Fire safety is the single most important compliance requirement for any HMO. Get it wrong, and you're not just facing fines—you could face criminal prosecution and imprisonment if a fire causes injury or death.

This guide covers the legal framework, specific equipment requirements, and the consequences of getting it wrong.

Quick Navigation

• The Legal Framework
• Fire Risk Assessments
• Fire Detection and Alarm Systems
• Fire Doors: FD30 Requirements
• Escape Routes and Emergency Lighting
• Fire Extinguishers and Blankets
• Penalties for Non-Compliance
• Fire Safety Checklist

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The Legal Framework

HMO fire safety is governed by two main pieces of legislation:

The Regulatory Reform (Fire Safety) Order 2005 (RRFSO) This applies to the common areas of your HMO—hallways, stairs, landings, and shared kitchens or living rooms. Under this order, you're the "responsible person" and must ensure fire safety measures are in place.

The Management of Houses in Multiple Occupation (England) Regulations 2006 These regulations set out specific management duties for HMO landlords, including maintaining fire safety equipment and keeping escape routes clear.

Together, these laws require you to:

• Carry out a fire risk assessment
• Install appropriate fire detection systems
• Fit fire doors to bedrooms and kitchens
• Maintain clear escape routes
• Provide fire safety information to tenants
• Keep records of all inspections and maintenance

Worth noting: These regulations apply regardless of whether your HMO requires a licence. Even a small 3-person HMO must comply with fire safety requirements. See our HMO licensing guide for when licensing applies.

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Fire Risk Assessments

A fire risk assessment is mandatory for every HMO.

What a Fire Risk Assessment Covers

A proper fire risk assessment examines:

• Sources of ignition — Electrical equipment, cooking appliances, heating systems, smoking areas
• Sources of fuel — Furniture, bedding, stored materials, building construction
• People at risk — Tenants, visitors, anyone who might be in the property
• Existing fire safety measures — Detection systems, fire doors, escape routes, extinguishers
• Gaps in protection — What additional measures are needed

Who Can Carry Out the Assessment?

You can conduct the fire risk assessment yourself if you're competent to do so. However, "competent" means you genuinely understand fire safety principles and can identify risks effectively.

For most landlords, we recommend using a qualified fire risk assessor. The cost typically ranges from £150 to £400 depending on property size, and it's money well spent for peace of mind and legal protection.

How Often Should You Review It?

Your fire risk assessment should be reviewed:

• At least annually
• After any significant changes to the property
• After any fire-related incident
• When the number or type of occupants changes

Keep your fire risk assessment documentation for at least five years. Councils and fire services can request to see it at any time.

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Fire Detection and Alarm Systems

The type of fire alarm system you need depends on your HMO's size and layout.

Alarm Grades Explained

Fire alarm systems are categorised by grade:

Grade	Power Source	Typical Use
Grade A	Mains with battery backup, control panel	Large HMOs, 3+ storeys
Grade D	Mains with battery backup, no control panel	Most small-medium HMOs
Grade F	Battery only	Not acceptable for HMOs

For most HMOs, you'll need a Grade D system at minimum.

Coverage Categories

The "LD" rating tells you where detectors must be installed:

• LD1 — Detectors in all rooms except bathrooms and toilets (highest protection)
• LD2 — Detectors in escape routes plus high-risk rooms (kitchens, living rooms)
• LD3 — Detectors in escape routes only (minimum standard)

What Your HMO Likely Needs

For one or two-storey HMOs under 200m² per floor:

• Grade D, LD3 system (minimum)
• Mains-powered with battery backup
• Interlinked detectors (when one sounds, they all sound)

For three-storey HMOs or those over 200m² per floor:

• Grade A system with control panel
• Interlinked detectors throughout
• Possibly a monitored system

For all HMOs with gas appliances:

• Carbon monoxide detectors in rooms with gas appliances
• This is a legal requirement under the Smoke and Carbon Monoxide Alarm (England) Regulations 2015

Interlinked Systems Are Essential

All smoke and heat detectors in an HMO must be interlinked. This means when one detector activates, every detector in the property sounds simultaneously.

