HMO Fire Risk Assessments in London: What Landlords Must Do

If you let a house in multiple occupation (HMO) in London, a written fire risk assessment is not optional. It is a legal duty under the Regulatory Reform (Fire Safety) Order 2005, and your local council will almost certainly ask for it as part of your HMO licence.

HMOs carry a higher fire risk than ordinary family homes. Several unrelated people sleep under one roof, often with locks on bedroom doors, shared kitchens, more electrical appliances and a single escape route down a shared staircase. That is why the law, the London Fire Brigade and London councils all pay close attention to them.

Since 1 May 2026, the stakes are higher too. The Renters' Rights Act 2025 has raised the maximum civil penalty for HMO licensing offences to £40,000. This guide explains what London HMO landlords need to do to stay safe and compliant.

What counts as an HMO in London?

Under the Housing Act 2004, a property is generally an HMO if it is let to three or more people from two or more households who share facilities such as a kitchen, bathroom or toilet. A household is a single person, a couple, or members of the same family.

Common London examples include:

Shared houses let room by room to young professionals
Student houses
Bedsit properties with shared facilities
Converted buildings split into flats that do not meet the 1991 Building Regulations (known as section 257 HMOs)

HMO licensing in London

There are three types of licensing, and London boroughs use all of them:

Licence type	Who it covers
Mandatory HMO licensing	HMOs with 5 or more people from 2 or more households, anywhere in England
Additional HMO licensing	Smaller HMOs (often 3 or 4 people) in boroughs that have declared a local scheme
Selective licensing	Most other privately rented homes in designated areas

Most London boroughs run additional licensing, so even a small three-person shared house may need a licence. Several boroughs are consulting on new or expanded schemes in 2026, so always check your own council's website. Many councils ask for a copy of a current fire risk assessment when you apply or renew.

The law: why a fire risk assessment is required

HMO fire safety sits under two overlapping regimes. The fire service enforces one, and the council enforces the other.

Legislation	What it means for HMO landlords	Enforced by
Regulatory Reform (Fire Safety) Order 2005	The "responsible person" must carry out and regularly review a suitable and sufficient fire risk assessment of the common parts	London Fire Brigade
Fire Safety Act 2021	In buildings with two or more sets of domestic premises, the assessment must also cover the structure, external walls and flat entrance doors	London Fire Brigade
Building Safety Act 2022 (section 156, from 1 October 2023)	The whole assessment must be recorded in writing, including the assessor's name, and fire safety information must be shared with residents	London Fire Brigade
Housing Act 2004 (HHSRS)	Fire is one of 29 hazards councils assess; a Category 1 fire hazard requires action	London borough council
Management of HMOs (England) Regulations 2006	Managers must keep escape routes clear and fire alarms and firefighting equipment in good working order	London borough council
HMO licence conditions	Smoke alarms on every storey, carbon monoxide alarms where required, and annual gas and electrical safety records; many councils also require a current fire risk assessment	London borough council

The "responsible person" is usually the landlord or the person who controls the premises, such as a managing agent. You can appoint a professional to carry out the assessment, but legal responsibility stays with you. If you do use someone else, the law requires them to be competent.

What an HMO fire risk assessment covers

A fire risk assessment is a structured look at your property to find what could start a fire, who would be at risk, and whether people could get out safely. For an HMO it should follow recognised guidance, such as the government's guide for sleeping accommodation and the LACORS Housing Fire Safety Guidance that London councils use.

A good assessment will look at:

Fire hazards – sources of ignition such as cooking, electrics, heaters, smoking and charging e-bike or e-scooter batteries, plus combustible materials and rubbish storage.
People at risk – the number of occupants, anyone with limited mobility, hearing loss or other vulnerabilities, and anyone sleeping in higher-risk rooms.
Means of escape – the protected route from each bedroom to a final exit, travel distances, inner rooms and whether exits can be opened without a key.
Fire separation – fire doors, walls, ceilings and fire stopping around pipes and cables.
Detection and warning – the type and grade of fire alarm system, and its testing and servicing records.
Emergency lighting and signage – where the size and layout of the property require them.
Firefighting equipment – for example, fire blankets in shared kitchens.
Management arrangements – maintenance logs, tenant information, inspections and how quickly defects are fixed.
Action plan – clear, prioritised actions with target dates for any deficiencies found.

The assessment should be recorded in full, kept with the property records and given to the council or fire service when asked.

