HMO landlords, licence holders and property agents

HMO fire risk assessment London and Surrey

Understand why an HMO fire risk assessment may be requested, check licensing and responsibility, estimate likely cost and request a properly scoped quote across London and Surrey.

Reviewed: 8 September 2026Guidance: EnglandEnquiries: London and Surrey HMOs

Concise, sourced answer

Does an HMO need a fire risk assessment?

Fire-safety duties for an HMO can arise under more than one regime. The Fire Safety Order applies to areas and building elements within its scope, while housing legislation, HMO management regulations and licence conditions can impose separate or overlapping requirements.

Fire Safety Order 2005Fire Safety Act 2021HMO Management Regulations 2006

Do not rely on bedroom count or an agent’s request alone to define the report. Confirm the property’s occupation, conversion, common parts, person in control, current licensing scheme and the exact evidence requested by the council or agent.

GOV.UK: HMO licence checkerGOV.UK: duty-holder guidance

Original scope map

The three checks an HMO owner should keep separate

The checks overlap, but one does not automatically satisfy the others. Apply all three to the exact address and occupation.

  1. 01
    Fire-safety law

    Identify the Fire Safety Order scope, responsible person and significant findings.

  2. 02
    Housing duties

    Check HMO management, housing-condition and landlord requirements.

  3. 03
    Local licensing

    Confirm mandatory, additional or selective licensing and current conditions.

  4. 04
    One property brief

    Bring the occupancy, layout, control, records and requested evidence together.

Fire Safety Services HMO scope map. The local authority and a competent assessor should resolve property-specific uncertainty.

This is a fictional, practical scenario—not a client case study or a building-specific compliance decision.

Key points

HMO or shared rental property fire risk assessment at a glance

  • When and why HMO landlords are asked for an FRA
  • Mandatory, additional and selective licensing checks
  • Fire doors, alarms and protected escape routes
  • Tailored quotes for landlords, agents and property portfolios
  • The responsible person must arrange a suitable and sufficient assessment and record its findings in full.
  • Review the relevant assessment and evidence when changes, an incident or new information could affect its validity.

HMO layout guide

Sleeping rooms depend on a protected route to safety

An HMO assessment connects bedroom doors, detection, shared kitchens, landings and the final exit. A weakness at one point can affect every resident using the route.

Simplified HMO floor plan showing bedrooms, fire doors, smoke and heat alarms, a shared kitchen, protected stairs, common escape route and final exit
Original Fire Safety Services diagramDownload branded SVG
01

Bedrooms and sleeping risk

Bedroom doors, warning, occupancy and any inner-room or travel arrangement need premises-specific consideration.

02

Protected route

The stair, landings and route to the final exit should remain suitably enclosed, clear and immediately usable.

03

Detection and warning

Coverage, grade, category, interconnection, audibility, testing and management must suit the property.

04

Higher-risk rooms

Shared kitchens, electrical equipment, charging, meters and storage can threaten the only escape route.

05

Management boundaries

Record what the landlord, licence holder, agent and occupants must inspect, report, maintain or avoid.

Scope note: The illustration does not prescribe an alarm category, door rating or construction solution. Those decisions depend on the building, occupation, housing guidance, licensing requirements and competent assessment.

Illustrative worked examples

See how common HMO instructions could be approached

These are fictional educational scenarios—not client case studies. They demonstrate a possible assessment journey without predicting the findings for your premises.

Browse all fire risk assessment worked examples

Property-specific guidance

Why this premises type needs its own assessment

HMOs combine sleeping accommodation with shared kitchens, escape routes and responsibilities. Occupants may live independently, change frequently and be unfamiliar with each other’s habits, so detection, protected routes, doors and management need to work even when a fire starts at night.

A letting or estate agent may ask for an FRA while onboarding a property, checking landlord documents, preparing a licence application or renewal, responding to a council request, arranging a transaction or reviewing a managed portfolio. That request is a prompt to establish the correct legal and assessment scope—not evidence that a generic certificate will be enough.