This is critical in an HMO because:

• Tenants may be sleeping in rooms far from where a fire starts
• Multiple closed doors between the fire and sleeping occupants reduce sound transmission
• Early warning gives everyone time to escape

Wireless interlinked systems are available if running cables through the property isn't practical.

Heat Detectors vs Smoke Detectors

Use heat detectors in kitchens to prevent false alarms from cooking. Smoke detectors in kitchens lead to tenants disconnecting them—creating a dangerous situation.

Use smoke detectors in all other areas—hallways, landings, bedrooms, and living rooms.

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Fire Doors: FD30 Requirements

Fire doors are your property's primary defence against fire spread. They buy time for occupants to escape and for fire services to respond.

Where Fire Doors Are Required

In an HMO, fire doors must be fitted to:

• Every bedroom
• Every kitchen (or the door to a hallway adjacent to the kitchen)
• Any room opening onto an escape route
• Cupboards under stairs
• Any door between a garage and the main building

What Makes a Door an FD30 Fire Door?

An FD30 fire door provides 30 minutes of fire resistance. To qualify, it must have:

The door leaf itself:

• Solid core construction (not hollow)
• Minimum 44mm thickness
• Third-party certification (look for a label or plug on the door edge)

Intumescent strips:

• These expand when heated, sealing the gap between door and frame
• Usually fitted in a groove around the door edge or frame

Cold smoke seals:

• Brush or rubber strips that block smoke before the intumescent strips activate
• Critical because smoke kills before flames do

Self-closing device:

• Overhead closers or rising butt hinges
• The door must close fully into the frame without manual intervention
• Tenants must not be able to prop doors open

Correct frame and ironmongery:

• The frame must be fire-rated to match the door
• Hinges must be appropriate (usually 3 hinges for FD30)
• Letter boxes, if fitted, must have fire-resistant flaps

Common Fire Door Mistakes

We see these problems regularly:

• Gaps too large — The gap between door and frame should be 2-4mm. Larger gaps let fire and smoke through.
• Missing intumescent strips — Fitting a fire door without strips makes it ineffective.
• Damaged seals — Strips that are painted over, damaged, or missing must be replaced.
• Broken closers — If the door doesn't close and latch automatically, it won't provide protection.
• Holes in doors — Even small holes (from removed locks or spy holes) compromise fire resistance.
• Wrong doors fitted — Standard internal doors are not fire doors, even if they look similar.

A genuine fire door will have a certification label or plug on the top edge or hinge side. If you can't find this, it's safest to assume the door isn't fire-rated.

Fire Door Costs

Budget approximately:

• FD30 fire door (including intumescent strips): £100-£200
• Fitting (including frame adjustments if needed): £100-£150
• Overhead door closer: £30-£60
• Total per door: £230-£410

For a 6-bedroom HMO, fire door compliance typically costs £1,500-£3,000.

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Escape Routes and Emergency Lighting

Every occupant must be able to escape the building without passing through a high-risk room (like a kitchen) and without needing a key.

Escape Route Requirements

Clear and unobstructed:

• No furniture, bicycles, or storage in hallways or stairwells
• Minimum clear width of 750mm (preferably 900mm)
• No locks that require keys to open from inside

Protected route:

• Fire doors separating the escape route from occupied rooms
• Fire-resistant construction (walls and ceilings)
• No unprotected glazing adjacent to escape routes

Final exit:

• Must lead directly to a place of safety (outside the building)
• Openable without a key from inside
• Should not require passing through another tenancy

Emergency Lighting

Emergency lighting is required in HMOs where:

• The escape route has no natural light
• The property has three or more storeys
• The escape route is complex or lengthy

Emergency lights must:

• Activate automatically when mains power fails
• Provide at least one hour of illumination
• Be tested monthly and documented
• Be serviced annually by a competent person

For smaller HMOs with good natural light to escape routes, emergency lighting may not be mandatory—but your fire risk assessment should confirm this.

Escape Windows

In some HMOs, particularly loft conversions, an escape window may be an alternative to a second staircase. Escape windows must:

• Have an unobstructed openable area of at least 0.33m²
• Be at least 450mm high and 450mm wide
• Have a cill height of no more than 1100mm from floor level
• Open onto a place of safety or rescue point

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Fire Extinguishers and Blankets

Fire extinguishers and blankets are supplementary safety equipment. The expectation is that occupants should escape, not fight fires—so these items are for tackling small fires only.

