Agent or manager request
A letting or managing agent is onboarding the property, reviewing compliance documents or taking over management.
Large-HMO landlords, licence holders and managing agents
Fire risk assessment for large HMOs
Coordinate mandatory licensing, sleeping risk, protected escape, alarm systems, fire doors and management evidence for HMOs occupied by five or more people.
Key points
Large HMO fire risk assessment at a glance
- Large HMOs normally require mandatory licensing
- The storey test was removed from the national licensing threshold
- Sleeping risk and shared facilities require premises-specific assessment
- Licensing evidence does not replace the Fire Safety Order assessment
- London and Surrey assessment enquiries
- 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.
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.
Property-specific guidance
Why this premises type needs its own assessment
GOV.UK defines a large HMO for the usual mandatory licensing route as a property rented to at least five people forming more than one household, where some or all share toilet, bathroom or kitchen facilities and at least one pays rent. The former three-storey restriction no longer applies.
Five occupants is a licensing threshold, not a complete measure of fire risk. A five-bedroom shared house, a converted property with bedsits and a large mixed-use HMO can require very different alarm, fire-door, compartmentation, emergency-lighting and management arrangements.
The assessor should reconcile the Fire Safety Order, housing law, the current licence and council standards without presenting any one document as the entire answer. Access, occupancy, household information, conversion history and the protected escape route need to be established clearly.
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 quoteLicence application or renewal
The council requires information, an existing assessment is unavailable or licence conditions need to be reconciled.
New HMO or change in occupation
The number of occupiers, households, bedrooms or shared facilities has changed.
Purchase, refinance or handover
A buyer, lender, insurer, freeholder or professional adviser needs current fire-safety evidence.
Council inspection or concern
The landlord needs to address a request, defect, complaint or enforcement-related issue.
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.
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.
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.
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 can hold relevant housing duties, while responsibility under the Fire Safety Order follows its statutory tests and actual control. An agent may arrange assessment, access and remedial work, but appointments should state who receives defects, authorises action and keeps the FRA current.
Read the main fire risk assessment guideOwnership 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 dutyholder | Typical matters to establish |
|---|---|
| Landlord or owner | Ownership decisions, investment, instructed work and areas or arrangements retained under the landlord’s control. |
| Licence holder | Compliance with the licence and conditions, suitability, management arrangements and information supplied to the council. |
| Person managing or having control | Housing Act and HMO-management duties can attach to the statutory manager or person having control. |
| Letting or managing agent | Duties and practical tasks depend on the appointment and actual control; an agent may arrange the FRA, access, inspections and remedial work. |
| Fire risk assessor | Provides 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 suitable assessment, full recording and appropriate general fire precautions for areas and duties within scope.
Housing Act 2004
Creates mandatory, additional and selective licensing and the housing-condition enforcement framework.
Mandatory HMO licensing
Usually applies where five or more people from more than one household share facilities, regardless of storey count.
HMO management regulations
Require effective management of escape routes, precautions, common parts, information and maintenance.
Local licence conditions
The council may require property-specific evidence and conditions within its lawful scheme.
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.
Occupation and licensing
Confirm residents, households, bedrooms, facilities, licence status, conditions and any council deadline.
Alarm system
Determine grade, category, coverage, audibility, interconnection, controls, testing and fault arrangements for the property.
Protected escape route
Examine enclosure, fire doors, locks, glazing, stairs, basements, inner rooms, storage and final exits.
Compartmentation and conversion
Consider walls, floors, ceilings, lofts, service penetrations and evidence of alterations or historic conversion.
Emergency lighting and signs
Assess what is needed for the actual size, layout, familiarity and common-route arrangement.
Management evidence
Review inspections, resident information, waste, smoking, repairs, access, tenancy changes and action closure.
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
Several residents and cooking locations increase ignition opportunities and management variability.
Compromised protected route
Door defects, storage, locks, penetrations or unsuitable linings can expose the only stair.
Conversion defects
Legacy work and repeated alterations can weaken fire separation or create unrecognised inner-room risks.
High occupancy and turnover
Residents may not know one another’s needs or understand alarms, instructions and reporting arrangements.
