HMO fire safety: what landlords must do

As the landlord of a house in multiple occupation (HMO), you are responsible for fire safety in the shared parts of the building, and housing law expects the whole property to have adequate fire precautions. In practice that means a written fire risk assessment, an interlinked fire alarm suited to the size and layout of the house, fire doors protecting the escape route, and keeping all of it maintained. Your council sets the detail for your property, and most councils base their standards on the LACORS fire safety guidance.

The rules that apply

Several pieces of legislation overlap in an HMO in England.

• The Regulatory Reform (Fire Safety) Order 2005 applies to the common parts of an HMO, such as shared hallways, stairs and kitchens. The Responsible Person, usually the landlord or managing agent, must carry out a fire risk assessment and maintain the fire precautions.
• The Housing Act 2004 gives councils powers to deal with hazards in rented homes, including fire, under the Housing Health and Safety Rating System. It also sets up HMO licensing.
• The Management of Houses in Multiple Occupation (England) Regulations 2006 require the manager to keep the means of escape free from obstruction and in good repair, and to keep fire alarms and firefighting equipment in good working order.
• The Smoke and Carbon Monoxide Alarm (Amendment) Regulations 2022 require private landlords, from 1 October 2022, to have at least one smoke alarm on every storey used as living accommodation, and a carbon monoxide alarm in any room used as living accommodation with a fixed combustion appliance, other than a gas cooker. Alarms reported as faulty must be repaired or replaced.

Gas safety and electrical safety checks are separate duties, and are not covered here.

Licensing and the council's standards

An HMO occupied by five or more people forming two or more households needs a mandatory licence from the council. Many councils also run additional licensing schemes that cover smaller HMOs.

A licence comes with conditions, which usually include fire safety requirements, such as the type of fire alarm, fire doors to certain rooms, and annual alarm and emergency lighting certificates. The council will normally inspect before or after granting the licence. Whether your HMO is licensed or not, the council can take enforcement action if the fire precautions are inadequate.

Most councils base their fire safety expectations on the LACORS guidance, Housing – Fire Safety: Guidance on fire safety provisions for certain types of existing housing. It sets out typical provisions for different types and sizes of HMO. Check your council's own HMO standards, as some go further.

Fire risk assessment

The Fire Safety Order requires a fire risk assessment of the common parts, and in England the whole assessment must be recorded in writing. For HMOs, assessors often follow PAS 79-2:2020, the code of practice for fire risk assessment of housing.

A good assessment looks at the whole escape route from each bedroom to the final exit, the alarm system, the doors, the kitchen, and how the house is actually used, including what tenants store in the hallway. It produces an action plan that tells you what needs doing first. Review it regularly, and whenever the layout, the number of occupants or the way the house is used changes. Read do I need a fire risk assessment? for more on what it involves.

Fire alarms

Fire alarms in HMOs are usually designed to BS 5839-6, the code of practice for domestic premises. It describes systems by grade, which is about the type of equipment and power supply, and category, which is about where the detectors go.

Councils commonly expect a mains-powered system with a standby supply, where all the alarms are interlinked so that a fire anywhere sets off every alarm. The usual pattern is smoke alarms in the escape route and in rooms opening onto it, including bedrooms, and a heat alarm in the kitchen. Larger HMOs, and those over several storeys, may need a system with a control panel, serviced by an engineer.

The exact system depends on the number of storeys, the number of occupants, the layout and the council's standards, so take the specification from your fire risk assessment and licence conditions. Battery-only smoke alarms are rarely enough for an HMO.

Test the alarms regularly and keep a record. Systems with a control panel should be serviced by a competent engineer at least every six months. Our guide to fire alarm servicing and testing explains what that involves.

Fire doors

Fire doors stop fire and smoke spreading into the escape route long enough for people to get out. In many HMOs, the doors from bedrooms and the kitchen onto the hallway or stairs need to be fire doors, commonly giving 30 minutes of fire resistance, with intumescent strips and smoke seals, and often with self-closing devices. The requirement depends on the type and size of the HMO and the layout of the escape route.

Fire doors only work if they are fitted and maintained properly. Check regularly that they close fully into the frame, that the seals are intact, and that no one has wedged them open or removed a closer. Replacement doors should be certified fire door sets, fitted to the manufacturer's instructions. You can get quotes for fire door inspection, repair and replacement.

Escape routes

Every occupant needs a safe way out. The main principles are:

• A protected route. The hallway and stairs from each bedroom to the front door should be separated from the rest of the house by fire-resisting walls and doors
• No inner rooms. A bedroom should not be reached only through another room where a fire could start, such as a kitchen or living room
• Keep it clear. No bikes, furniture, rubbish or stored items in the escape route
• No keys needed to get out. Final exit doors and bedroom doors should open from the inside without a key, for example with a thumb-turn lock

Emergency lighting

Emergency lighting is not needed in every HMO. It is more likely to be required where the escape route is long or complex, has no natural light, or serves larger numbers of people. Your fire risk assessment and the council's standards will say whether you need it. Where it is fitted, it needs a monthly functional test and an annual full-duration test. See our guide to emergency lighting testing.

Maintenance and records

Keep certificates, test records and your fire risk assessment together, because the council will ask for them at a licence application or inspection.

Scotland, Wales and Northern Ireland

This guide covers England. Scotland, Wales and Northern Ireland have their own HMO licensing schemes and their own rules on smoke alarms in rented homes. If your HMO is outside England, check with the council for the property.