Do I Need an HMO Fire Risk Assessment?

Yes. If you run a House in Multiple Occupation, an HMO fire risk assessment is a legal requirement, not an optional extra, and since October 2023 it has to be written down in full. Whether your HMO is in Maidstone or a village in rural Kent, the duty is the same, and councils routinely ask to see the assessment when they inspect or process a licence.

Why it is required

The Regulatory Reform (Fire Safety) Order 2005 requires the responsible person to carry out a suitable and sufficient fire risk assessment of the premises and act on the findings. The recording duty was tightened by Section 156 of the Building Safety Act 2022. For HMOs, a written assessment is also commonly a condition of the licence, so there are usually two reasons you need one.

What it has to cover

An HMO assessment works through the recognised five steps: identify the fire hazards, identify who is at risk, evaluate and reduce the risk, record and plan, and review. In an HMO that means looking hard at the shared escape route, the detection system, the fire doors, ignition sources in the shared kitchen, and how tenants who may be asleep would get out. The LACORS guidance is the benchmark most assessors and councils use.

Can I do it myself

For a small, simple HMO the guidance accepts that a landlord can carry out their own assessment, and the government publishes a free five-step method. That route is genuinely open to you. The honest qualifier is that an HMO carries more technical judgement than a single let: deciding the right alarm category, whether a door needs to be FD30S, whether a travel distance is acceptable, or whether an inner room is a problem.

Where a professional earns their fee

A competent assessor brings current knowledge of LACORS and BS 5839-6, an objective eye, and a defensible record if the council or fire service challenges you. The same guidance that lets you self-assess also says that if you are not confident interpreting and applying it, you should use a competent person, and that you stay legally responsible whoever does the work. For anything beyond a straightforward two-storey share, that scrutiny is usually money well spent, and our guide to assessment cost sets out what drives the price.

Keeping it current

An assessment is not a one-off. Review it regularly and straight away after any change: a new tenant profile, a refurbishment, new furniture, or a near miss. Date each review and note what you checked. Kent Fire and Rescue Service provides business fire safety advice, and your council licensing team can confirm the local expectations.

What the council asks to see

When a council processes an HMO licence or carries out an inspection, the fire safety paperwork is usually the first thing requested. Expect to produce the recorded fire risk assessment, alarm installation and servicing records, the gas safety record and the EICR. Our HMO fire safety checklist sets out the full list so nothing is missing on the day.

An assessment that exists but was never acted on is little better than none, because the duty is to act on the findings, not simply to hold a document. Keep a note of what you fixed and when, so the assessment and the works tell a single, consistent story. Kent Fire and Rescue Service offers business fire safety advice, and engaging early tends to head off the enforcement route entirely.

Get your assessment right

Want certainty that your assessment is suitable and sufficient for an HMO? For advice tailored to your property from a competent professional, speak to Jamie at ESI: Fire Safety on 01276 300 351.

Picture of Jamie Morgan MIFSM MIET

Jamie Morgan MIFSM MIET

Jamie Morgan is an electrical and fire safety specialist with more than 25 years’ experience designing, inspecting, and validating electrical and life-safety systems across the UK.

He is a Member of the Institute of Fire Safety Managers (MIFSM) and the Institute of Engineering & Technology (MIET), reflecting his commitment to professionalism and continuous development. Through ESI: and his consultancy work, Jamie is dedicated to raising industry standards and helping organisations stay compliant and safe.

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