Yes. If you run a house in multiple occupation, you need a fire risk assessment — and for most landlords the question arrives attached to a licence application or renewal, which is exactly when it matters.
Let me set out why, what it covers, and what happens if you don't have one.
The legal basis
The common parts of an HMO — the shared hallways, stairs, landings and escape routes — fall under the Regulatory Reform (Fire Safety) Order 2005. Article 9 requires the Responsible Person (usually you, as landlord or managing agent) to make a "suitable and sufficient" assessment of the fire risks people are exposed to, and to keep it under review.
HMOs are a particular case because they sit under two regimes at once: the Fire Safety Order for the common parts, and the Housing Health and Safety Rating System for the individual living accommodation. That overlap catches a lot of landlords out. For now, the short version: a fire risk assessment is how you discharge the Fire Safety Order duty.
What HMO licensing usually requires
For most landlords the practical trigger isn't the legislation in the abstract — it's the council. Under the Housing Act 2004, HMOs above a certain size need a mandatory licence, and many councils operate additional or selective licensing schemes on top of that. In nearly every case, an in-date fire risk assessment (or equivalent fire safety evidence) is a condition of the licence.
That means the assessment isn't optional paperwork. It's part of what the council checks before it grants or renews your licence — and part of what it can act on if a complaint or inspection turns up a problem.
What actually gets assessed
An HMO fire risk assessment is specific to the building in front of me, not a template. In practice I'm looking at:
- Means of escape — can everyone get out, from every let, by a protected route?
- Fire doors — are they the right rating, properly fitted, and actually closing?
- Detection and alarm coverage — is the system right for the layout, and does it reach every room it needs to?
- Compartmentation between lets — do the walls and floors between units genuinely hold fire back, or has that been undone by past alterations?
The report you get back is a prioritised list of what, if anything, needs doing — not a generic checklist.
What happens if you don't have one
The realistic risk for most HMO landlords isn't a dramatic fire-service enforcement action. It's simpler and more common: a licence refused, delayed, or granted with conditions you then have to scramble to meet. An out-of-date or missing assessment is one of the easiest things for a council to pull you up on, and the responsibility stays with you either way.
Getting the assessment done ahead of your renewal, rather than in the week before, is the difference between a smooth licence and a stressful one.
Booking one
I carry out HMO fire risk assessments personally, on a fixed fee agreed in writing — no day rates, no per-issue add-ons, no scope creep. If you've got a licence application or renewal coming up, it's worth timing the assessment to that.