HMO Fire Risk Assessments: The Landlord’s Guide
Updated September 2026 · Licensing details checked on 13 council websites
Short answer: yes. If you let a house to three or more people who are not one household, the shared parts count as non-domestic premises under the Regulatory Reform (Fire Safety) Order 2005, and you need a written fire risk assessment, licensed or not. For a typical shared house it costs £150 to £300. In practice, your council’s licence conditions usually decide how far the fire precautions have to go.
HMO fire safety is where most landlords get conflicting advice. The law says one thing, the council’s licensing team asks for another, and two assessors can walk round the same house and disagree about the doors. This guide sets out what actually applies, what councils ask for, and what a sensible assessment of a shared house looks like.
We checked the HMO licensing pages of 13 councils in England and Wales, read what landlords are asking on property forums, and pulled real enforcement cases, so you can see how this plays out rather than just what the regulations say.
Which HMOs need a fire risk assessment
In Wales, the rules are the same for the fire risk assessment, but mandatory licensing only covers HMOs of three or more storeys with five or more occupiers. Councils such as Cardiff use additional schemes in particular wards to pick up smaller HMOs.
What 13 councils ask for with an HMO licence
The fire risk assessment is a legal duty on its own, but for most landlords the real trigger is the licence. Here is what we found on each council’s own licensing pages in September 2026.
| Council | Licensing for small HMOs (3–4 people) | Licence fee (5-person HMO) | Fire paperwork named by the council |
|---|---|---|---|
| Birmingham | Yes, since June 2023 | £755* | Fire alarm test certificate, emergency lighting test certificate, plan showing alarms, lighting and fire doors |
| Bristol | Yes, citywide since August 2024 | £1,861* | Not listed on the fee pages |
| Brighton & Hove | Yes, citywide since July 2024 | £871 | Fire risk assessment required in licence conditions; alarm certificate on request within 28 days |
| Cardiff | Yes, in Cathays and Plasnewydd | £410–£860 | May request an alarm servicing report, emergency lighting certificate and fire risk assessment |
| Coventry | Yes, citywide since May 2025 | £1,571 | States a fire risk assessment is a legal requirement; accepts a signed self-certification that one is in place |
| Hull | Not stated | £910 | Not listed |
| Leeds | No (5+ people only) | £975 | Conditions refer to fire safety regulations |
| Leicester | Not stated | £900 | Working smoke alarms and clear escape routes listed as duties |
| Manchester | Not stated | £1,321 | Not listed on the fee page |
| Newham (London) | Yes, borough-wide since 2023 | £1,400 | Not listed on the fee page |
| Nottingham | Yes, citywide since January 2024 | £1,607 | Not listed on the scheme page |
| Oxford | Yes, citywide (new scheme June 2026) | £858 | Fire risk assessment and emergency lighting certificate (if fitted) with the application |
| Sheffield | No scheme found | £1,185 | Gas and electrical certificates; notes some HMOs must comply with the Fire Safety Order |
Checked on each council’s website, September 2026. Fees are for a new application and usually change every April. *Birmingham figure is the additional (small HMO) licence; Bristol figure is the additional licence. Cardiff: £410 if the property is compliant, £860 if not. Discounts for accredited landlords are available in most areas. Always check your own council’s current page before applying.
What the check told us
- The assessment is the cheap part of being licensed. Licence fees for a five-person HMO ran from £410 to £1,861. A fire risk assessment for the same house is typically £150 to £300, a fraction of the licence fee in most of the cities we checked.
- Small HMOs are no longer a grey area in many cities. Eight of the 13 councils license some or all three- and four-person HMOs. If you let a three-bed house to three sharers in Bristol, Coventry, Oxford or Nottingham, for example, it needs a licence.
- Councils are asking for fire paperwork up front. Birmingham, Oxford, Coventry, Cardiff and Brighton all name fire documents in their applications or conditions. Turning up without a current assessment is an easy way to slow your licence down.
What an HMO fire risk assessment usually finds
The same handful of issues account for most action points in shared houses. None of them are exotic, and most are cheaper to fix than landlords fear.