In England, mandatory HMO licensing generally applies where five or more people forming two or more households share facilities, although councils can operate additional HMO or selective licensing schemes. Fire-safety requirements must reflect the actual property, occupancy, conversion history, local scheme and licence conditions—not simply bedroom count.

Why HMO owners enquire

“My estate agent says I need a fire risk assessment”

An agent’s request often follows a compliance, licensing or transaction event. Find out what prompted it, then give the assessor that context so the report addresses the actual property and deadline.

Request an HMO FRA quote
01

Agent or manager request

A letting or managing agent is onboarding the property, reviewing compliance documents or taking over management.

02

Licence application or renewal

The council requires information, an existing assessment is unavailable or licence conditions need to be reconciled.

03

New HMO or change in occupation

The number of occupiers, households, bedrooms or shared facilities has changed.

04

Purchase, refinance or handover

A buyer, lender, insurer, freeholder or professional adviser needs current fire-safety evidence.

05

Council inspection or concern

The landlord needs to address a request, defect, complaint or enforcement-related issue.

06

Existing FRA review

The property, residents, fire precautions or management arrangements may no longer match the report.

London incident context

221 recorded fires in other residential premises

London Fire Brigade recorded this total across London in calendar year 2025. It is a broad incident category, not a count for this exact premises type and not a measure of whether an individual building is safe.

Property licensing

Does the HMO need a licence?

Licensing rules depend on the occupiers and the council’s current scheme. A licence and an FRA are different: holding or applying for a licence does not replace the premises-specific assessment.

01

Mandatory HMO licensing

Generally applies in England where five or more people forming more than one household share facilities. It is no longer restricted to three-storey properties.

02

Additional HMO licensing

A council can designate a scheme covering smaller HMOs, commonly properties occupied by three or four people from more than one household.

03

Selective licensing

A council can require licences for privately rented properties in a designated area, including properties that are not HMOs.

Legal responsibility

Who must arrange the assessment?

The landlord, licence holder, person managing or person having control may hold relevant housing duties. Under the Fire Safety Order, responsibility follows the statutory test and degree of control, so an agent with substantive management control may also have duties. Appointments and responsibilities should be recorded where ownership and daily management are separated.

Read the main fire risk assessment guide

Ownership and management

Landlord, licence-holder and agent responsibilities

Appointing an agent or assessor does not automatically transfer every duty. Record the owner, licence holder, statutory manager, person having control and anyone controlling relevant fire-safety arrangements.

Potential dutyholderTypical matters to establish
Landlord or ownerOwnership decisions, investment, instructed work and areas or arrangements retained under the landlord’s control.
Licence holderCompliance with the licence and conditions, suitability, management arrangements and information supplied to the council.
Person managing or having controlHousing Act and HMO-management duties can attach to the statutory manager or person having control.
Letting or managing agentDuties and practical tasks depend on the appointment and actual control; an agent may arrange the FRA, access, inspections and remedial work.
Fire risk assessorProvides competent assistance within the agreed scope, but does not take over the dutyholder’s responsibility to act and review.
For managing and letting agents

Confirm in writing who commissions assessments, arranges access, receives defect reports, authorises urgent work, retains records and checks that actions have been completed. The management agreement should match what happens in practice.

Legal framework

Fire-safety duties affecting this property

The Fire Safety Order is the core life-safety regime in England. Other laws and sector requirements can overlap, so the assessment and action plan should not be managed in isolation.

Fire Safety Order 2005

Requires assessment and appropriate precautions for areas within scope, with findings recorded in full.

Housing Act 2004

Provides the HMO licensing and Housing Health and Safety Rating System framework used by local housing authorities.

HMO management regulations

Require managers to maintain escape routes and fire precautions and keep common parts safe and unobstructed.

Local licence conditions and guidance

Councils may impose conditions and use LACORS or other risk-based housing guidance; local requirements should be checked directly.