Battery charging
E-bikes, scooters, power banks and personal devices can introduce significant hazards in rooms or escape routes.
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
The assessment must provide sufficiently early warning and a route protected for the expected escape time.
Residents needing assistance
Mobility, sensory, cognitive, language or health needs can affect warning and evacuation.
Visitors and children
The maximum credible occupancy may exceed the licence-holder’s normal resident schedule.
People in adjoining premises
Flats, commercial units and neighbouring homes can be affected by shared construction, ducts and escape.
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.
- Base warning and escape arrangements on the real bedroom and household layout.
- Make sure every resident can open the final exit without a key or complicated operation from inside.
- Keep protected routes free from storage, charging and combustible items.
- Provide understandable instructions for alarms, calling 999, leaving the building and reporting defects.
- Coordinate with commercial or residential occupiers where the building contains other uses.
What to expect
The five-stage assessment process
- 1
Prepare
Confirm the areas in scope, responsible persons, occupancy, plans, previous reports and relevant fire-safety records.
- 2
Inspect
Walk the premises and examine hazards, people at risk, escape, fire protection and management arrangements.
- 3
Evaluate
Judge whether precautions are suitable for the actual use, occupants, construction and emergency strategy.
- 4
Record and prioritise
Document findings in full and provide a clear, risk-prioritised action plan with responsible owners.
- 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 premises-specific FRA and action plan
- HMO licence, conditions and council correspondence
- Floor plan, rooms, occupiers and household schedule
- Alarm design, commissioning, test and service evidence
- Emergency-lighting and fire-door records
- Electrical, gas and relevant appliance information
- Resident information and common-area checks
- Defect, repair and action-closure evidence
- Agent appointment and responsibility records
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 bedrooms, occupiers, households or shared facilities
- Licence application, renewal, variation or new conditions
- Conversion, refurbishment or altered protected route
- Changed alarm, emergency lighting or fire-door arrangements
- Fire, near miss, repeated false alarm or council concern
- New evidence about construction or unresolved defects
- Change of landlord, licence holder or managing agent
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.
Bedrooms and storeys
Room count, floors, stairs, basements and shared facilities.
Conversion and mixed use
Bedsits, self-contained units, commercial areas, inner rooms and unclear fire separation.
Systems and door scope
Alarm complexity, emergency lighting, fire doors and any sampling or separate inspection.
Licensing and evidence
Council conditions, plans, access, previous reports and unresolved correspondence.
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 large HMO 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.
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.
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 guideCompare all 33 boroughs
Review active, area-specific and upcoming additional HMO and selective licensing schemes, dates and direct council sources.
Open the London licensing tableProperty licence checker
Use the London-wide checker, then verify the result and current requirements with the relevant borough.
Check a London addressFind 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 postcodeLocal 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 large HMO fire risk assessment guidance.
Frequently asked questions
Fire risk assessment for large HMOs FAQs
What counts as a large HMO?
For the usual mandatory licensing definition, it is generally rented to five or more people forming more than one household, some or all share facilities and at least one pays rent. Detailed definitions and exemptions should be checked with the council.
Does a large HMO have to be three storeys?
No. The national mandatory licensing threshold has applied regardless of storey count since 2018, although storeys remain highly relevant to fire risk and the precautions needed.
Does the HMO licence replace the FRA?
No. Licensing and the Fire Safety Order overlap but perform different functions. The FRA evaluates the premises-specific fire risk and precautions and must be kept current.
Does the assessor need access to bedrooms?
The agreed scope should reflect bedroom doors, detection, inner-room arrangements, escape and resident-created risks. Reliable conclusions may require access to all rooms or a justified approach to sampling and limitations.
Can the managing agent arrange the assessment?
Yes. The agent can arrange assessment and access for the landlord or licence holder. Duties still depend on the legal appointment and actual control, and the responsible parties must ensure findings are acted on.
How much does a large-HMO FRA cost?
A relatively straightforward large HMO may commonly start around £450–£950 in London or Surrey. Bedroom count, conversion, mixed use, access, systems, licence evidence and unresolved defects can move the price outside this range.
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
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.