HMO Emergency Lighting: Everything you need to know

Reading Time: 7 minutes

When it comes to building and fire regulations, unforeseen circumstances like power outages or emergencies are a primary concern. Given the nature and layout complexities of HMOs, this, too, should be top on your list of priorities. For landlords, a functional emergency lighting system is crucial for the safety and security of tenants, and compliance is a matter of responsibility with often severe legal implications. Discover the crucial role emergency lighting plays in ensuring compliance with building and fire regulations for HMOs.




Emergency lighting is a safety system designed to activate automatically during a power outage. Its primary purpose is to illuminate escape routes and safety equipment, crucial for the safety and well-being of occupants in the event of an emergency, facilitating a swift and secure evacuation.

According to our regulation, certain premises, schools, hotels, offices, care facilities, and Houses of Multiple Occupation (HMOs) – our main focus here – are required to have emergency lighting installed to ensure adherence to safety standards. This measure is critical in protecting occupants and ensuring a secure evacuation process during emergencies.



While all HMOs must comply with safety regulations and requirements, such as fire doors and carbon monoxide alarms, not all present the same level of risk, for instance, HMOs with high number of tenants or several storeys will pose an amplified risk. Because of the layout and variety of HMOs –typically more complex than a single-let property– an emergency lighting system may be mandatory.

With multiple occupancy units and shared spaces like hallways, staircases, and escape routes, the emergency lighting system must be designed to cover all these areas adequately. It must ensure that in the event of a power cut, residents can navigate their way out of the property safely.



These regulations mandate that HMO landlords and managers ensure their properties have adequate emergency lighting systems.

The responsibilities for emergency lighting in HMOs are governed by various regulations and standards, including Building Regulations, the Regulatory Reform (Fire Safety) Order 2005, and local council requirements.

  • Building Regulations: These are broader regulations that cover all aspects of construction and safety in buildings, including requirements for emergency lighting as part of overall building safety. I.E.E. Wiring Regulations.
  • BS5266-1:2016: This is the specific British Standard providing detailed guidelines on emergency lighting, including where and how it should be installed and maintained.
  • Regulatory Reform (Fire Safety) Order 2005: This legislation focuses on fire safety in commercial spaces, including HMOs. It requires suitable safety measures, including emergency lighting, to be in place.
  • Local Council Requirements: These can vary by area but generally include specific rules or guidelines on building safety, which might add to or clarify the above regulations.

Regular inspections and maintenance of these systems are also required to ensure they remain in good working order.

  • I.E.E. Wiring Regulations: Known as BS 7671, the regulations fall under the technical and safety standards for electrical installations –wiring, sockets, switches, and other electrical components. They complement the Building Regulations and are crucial for ensuring the safety and compliance of electrical works, including those related to emergency lighting systems in HMOs.

While not directly part of the hierarchy of building and fire safety regulations, I.E.E. wiring regulations are essential for the safe and proper implementation of electrical aspects within these broader safety frameworks.



The emergency lighting requirements can vary widely based on each HMO’s unique layout and design and because each specific area presents unique challenges and risks. Common areas like hallways, stairwells, and exit points must have adequate emergency lighting to ensure safe evacuation. This requirement includes ensuring all escape routes are well-lit and clear of obstructions.

Areas with specific risks, such as kitchens, should have emergency lighting to address the potential hazards in these zones. The lighting should be strategically placed to illuminate the spaces effectively, ensuring that occupants can safely exit the building or access safety equipment in an emergency.

The standard (BS 5266 Part 1) covers key specifications, including location and quantity of lights, duration of operation, maintenance, and testing schedules. For HMOs, these requirements vary:

  • Smaller HMOs accommodating 3 to 4 occupants: Emergency lights are typically installed only upon request by the local authority as part of the selective licensing application process. It’s important to note that some councils may not mandate a selective license. Nonetheless, for safety reasons, it’s recommended to have emergency lights installed at all levels in HMOs regardless of licensing requirements.
  • HMOs with 5 or more occupants: emergency lighting is a mandatory requirement for communal areas such as corridors, stairs, kitchen, and living areas. This is essential as part of the mandatory licensing application process and may also extend to bedrooms in some cases.
  • Larger HMOs: A detailed system designed according to the property layout and compliant with BS 5266 Part 1 standards is essential, reflecting larger spaces’ greater complexity and increased safety needs.
  • Duration and Type: The system should ideally provide illumination for a minimum of 3 hours and be classified as a (more on this later), which activates only during power failures. LED emergency spotlights are frequently preferred in HMOs due to their stylish and discreet design.
  • Circuit Failure Compliance: In line with BS 5266:2016, the system must function during circuit failures, ensuring uninterrupted safety lighting.
  • Wiring Standards: All installations should adhere to I.E.E. Wiring Regulations, ensuring safe and reliable wiring practices.
  • Certification: Post-installation, obtaining verification and completion certificates is crucial to validate the work and ensure regulatory compliance.