Assessment scope

What the assessor should examine

The final scope should reflect the actual building and any limitations. A site visit and a prioritised written report are fundamental for a professional assessment.

01

Occupancy and layout

Record households, residents, bedrooms, storeys, shared facilities, inner rooms, basements and escape arrangements.

02

Detection and warning

Check alarm grade, category, coverage, interconnection, audibility, testing and compatibility with any common system.

03

Protected route

Assess enclosure, fire doors, locks, glazing, linings, storage and whether the route remains usable from every bedroom.

04

Cooking and electrical risk

Review shared kitchens, appliances, charging, meters, landlord installations and tenant-supplied equipment.

05

Emergency lighting and signs

Determine what is necessary for the size, layout, familiarity of residents and relevant housing guidance.

06

Management and records

Examine inspections, testing, waste, smoking, tenancy information, repairs, access and licence conditions.

Property-specific hazards

Risks that deserve particular attention

These examples are prompts, not a complete checklist. The assessment must identify all significant hazards and how they could affect people in and around the premises.

Shared cooking

Multiple users, unattended cooking and varying housekeeping standards increase ignition risk.

Charging and electrical equipment

Portable heaters, extensions, white goods, e-bikes and batteries can add significant risk.

Compromised escape routes

Storage, locks, poorly fitting doors and unprotected construction can affect the only route out.

Frequent occupancy changes

New residents may not understand alarms, exits, house rules or how to report defects.

People at risk

Who may need additional consideration?

The assessment must consider everyone lawfully on or near the premises, including people who may be unable to recognise danger, respond quickly or use the standard escape route without help.

Sleeping residents

Detection and protected escape require particular attention because fire may develop before occupants wake.

Residents with additional needs

Mobility, sensory, cognitive, language or health needs should be considered without recording unnecessary personal data.

Visitors and children

The maximum credible occupancy may be higher than the tenancy list suggests.

People in adjoining premises

Converted and mixed-use buildings may expose neighbours or commercial occupiers to shared risks.

Emergency planning

Evacuation points to test

A written plan is only useful if it matches the building, occupants, available staff and fire precautions and can be carried out under foreseeable conditions.

  • Confirm that bedroom and common alarm arrangements provide warning appropriate to the property.
  • Every resident should be able to open exit doors without a key or complicated operation from inside.
  • House rules and instructions should explain alarm testing, escape, calling 999 and reporting damaged precautions.
  • Where commercial premises or separate flats share the building, responsible persons must coordinate alarm and evacuation arrangements.

What to expect

The five-stage assessment process

  1. 1

    Prepare

    Confirm the areas in scope, responsible persons, occupancy, plans, previous reports and relevant fire-safety records.

  2. 2

    Inspect

    Walk the premises and examine hazards, people at risk, escape, fire protection and management arrangements.

  3. 3

    Evaluate

    Judge whether precautions are suitable for the actual use, occupants, construction and emergency strategy.

  4. 4

    Record and prioritise

    Document findings in full and provide a clear, risk-prioritised action plan with responsible owners.

  5. 5

    Review

    Keep the assessment current and revisit it when change, an incident or new information may affect its validity.

Evidence and management

Records to prepare and retain

Good records help an assessor understand the premises, allow defects to be tracked and demonstrate that significant findings have been acted on.

  • Current FRA, reviews and action plan
  • HMO licence, application or renewal information and conditions
  • Floor plans, bedroom and household schedule
  • Alarm, emergency-lighting and extinguisher records
  • Fire-door and common-area inspection records
  • Electrical and gas safety information relevant to fire risk
  • Resident information, inspections and defect reports
  • Agent appointment and responsibility records where management is delegated

Keeping it current

When to review the assessment

There is no single fixed review interval suitable for every premises. Set a proportionate programme and review sooner whenever there is reason to think the assessment may no longer be valid.