Fire Blankets (Required)

Fire blankets must be provided in:

• All kitchens (see our kitchen requirements guide for full specifications)
• Any bedroom with cooking facilities (studio-style rooms)

Fire blankets should be:

• Wall-mounted within reach of the cooker (but not directly above it)
• Large enough to cover a pan fire (minimum 1m x 1m)
• Inspected annually for damage

Fire blankets are single-use. Replace any that have been opened or used.

Fire Extinguishers (Usually Not Required)

Fire extinguishers are generally not required in HMOs unless your fire risk assessment specifically identifies a need.

The reasoning is practical:

• Untrained people using extinguishers can make fires worse
• The priority should always be escape, not firefighting
• Tenants may delay escaping to attempt firefighting

If extinguishers are provided, they must be:

• Appropriate type for the risks present
• Serviced annually by a qualified technician
• Kept accessible and properly mounted

Never provide fire extinguishers without also providing training on their use.

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Penalties for Non-Compliance

Fire safety breaches carry serious consequences.

Criminal Prosecution

Under the Regulatory Reform (Fire Safety) Order 2005, fire safety failures can result in:

• Unlimited fines
• Up to two years imprisonment
• Prohibition notices preventing use of the property

If a fire causes death and you're found to have neglected fire safety, you could face manslaughter charges.

Council Enforcement

Local authority housing officers can:

• Issue improvement notices requiring specific works
• Issue prohibition orders preventing occupation
• Revoke your HMO licence
• Prosecute for management regulation breaches
• Issue civil penalties up to £30,000

Insurance Implications

Your insurance may be void if:

• You've failed to comply with fire safety requirements
• You've made false declarations about fire safety measures
• Required equipment wasn't maintained or tested

This means you could be personally liable for all fire damage, injury claims, and legal costs.

Rent Repayment Orders

Tenants can apply for rent repayment orders if you're convicted of certain housing offences. This could mean repaying up to 12 months' rent per tenant.

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Fire Safety Checklist

Use this checklist to assess your HMO's fire safety compliance:

Documentation

• Fire risk assessment completed and dated within last 12 months
• Fire risk assessment reviewed after any property changes
• Records of all fire safety equipment inspections
• Certificates for fire alarm installation and servicing
• Fire safety information provided to tenants

Fire Detection

• Mains-powered smoke detectors on each floor
• Heat detector in kitchen (not smoke detector)
• All detectors interlinked
• Carbon monoxide detectors where gas appliances present
• Monthly alarm testing with records kept
• Annual professional service completed

Fire Doors

• FD30 fire doors to all bedrooms
• FD30 fire door to kitchen or hallway adjacent
• Intumescent strips and smoke seals fitted
• Self-closing devices working correctly
• Gaps between door and frame 2-4mm
• No damage, holes, or modifications to doors
• Certification labels visible on door edges

Escape Routes

• All escape routes clear and unobstructed
• No locks requiring keys from inside
• Final exit leads to place of safety
• Emergency lighting installed and working (if required)
• Escape route signage in place (if required)

Firefighting Equipment

• Fire blanket in each kitchen
• Fire blankets inspected annually
• Extinguishers serviced annually (if provided)

General Safety

• Electrical installation tested (EICR within last 5 years)
• PAT testing for landlord-supplied appliances
• Gas safety certificate current
• No storage under stairs
• Bin storage away from building

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Getting It Right

Fire safety compliance requires attention to detail and ongoing maintenance. If you're unsure whether your HMO meets current standards, a fire risk assessment from a qualified assessor is the best starting point—it'll identify specific issues and prioritise what needs addressing.

The key is treating fire safety as an ongoing responsibility, not a one-time checkbox. Regular testing, good record-keeping, and prompt attention to any issues will keep you compliant and—more importantly—keep your tenants safe.

If you're planning an HMO conversion and want to build fire safety in from the start, get in touch.

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This guide was last updated in January 2026. Fire safety regulations can change, so always verify current requirements with your local authority or a qualified fire safety professional.