Typical fire safety measures in London HMOs

The right measures depend on the size, layout and use of each property, which is exactly why a fire risk assessment matters. As a general guide, London councils expect the following, based on LACORS guidance:

Fire alarms – smaller shared houses usually need mains-powered, interlinked smoke and heat alarms with battery back-up (Grade D1). Larger HMOs of three or more storeys, or bedsits, may need a panel-based system (Grade A). Coverage usually includes the escape route, every bedroom and a heat detector in the kitchen.
Fire doors – 30-minute fire doors (FD30) with self-closers to bedrooms, kitchens and the escape route, fitted correctly in their frames with intumescent strips.
Locks – bedroom and exit doors must open from the inside without a key, usually with a thumb-turn lock.
Protected escape route – a hallway and staircase kept clear of furniture, bikes, rubbish and storage, with fire-resisting walls and ceilings.
Carbon monoxide alarms – in any room with a fixed combustion appliance, such as a gas boiler.
Fire blankets – in each shared kitchen.
Emergency lighting – in larger or more complex HMOs, or where the escape route has no natural light.
Tenant information – clear instructions on what to do in a fire, how to report faults, and rules on smoking, cooking and battery charging.
Records – a fire safety logbook showing alarm tests, servicing, fire door checks and repairs.

Don't overlook lithium-ion batteries. E-bike and e-scooter fires are now among the London Fire Brigade's biggest concerns in shared housing, so your assessment and house rules should cover where they are stored and charged.

Penalties and enforcement in London

In London, the London Fire Brigade enforces the Fire Safety Order and the borough council enforces housing law. Many boroughs have formal protocols to share information and carry out joint inspections.

Breach	Possible consequence
No suitable fire risk assessment, or serious fire safety failings	Enforcement or prohibition notice from the London Fire Brigade; on conviction, an unlimited fine and up to two years in prison
Operating an HMO without a required licence	Civil penalty of up to £40,000 (since 1 May 2026) or prosecution with an unlimited fine
Breaching HMO licence conditions or management regulations	Civil penalty of up to £40,000 per offence
Unlicensed HMO	Rent repayment order of up to two years' rent
Category 1 fire hazard	Improvement notice, prohibition order or emergency remedial action by the council

The Renters' Rights Act 2025 also means superior landlords, such as freeholders and head lessees, can now face rent repayment orders for licensing breaches. Arm's-length company structures no longer give the protection they once did.

Most importantly, these rules exist because fires in shared houses can kill. A fire risk assessment that is acted on protects your tenants first and your business second.

How often should you review it?

The Fire Safety Order requires the assessment to be reviewed regularly. In practice, most London councils and fire safety professionals expect:

A review at least once a year
A review straight away after any significant change, such as building works, a new layout, a change in the number or type of tenants, or a fire or near miss
A new assessment if the existing one is no longer suitable and sufficient

Check your licence conditions, as some councils set their own review periods.

Choosing a competent fire risk assessor

The law requires anyone you appoint to be competent. Look for an assessor who:

Holds a recognised fire risk assessment qualification
Is on a professional register, such as those run by the Institution of Fire Engineers or the Institute of Fire Safety Managers
Has real experience of HMOs and the LACORS guidance
Has suitable professional indemnity insurance
Gives you a full written report with a clear, prioritised action plan

Be wary of very cheap "desktop" assessments done without a site visit. A council or the fire brigade will judge the quality of the assessment, not just whether you have one.

How Whale Fire can help

At Whale Fire, our assessments are led by front-line fire service experience. We understand how fires start, how they spread through shared houses, and what councils and fire safety officers look for.

We provide:

Full written HMO fire risk assessments, recorded in line with current law
A clear, prioritised action plan you can act on and show to your council
Practical advice on fire doors, alarms, escape routes and lithium-ion battery risks
Annual reviews to keep you compliant

Extinguish the Risk. Contact Whale Fire today to book your HMO fire risk assessment.

Frequently asked questions

Is a fire risk assessment a legal requirement for an HMO in London? Yes. The Regulatory Reform (Fire Safety) Order 2005 applies to the common parts of HMOs. The responsible person must carry out a suitable and sufficient fire risk assessment, record it in full, and review it regularly.

Do I need a fire risk assessment for a small three-person HMO? In most cases, yes. The Fire Safety Order applies to the shared areas regardless of licensing, and most London boroughs also license smaller HMOs under additional licensing schemes.

Can I do the fire risk assessment myself? The law allows it if you are competent. But HMOs are higher-risk premises, and many councils expect a professional assessment. If you get it wrong, you remain legally responsible.

How often does an HMO fire risk assessment need updating? Review it at least annually and after any significant change, such as works, a new layout or a change of tenants.

Who enforces HMO fire safety in London? The London Fire Brigade enforces the Fire Safety Order. Your borough council enforces HMO licensing, the management regulations and the Housing Health and Safety Rating System.

What is the fine for not having an HMO fire risk assessment? Failing to comply with the Fire Safety Order can lead to an unlimited fine and up to two years in prison. Licensing breaches can bring civil penalties of up to £40,000. Contact Us - Whale Fire