- Fire doors that aren’t quite fire doors. A door can be FD30-rated and still fail because it has no intumescent seals, only two hinges, a big gap at the frame, or a closer that doesn’t latch it shut. Many of these are repairs, not replacements.
- A kitchen on the escape route. The kitchen is where most fires start. If tenants have to pass the kitchen door to get from their rooms to the front door, that door and the detection around it matter more than anything else in the house.
- Detection that doesn’t talk to itself. Separate battery alarms in each room don’t warn anyone upstairs about a fire in the kitchen. Shared houses generally need mains-powered, interlinked detection, with heat detection in the kitchen.
- Locks that need a key to get out. Bedroom and front doors should open from the inside without a key. A thumb-turn is the usual answer.
- Storage on the escape route. Bikes in the hall, a tumble dryer in the under-stairs cupboard, an unprotected electrical intake. These are free or cheap to fix and come up constantly.
- A loft conversion that changed the rules. Adding a third storey usually means the stair needs better protection, and it can tip a property into mandatory licensing.
Questions HMO landlords keep asking
These are real posts from landlord forums, linked so you can read the full threads.
“My house is a 4-bedroom house, and I do not need a compulsory HMO license. However, I need an HMO Compliance Assessment.”
Landlord of a four-bed shared house, OpenRent Community, October 2024
Not needing a licence doesn’t take you out of the Fire Safety Order. An unlicensed shared house still needs a fire risk assessment of the common parts, and the council can still act on fire hazards under the Housing Act. The replies in the thread gave the right advice: use a competent assessor and keep a protected route out that doesn’t go through the kitchen.
“Are self-closing mechanisms actually compulsory on bedroom doors (tenants hate them)?”
Landlord managing several HMOs, Safelincs Fire Safety Forum, January 2023
It depends on the house. National guidance for existing housing is risk-based, so a small two-storey shared house may not need closers on every bedroom door, while a larger or three-storey HMO usually will. What doesn’t work is a closer tenants wedge open. If yours keep getting propped, ask the assessor about hold-open closers linked to the alarm, and avoid cheap concealed chain closers, which often don’t pull a fire door fully shut.
“The report indicates the doors are not compliant as they have no seals and only two hinges instead of the required three.”
HMO landlord asking whether to repair or replace, Property118, September 2022
Seals and a third hinge can often be added to a sound door for far less than a new doorset. Ask the assessor to say which doors can be upgraded and which need replacing, and get the work priced by someone who didn’t write the report.
“I engaged another professional who charged me £150 and gave me a clean report with no issues.”
Landlord of a house split into two flats, Property118, July 2026
The first assessor had charged £295, classed the building as an HMO and recommended a water mist system for one bedroom. Getting the classification right comes first, because it changes everything that follows. A converted house can be a section 257 HMO, or it can be two ordinary flats. If a report doesn’t explain how it decided, ask.
How much an HMO fire risk assessment costs
From our survey of 20 published UK price lists, the median price for an HMO or shared house was £205 including VAT. Typical ranges:
Pricing is banded by rooms and storeys, not per bedroom. The full breakdown, and the costs that usually follow an assessment, are in our fire risk assessment cost guide.
Which laws apply to an HMO, in plain English
- Regulatory Reform (Fire Safety) Order 2005. The common parts of an HMO are covered. The responsible person, usually the landlord or managing agent, must have a suitable and sufficient fire risk assessment and, since October 2023, must record it in full in writing.
- Housing Act 2004 (HHSRS). Fire is one of the 29 hazards councils assess. They can act on fire hazards in any HMO, licensed or not.
- Management of HMOs (England) Regulations 2006. The manager must keep escape routes clear and in good repair, keep fire alarms and firefighting equipment working, and display fire escape notices (except in HMOs with four or fewer occupiers).
- Smoke and Carbon Monoxide Alarm Regulations 2022. At least one smoke alarm on every storey with living accommodation, and a CO alarm in any room with a fixed combustion appliance (not gas cookers). Licensed HMOs get the same requirements through their licence conditions.
