerable occupants or people needing assistance

Fire hazards:

• Electrical installations and portable appliances
• Cooking facilities and kitchen fire risk
• Smoking materials
• Portable heaters
• Waste storage
• Arson risk (external storage, insecure areas)

People at risk:

• All tenants (remember they're asleep for 8+ hours per day)
• Visitors
• Maintenance contractors
• Anyone who might need assistance evacuating

Existing precautions:

• Fire detection and alarm system (grade and category)
• Emergency lighting
• Fire doors and compartmentation
• Escape routes and signage
• Firefighting equipment
• Tenant information and training

Action plan:

• Improvements needed with priorities
• Responsible person for each action
• Target completion dates

Who should conduct the assessment?

For HMOs, use a qualified fire risk assessor with specific HMO experience:

• Look for assessors registered with professional bodies (IFE, IFSM, CFPA)
• Check they have third-party certification (e.g., BAFE SP205)
• Ask about their HMO experience specifically
• Expect to pay £250-600+ depending on property size and complexity

Review frequency

Review your fire risk assessment:

• At least annually (good practice for HMOs)
• After any fire, near-miss, or false alarm
• When you change the layout (convert rooms, alter escape routes)
• When occupancy changes significantly (number of tenants, vulnerable occupants)
• If local fire service or council raises concerns

Common fire safety deficiencies in HMOs

Based on enforcement data and inspection reports, these are the most frequent issues found:

1. Fire doors

• Self-closers removed or not working
• Doors wedged open (even "just during the day")
• Intumescent strips missing or damaged
• Gaps around the door too large
• Non-compliant replacement doors fitted
• Bedroom doors that aren't fire doors at all

Fix: Audit every fire door quarterly. Use a simple checklist: Does it close fully? Does it latch? Are the seals intact? Are gaps less than 3mm?

2. Fire alarm system inadequate

• Battery-only smoke alarms (mains required)
• Alarms not interconnected
• Wrong type in wrong location (smoke in kitchen causing false alarms)
• Alarms past their replacement date (10-year life)
• Insufficient coverage

Fix: Upgrade to at least Grade D LD2. For larger or more complex HMOs, install a full Grade A system. Have it installed and certificated by a competent alarm installer.

3. Blocked escape routes

• Bikes, boxes, or furniture in hallways
• Stored items on landings or stairs
• Bins or clutter near exit doors

Fix: Regular inspections. Include escape route checks in routine property visits. Make it clear to tenants in their tenancy agreement.

4. No fire risk assessment

• No documented assessment at all
• Generic template not specific to the property
• Assessment done by landlord with no competence
• Assessment years out of date

Fix: Commission a proper assessment from a qualified assessor. Budget for it as a routine cost of operating an HMO.

5. Emergency lighting missing or not tested

• No emergency lights where required
• Lights not tested monthly
• No records of testing

Fix: Install compliant emergency lighting where needed. Set up a monthly test regime and record results.

6. Inadequate compartmentation

• Holes in walls/ceilings allowing fire spread
• Services (pipes, cables) passing through walls without fire-stopping
• Missing or damaged ceiling panels
• Loft spaces not properly separated between properties

Fix: Survey the building for breaches in compartmentation. Use fire-rated sealant, fire batts, or fire-resistant boards to restore fire separation.

Fire door requirements — the detail

Fire doors deserve special attention because they're so often deficient. Here's what you need to know:

What is a fire door?

A fire door is a specially constructed door designed to resist fire and smoke for a specified period (usually 30 minutes for HMOs, denoted as FD30).

It comprises:

• The door leaf itself (solid core, fire-resistant materials)
• The frame and architrave (must also be fire-rated)
• Intumescent seals (expand to seal gaps when heated)
• Smoke seals (prevent smoke passage even before intumescent strips activate)
• Self-closing device (ensures the door closes and latches after use)
• Appropriate hardware (latches, hinges, letter plates if any)

Where are fire doors required in HMOs?

• All bedroom doors opening onto an escape route
• Kitchen doors (especially shared kitchens)
• Living room/lounge doors in some configurations
• Doors to storage rooms containing high fire risk items
• Doors at the base of stairs (to protect the stairwell)

Common fire door mistakes

1. Self-closers removed "because tenants don't like them"

This completely defeats the purpose of a fire door. If it's required to be a fire door, it must have a self-closing device. No exceptions.

2. Door stops or wedges holding the door open

Wedging a fire door open — even temporarily — means it won't protect you in a fire. If access is genuinely needed, install a hold-open device linked to the fire alarm (expensive, but compliant).

3. Gaps too large

Check gaps with a £1 coin (roughly 3mm). If the coin slides through easily, the gap is too large. Adjust hinges, fit brush strips, or replace the door.

4. Intumescent strips painted over or missing

Paint can prevent intumescent strips from expanding properly. If you repaint fire doors, be careful around the seals.

5. Holes or glazing panels not fire-rated

Drilling holes for cables, or replacing damaged glass with standard glass, compromises the fire door. Any glazing must be fire-rated.

Maintaining fire doors

Quarterly visual inspection:

• Does the door close fully and latch?
• Are the intumescent and smoke seals intact?
• Are there any gaps larger than 3mm?
• Is the self-closer working correctly?
• Is the door in good repair (no warping, holes, or damage)?

Annual professional inspection: Consider having a fire door inspection specialist check all doors annually, especially in larger HMOs.