  • Change in occupancy, household numbers or resident needs
  • Licence renewal, new conditions or housing-authority action
  • Conversion, refurbishment or changes to bedroom or kitchen layout
  • New battery charging, cooking or other significant hazards
  • Fire, alarm activation, near miss or repeated false alarms
  • Significant defects or evidence the assessment is no longer valid

Quote planning

What affects assessment cost?

A useful quote reflects assessor time, competence, site access and reporting complexity. A low headline price is not meaningful without a clear scope.

01

Bedrooms and storeys

Number of rooms, floors, stairs and shared facilities.

02

Conversion and layout

Age, inner rooms, basements, mixed uses and protected-route complexity.

03

Licensing context

Local conditions, documents and actions that need reconciliation.

04

Records and access

Resident access, alarm details, plans and previous reports.

Compare like with like

What an HMO FRA quotation should state

A cheap quote may assume limited room access, a shorter visit or a generic report. Give each provider the same HMO and licensing information and compare the assessment scope before price.

  • Exact property, storeys, bedrooms, shared facilities and ancillary areas included
  • Current occupancy, household arrangement and maximum credible number of people
  • Access expected to bedrooms, doors, basements, lofts and service areas
  • HMO type, current licence status, council scheme and any fixed deadline
  • Alarm, emergency-lighting, fire-door and protected-route scope
  • Written premises-specific report with photographs where useful and prioritised actions
  • Limitations, sampling, inaccessible areas and any specialist surveys excluded
  • Site attendance, report date, VAT, travel and post-report clarification

Choosing an assessor

Check the person as well as the company

BAFE SP205 provides third-party certification for organisations delivering life-safety fire risk assessments. The National Fire Risk Assessors Register (NFRAR), administered by the Institute of Fire Safety Managers, records individually assessed fire risk assessors and their competency level.

Use both as complementary evidence: verify the organisation’s current BAFE SP205 status where applicable and the individual’s current NFRAR registration and assessed level. Also check direct experience with HMO or shared rental property premises, insurance, report scope, site visit, exclusions and how follow-up questions are handled.

Estate, letting and property professionals

Arrange one HMO assessment or a portfolio programme

Agents can use the enquiry form for a landlord’s property, a new management instruction or several HMOs. A consistent brief can simplify procurement, but every property still needs its own scope, inspection, findings and action plan.

Prepare before requesting quotes

  • Property address, council, owner and licence-holder details
  • Number of storeys, bedrooms, occupiers and separate households
  • Tenancy or room schedule and shared-facility arrangement
  • Current licence, application, renewal date and relevant conditions
  • Existing FRA, action plan, plans and previous council correspondence
  • Alarm, emergency-lighting, fire-door and servicing records
  • Access contact for occupied rooms and any fixed transaction deadline

Related fire-safety services

Acting on the assessment

The FRA should define outcomes and priorities. Any design, installation, inspection or maintenance work must then be scoped and completed competently.

Fire doors and protected routes

Plan a competent fire door inspection

Sleeping risk, vulnerable occupants, repeated use and flat-access arrangements can make door condition and records especially important in this premises type.

Check fire-door requirementsUse the inspection checklistRead the inspection guideEstimate inspection cost

London and Surrey HMOs

Check the council scheme before instructing the FRA

Mandatory licensing rules are national, but additional and selective schemes, application evidence and licence conditions vary by council. Confirm the property address, scheme and deadline rather than relying on a previous tenancy or a nearby property.

Selective licensing

Does the licence require an FRA?

Understand why an agent or council may ask for fire-safety evidence and how to verify the property-specific requirement.

Read the selective licensing guide
London research

Compare all 33 boroughs

Review active, area-specific and upcoming additional HMO and selective licensing schemes, dates and direct council sources.

Open the London licensing table
London address

Property licence checker

Use the London-wide checker, then verify the result and current requirements with the relevant borough.

Check a London address
England

Find the local council

Enter the HMO postcode on GOV.UK to reach the council’s licensing service, including for Surrey properties.

