HMO Fire Risk Assessment — Do I Need One?

Do I need a fire risk
assessment for my HMO?

Yes. All Houses in Multiple Occupation require a fire risk assessment. It is a legal requirement under both the Regulatory Reform (Fire Safety) Order 2005 and the Housing Act 2004, and is a mandatory condition of every HMO licence application in England.

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Legal requirement for all HMOs
Mandatory for HMO licence applications
Applies regardless of property size
FireCertificates arranges HMO assessments across Hampshire, Surrey and Berkshire
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HHR Holdings Ltd t/a firecertificates.co.uk · Co. No. 17177195 · ICO ZC132343. Not a fire safety company. All assessment work by independent BAFE/IFE-registered professionals. No obligation.

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Short Answer: Yes

Every HMO requires a fire risk assessment regardless of size, age of property or number of tenants.

Licensing Requirement

HMO licence applications require a valid fire risk assessment as a core condition. No assessment, no licence.

Housing Act 2004

In addition to the Fire Safety Order, the Housing Act 2004 imposes specific fire safety requirements on HMO landlords.

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HMO Fire Risk Assessment — The Legal Position

Why every HMO landlord
needs an assessment.

There is no size threshold, no age exemption and no occupancy minimum. If your property meets the definition of an HMO, a fire risk assessment is legally required.

The definition of an HMO

A property is an HMO if it is occupied by three or more people forming two or more households who share facilities such as a kitchen or bathroom. This applies to shared houses, bedsits, converted flats and purpose-built student accommodation. A household is a single person or a group of people related by blood, marriage or civil partnership.

The two legal frameworks

HMO landlords face requirements under two separate pieces of legislation. The Regulatory Reform (Fire Safety) Order 2005 applies to communal areas of all HMOs. The Housing Act 2004 imposes additional fire safety requirements through the HHSRS (Housing Health and Safety Rating System) and the HMO licensing regime.

HMO licensing and fire risk assessments

Mandatory HMO licensing applies to properties of five or more tenants in two or more households. All local authorities have power to introduce additional licensing schemes covering smaller HMOs. In both cases, a valid fire risk assessment is a core licensing condition. A licence application without one will not be processed.

Housing Act 2004 — HMO Licensing
"A licence may not be granted unless the authority is satisfied that the proposed licence holder is a fit and proper person and that the house is reasonably suitable for occupation as an HMO."

Housing Act 2004. Fire safety, including a valid fire risk assessment, is a core element of whether an HMO is considered suitable for occupation under licensing requirements.

01
3+ tenants sharing facilitiesAny property meeting this definition is an HMO and requires a fire risk assessment, regardless of whether it requires a licence.
02
Mandatory licensing (5+ tenants)Mandatory licensing applies nationally. A valid fire risk assessment is a core licensing condition.
03
Additional licensing schemesMany councils in Hampshire, Surrey and Berkshire operate additional licensing covering smaller HMOs. Check your local council's scheme.
04
Annual reviewThe assessment must be reviewed annually and after any change of tenancy or premises. A stale assessment can cause licence renewal to fail.
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Common Questions

Questions answered.

Do I need a fire risk assessment for a small HMO with only three tenants?+
Yes. There is no minimum size threshold. Any property occupied by three or more unrelated tenants sharing facilities is an HMO and requires a fire risk assessment under the Regulatory Reform (Fire Safety) Order 2005. Even if your property does not require a licence, the legal requirement for a fire risk assessment still applies.
What happens if I apply for an HMO licence without a fire risk assessment?+
Your application will not be processed. A valid fire risk assessment is a mandatory condition of HMO licence applications at every local authority. Without it, neither a new application nor a licence renewal will succeed.
How much does an HMO fire risk assessment cost?+
Most HMOs cost £250–£450 for a standard three to six bedroom property. Larger or more complex properties may cost £400–£550 or more. Contact FireCertificates for a specific assessment for your property.
Who can carry out an HMO fire risk assessment?+
The assessment must be carried out by a competent person. BAFE SP205 registration and IFE membership are the recognised benchmarks. The assessment must comply with BS 9792:2025, the current British Standard for fire risk assessments in sleeping accommodation. FireCertificates only works with assessors meeting these qualifications.
Do I need a new fire risk assessment every time a tenant changes?+
Not necessarily a completely new assessment, but a review is good practice after every tenancy change. A change in the number of tenants or the type of occupancy may affect the risk profile of the property. Annual reviews as a minimum are recommended for all HMOs.
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Email: hello@firecertificates.co.uk — we respond within 2 hours. Not a fire safety company — all assessment work by independent registered professionals.

HHR Holdings Ltd t/a firecertificates.co.uk · Co. No. 17177195 · ICO ZC132343. Not a fire safety company. All assessment work by independent BAFE/IFE-registered professionals.

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We will be in touch within 2 hours during working hours. For urgent matters email hello@firecertificates.co.uk directly.

Not a fire safety company

FireCertificates.co.uk is a specialist connection service. We are not fire risk assessors and do not carry out assessments. All assessment work is performed by independent BAFE SP205 or IFE-registered assessors under their own professional terms of engagement.

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Every assessor in the FireCertificates network holds a recognised professional qualification — BAFE SP205, IFE or equivalent — and carries current professional indemnity insurance. We do not refer to unaccredited assessors.

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