Alarm systems — Grade A vs Grade D

Fire alarm systems are graded by power source and sophistication:

Grade D systems

• Mains-powered with battery backup
• Individual alarm units interconnected wirelessly or by cable
• Suitable for smaller, lower-risk HMOs

Pros: Lower cost, easier to retrofit, adequate for many HMOs Cons: No central control panel, harder to identify which sensor activated, limited expandability

Grade A systems

• Full fire alarm system with control panel
• Wired system with break glass call points, detectors, and sounders
• Often required for larger or higher-risk HMOs

Pros: Central control and monitoring, easier to identify fire location, more robust Cons: Higher cost (£1,000-3,000+), requires professional installation and annual servicing

LD2 category

The "LD2" part refers to coverage:

• L = Life protection (as opposed to property protection)
• D2 = Detectors in escape routes plus rooms with significant fire risk

For HMOs, this typically means:

• Smoke alarms in all hallways, landings, and circulation spaces
• Smoke alarms at the head and base of stairs
• Heat detectors in kitchens
• Often smoke detectors in living rooms

Some higher-risk HMOs may require LD1 (detectors in all rooms including bedrooms).

Which system does your HMO need?

Your local authority licensing team or fire risk assessor will specify requirements based on:

• Number of storeys
• Number of tenants
• Complexity of layout
• Travel distances to exits
• Existing building construction

Don't guess. Get professional advice on the appropriate system for your specific HMO.

Working with your local authority

Local council housing and environmental health teams enforce HMO standards. Building a good relationship helps:

Proactive engagement

• Contact them before you start operating an HMO
• Ask for pre-licensing inspections (some councils offer this)
• Seek their advice on borderline issues
• Attend landlord forums or training they offer

During inspections

• Be cooperative and professional
• Have your documentation ready (fire risk assessment, test records, gas/electrical certificates)
• Take notes on what the inspector says
• Ask for clarification if you don't understand requirements

After inspections

• Take enforcement notices seriously — compliance deadlines are legal requirements
• If you can't meet a deadline, communicate early and show what you're doing
• Don't wait until the last minute to commission work
• Keep records of all improvements made

Costs of HMO fire safety compliance

Budget for fire safety as an operating cost, not a one-off expense.

Initial compliance (for a typical 5-bed HMO):

• Fire risk assessment: £300-600
• Fire alarm upgrade (Grade D LD2): £800-1,500
• Fire alarm upgrade (Grade A LD2): £1,500-3,000
• Fire doors (if replacing all bedroom and kitchen doors): £3,000-6,000
• Emergency lighting: £500-1,500
• Compartmentation repairs: £500-2,000 (highly variable)

Total initial compliance cost: £5,000-15,000+ depending on starting condition

Annual ongoing costs:

• Fire alarm service (Grade A): £150-250
• Emergency lighting annual test: £100-200
• Fire extinguisher service (if fitted): £50-100
• Fire risk assessment review: £200-400
• Replacement smoke alarms (Grade D, 10-year life): budget £50-100/year

Total annual ongoing cost: £550-1,050+

These costs are unavoidable if you operate an HMO. Factor them into your rental yield calculations.

Tenant responsibilities and landlord duties

While you as landlord hold the ultimate legal responsibility, tenants have duties too:

What tenants must do:

• Not tamper with fire safety equipment (alarms, fire doors)
• Not block escape routes or store items in hallways
• Report defects (broken self-closers, damaged alarms) promptly
• Follow the fire action plan in the event of fire
• Not introduce high fire-risk items without permission (e.g., certain heaters)

What you must do:

• Provide and maintain all fire safety equipment
• Inspect regularly to ensure equipment remains functional
• Respond quickly to reported defects
• Enforce rules about escape routes and fire door management
• Educate tenants about fire safety at move-in

Include fire safety clauses in tenancy agreements:

• Prohibition on tampering with alarms or fire doors
• Requirement to keep escape routes clear
• Right of access for fire safety inspections and maintenance
• Consequences for breaches (potential eviction for serious breaches)

Frequently asked questions

Next steps

If you operate or plan to operate an HMO:

1. Confirm your HMO status — check with your local authority if you're unsure
2. Check licensing requirements — apply for a licence if needed (or confirm additional/selective licensing doesn't apply)
3. Commission a fire risk assessment — use a qualified assessor with HMO experience
4. Implement the action plan — prioritize high-risk findings and address them urgently
5. Establish maintenance schedules — weekly alarm tests, monthly emergency light checks, quarterly door inspections
6. Document everything — keep records of assessments, tests, maintenance, and tenant communications

Resources:

• What is a fire risk assessment? — understand the assessment process in detail
• Do I need a fire risk assessment? — decision tool for all property types
• Fire Safety Responsibility Checker — identify who's responsible in your situation

Download our HMO Fire Safety Checklist — comprehensive checklist covering all requirements for Houses in Multiple Occupation.

Related content:

• Landlords sector guide — all your landlord health and safety duties
• Fire Safety topic page — comprehensive fire safety guidance
• HMO licensing requirements — understand licensing rules

This article provides general guidance on fire safety requirements for HMOs under UK law. It is not legal advice. Fire safety requirements can vary based on specific circumstances, local authority conditions, and building characteristics. Always consult with a qualified fire risk assessor and your local authority housing team for advice specific to your property.