Find the council by postcode

Local coverage

Find and compare assessment support across London and Surrey

Explore local assessor information and quotation guidance, or use the form below to request a property-specific quote.

For county-wide duties, cost factors and local context, read the Surrey HMO or shared rental property fire risk assessment guidance.

01Find a London assessor02Find a Surrey assessor

Frequently asked questions

HMO fire risk assessment London and Surrey FAQs

Does every HMO need a fire risk assessment?

Relevant areas of HMOs can fall within the Fire Safety Order, while housing and licensing duties require fire risk to be properly managed. Councils commonly expect a suitable assessment for licensed HMOs. The precise scope depends on the property, occupation and local licensing requirements.

When does mandatory HMO licensing apply?

In England it generally applies where five or more people forming two or more households share facilities. Local councils can extend licensing to other HMOs or rented properties, so the council’s current scheme must be checked.

Why has my estate or letting agent asked for an FRA?

Agents often request an FRA during compliance onboarding, a new management instruction, licence application or renewal, property transaction, insurer or lender check, or because the existing report is missing or may be out of date. Ask what prompted the request and provide that context to the assessor.

Can an estate or letting agent arrange the HMO FRA?

Yes. An agent can arrange access and commission an assessment for the landlord or licence holder. Its own legal position depends on its appointment and control, and commissioning an assessor does not remove the responsible dutyholder’s obligation to make sure the assessment is suitable and acted upon.

Does a three- or four-person HMO need a licence?

It may. Mandatory licensing generally starts at five occupiers from more than one household, but a council can operate an additional HMO licensing scheme covering smaller HMOs. Always check the current scheme for the property address.

Is an HMO licence the same as a fire risk assessment?

No. A licence is the council’s permission to operate the property subject to conditions. The FRA is the premises-specific evaluation of fire risk and precautions. A licence, application or inspection does not replace the assessment.

Is a domestic smoke alarm enough for an HMO?

Not automatically. Alarm grade, category and coverage depend on the property, storeys, layout, occupancy, conversion and local housing guidance. Larger or higher-risk HMOs may require a Grade A system or other enhanced provision.

Does an HMO FRA inspect every bedroom?

The agreed scope and access should reflect the property and relevant legal boundaries. Bedroom doors, detection, inner-room arrangements, escape and resident-created risks may require access or reliable evidence. The quotation should state what will be inspected and any sampling or access limitations.

How often should an HMO FRA be reviewed?

There is no universal fixed legal interval. It must be kept current and reviewed regularly, particularly after occupancy, layout, licensing, alarm or risk changes and after any incident or near miss.

How much does an HMO fire risk assessment cost?

A small, relatively straightforward HMO may commonly fall around £350–£750 in London or Surrey. Bedrooms, storeys, conversion, occupancy, licensing context, access, fire doors, alarm arrangements and available records can move the price outside this indicative range.

Will I receive an HMO fire-safety certificate?

A competent FRA should provide a written assessment and prioritised action plan, not a generic pass certificate. The responsible person must consider and act on the findings, retain evidence and keep the assessment current.

Who enforces HMO fire safety?

Local housing authorities enforce Housing Act and licensing duties, while fire and rescue authorities enforce the Fire Safety Order. The two regimes overlap and authorities may coordinate.

HMO assessment enquiry

Request an HMO fire risk assessment quote

Send the essential contact and property details. We can ask about licensing, occupancy, access and fire-safety arrangements when we call.

  • No obligation to book
  • Telephone number required
  • Detailed HMO and licensing information can be discussed by telephone

Submitting this form does not confirm an appointment, compliance outcome or fixed price.

Sources and limitations

Guidance reviewed 8 September 2026

This page provides general information for England. It is not legal advice, a building-specific assessment or a guarantee of compliance. Fire Safety Services is independent and is not affiliated with BAFE, NFRAR, IFSM, the Government or fire and rescue services.