HMO fire safety requirements in England

In broad terms, GOV.UK describes an HMO as a home let to at least 3 people who are not from 1 household and who share facilities such as a kitchen or bathroom. A large HMO has 5 or more people from more than 1 household. The full legal test, including converted blocks of flats, is in section 254 of the Housing Act 2004.

The LACORS Housing Fire Safety guide, written with the fire and rescue service and environmental health bodies, explains how the 2 regimes fit together. It describes the Housing Health and Safety Rating System as the principal tool for assessing fire safety in HMOs, and the Fire Safety Order as applying to the common parts, with a protocol between councils and fire services.

Yes. The Fire Safety Order applies to the common parts of an HMO, so the landlord or manager, as responsible person, must make a suitable and sufficient fire risk assessment. Since 1 October 2023 the full assessment must be recorded in writing, with the name of anyone engaged to make or review it. BS 9792:2025, the code of practice for housing, names HMOs in its scope.

• The escape route from each bedroom to the final exit, and any inner rooms
• Fire doors to bedrooms, kitchens and the escape route, with self-closers and seals
• The fire detection and alarm system, its coverage and its test records
• Emergency lighting, where the escape route needs it
• Shared kitchens and cooking appliances
• Locks on bedroom and exit doors, and whether they open from inside without a key
• Storage, bins and bicycles in the escape route
• The fire safety information given to tenants

From 1 October 2022, the amended alarm regulations require a smoke alarm on every storey with living accommodation and a carbon monoxide alarm in any room with a fixed combustion appliance, other than a gas cooker. Landlords must repair or replace faulty alarms once told about them, and check alarms are working on the first day of each new tenancy. Licensed HMOs are exempt from these regulations but meet equivalent duties through licence conditions. Councils can impose penalties of up to £5,000 per breach.

Many do. Additional licensing extends licensing to smaller HMOs, and selective licensing to other private rented homes. 2 examples from 2026:

• Reading Borough Council: additional licensing of HMOs with 3 or more people from 2 or more households across the whole borough, from 1 March 2026 to 28 February 2031. Reading HMO licensing.
• Oxford City Council: a renewed city-wide additional licensing scheme from 25 June 2026 to 25 June 2031, covering HMOs with 3 or 4 occupiers, flats that are HMOs, and section 257 HMOs that are mainly tenanted. Oxford additional licensing.

Schemes in London vary by borough. See the area pages for Berkshire, Oxfordshire and London councils.