- Fire Safety (England) Regulations 2022. Where a building has two or more sets of domestic premises, residents must be given fire safety instructions and information about fire doors. This is likely to apply to converted-flat HMOs. For a single shared house, check with your fire and rescue service.
- The LACORS housing fire safety guide (2008). Not law, but the national benchmark councils and assessors use for HMOs. It is risk-based, not a checklist, which is why a small two-storey house and a large three-storey bedsit HMO can end up with very different recommendations.
What councils and fire services have done
HMO enforcement comes from two directions: the fire service under the Fire Safety Order, and the council under the Housing Act. From 1 May 2026, the maximum civil penalty a council can issue for offences such as running an unlicensed HMO rose from £30,000 to £40,000 under the Renters’ Rights Act 2025.
The Brighton case is worth reading twice. The fine was modest, but the costs were almost double it. The failures were ordinary ones that a current assessment and a monthly walk-round would have caught.
Five ways to get more from your HMO assessment
- Book it before the licence, not after. If you’re applying or renewing, have a current assessment ready to send. Several councils ask for it, and it answers most of the fire questions the inspection will raise.
- Beat the summer rush in university towns. Student HMO renewals, licence applications and new lets all pile up between July and September. Booking in spring gets you a choice of dates and time to do any work before tenants move in.
- Tenants don’t need to be in. A standard Type 1 assessment covers the common parts. If a room is locked, a good assessor records it as not inspected rather than guessing.
- Ask which guidance was used. Every recommendation should be traceable to the LACORS guide, the council’s standards or a specific risk in your house. If it isn’t, ask why.
- Review it every year. HMOs have sleeping risk and tenants change often. An annual review, and one after any building work or change of use, keeps the assessment current. Reviews usually cost less than the first assessment.
What a typical HMO assessment looks like
Example
The property: a three-storey Victorian terrace let as a five-bedroom shared house to professionals, with the kitchen in the rear extension.
The visit: about an hour and a half. The assessor walks every floor, checks the alarm panel and the fire log, and looks at each bedroom door from the landing.
What usually comes up: two bedroom doors with their self-closers taken off by tenants, no heat detector in the kitchen, and no record of the monthly emergency lighting tests. All three are quick, low-cost fixes, and the dated action plan says which to do first.
Cost: around £150 to £300, with the report a few working days after the visit.
An illustrative example based on the guidance and prices on this page. Not a real customer or property.
HMO fire risk assessments: quick answers
Does a small HMO need a fire risk assessment?
Yes. Any house let to three or more people forming two or more households is an HMO, and its common parts fall under the Fire Safety Order, whether or not it needs a licence.
How much does an HMO fire risk assessment cost?
Typically £150 to £300 for a shared house of up to six rooms, and £250 to £450 for larger HMOs. The median published HMO price in our September 2026 survey was £205 including VAT.
How often should an HMO fire risk assessment be reviewed?
There is no fixed legal interval, but because HMOs have sleeping risk and changing tenants, most landlords review annually, and always after building work, a change in layout or a change in how the house is let.
Can I do my own HMO fire risk assessment?
The law allows it if you are competent. In practice, most HMO landlords use a professional, because councils, insurers and tribunals give far more weight to an independent assessment if something goes wrong.
Do bedroom doors in an HMO need to be fire doors?
Often, but not always. In larger and three-storey HMOs, 30-minute fire doors to bedrooms and the kitchen are standard. In a small two-storey shared house, sound, well-fitting solid doors may be acceptable. The assessment should explain which applies to your house.
Do I need a fire risk assessment for my HMO licence application?
Some councils ask for one with the application, including Oxford, and others such as Coventry and Brighton make it a licence condition. Even where it isn’t requested, having a current assessment ready makes the inspection much smoother.
Is a converted house of flats an HMO?
It can be. A building converted into flats that doesn’t meet 1991 Building Regulations, where less than two thirds of the flats are owner-occupied, is a section 257 HMO. Your council can confirm how it classes your building.
Get a Price for Your HMO
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