For updated and detailed information, consult the actual BS 5266 documentation or engage with a professional who specialises in building safety and compliance.



Typically, emergency lighting systems come in three different types. As is often the case with HMO regulations, each council may apply specific criteria to determine which system suits an HMO.

1.   Maintained emergency lighting

This system remains illuminated continuously, functioning as regular lighting under normal conditions and switching to emergency mode during power outages. Offers constant lighting, ensuring that escape routes and critical areas are always illuminated. It’s particularly useful in high-traffic areas and places where immediate visibility is crucial.

2.   Non-maintained emergency lighting

This lighting activates only when the regular power supply fails. It’s typically used in areas where continuous lighting isn’t necessary. More energy-efficient and cost-effective, as it only operates during emergencies, this system is ideal for less frequented areas and is widely used in HMOs.

3.   Sustained emergency lighting

This system combines both maintained and non-maintained functionalities with two sets of lamps, one for regular use and one for emergencies. Provides more flexibility, making it suitable for a variety of spaces.



The choice of emergency lighting system in an HMO should be guided by a careful assessment of the property’s specific needs, compliance requirements set by standards and local authorities, and the balance between safety and efficiency. Factors to keep top of mind include,

  • Property Layout and Usage: The size and complexity of the HMO, along with how the different spaces are used, will influence the selection.
  • Legal and Safety Requirements: Compliance with building and fire safety regulations is paramount and shouldn’t be taken lightly.
  • Energy Efficiency and Cost: Balancing upfront installation costs with long-term energy consumption and maintenance expenses is key.
  • Aesthetics: While not a cause of concern in compliance and functionality, for some HMOs, the visual impact of emergency lighting fixtures is a consideration, especially in common areas and entryways. Aim to balance energy efficiency and features that can facilitate system management.



Compliance with Building Regulations and Fire Safety Legislation is non-negotiable for HMO properties, and these regulations mandate the installation of appropriate emergency lighting systems as part of the broader fire safety measures.

The adequacy of emergency lighting is assessed during the property’s inspection for its Completion Certificate. This certificate is a prerequisite for obtaining an HMO License, underscoring the importance of getting the emergency lighting system right from the start. However, it’s crucial to confirm whether the appointed electrical contractor provides this certification service, as not all of them do. It’s recommended to inquire in advance to guarantee adherence to regulations and obtain the appropriate documentation.

These standards are critical for ensuring tenant safety and also a legal requirement for HMOs.

How concerned should landlords be about neglecting these standards? Non-compliance can lead to costly consequences, from preventing you from renting out the property to substantial fines (in the hundreds of thousands) and imprisonment.

Emergency Lighting Regulations: Proving Compliance

To prove compliance, HMO landlords must keep:

  • Installation Certificates: Documents proving the system was installed by a qualified professional.
  • Maintenance and Testing Records: Detailed logs of all maintenance and testing activities.
  • Compliance Certificates: Certificates received after each professional inspection.



Your will be best placed to perform a comprehensive and accurate assessment, locating the position of emergency lights in the pre-construction phase.

  1. Assessment: Begin by assessing the property to identify all areas that require emergency lighting, including escape routes and high-risk areas.
  2. Planning: Designing a lighting plan that covers all necessary areas, ensuring compliance with legal standards.
  3. Choosing the Right System: Select the appropriate emergency lighting system based on the property’s requirements.
  4. Professional Installation: This is carried out by a qualified electrician or specialist to install the system. They will handle the wiring and placement of lights according to the plan.
  5. Testing: Once installed, the system should be tested to ensure it functions correctly.



Regular maintenance and testing are crucial for ensuring the emergency lighting is operating and reliable. For compliance, evidence of tests and maintenance are also essential.

  • Routine checks: Regular checks to ensure all lights and batteries are operational.
  • Functional test: All leading lights must undergo a monthly test unless the system operates on a central battery, which requires daily testing.
  • Annual testing: Conducting a full discharge test at least once a year to verify the system’s ability to function during an emergency.

Essential maintenance tasks for HMO landlords and managers

  • Record Keeping: Maintain logs of all tests and maintenance activities.
  • Immediate Repairs: Address any faults or issues with the system as soon as they are identified.
  • Staying Informed: Keeping up to date with any changes in regulations or standards.

Installing and maintaining emergency lighting systems in HMOs requires a systematic approach, adherence to legal requirements, and the involvement of qualified professionals. These qualifications are non-negotiable for both installation and maintenance. Professionals ensure:

  • Compliance: Adherence to all relevant safety and building regulations.
  • Expertise: Proper installation and maintenance, reducing the risk of system failure.
  • Safety: Ensuring the safety of tenants and the property.



The certification process for emergency lighting systems in your HMO involves several key steps:

  1. Professional Assessment: A qualified professional must assess the emergency lighting system to ensure it meets all regulatory standards.
  2. Testing and Inspection: The system undergoes thorough regular testing and inspection, verifying its functionality and compliance.
  3. Certification Issuance: Upon successful inspection and testing, a certificate of compliance is issued, affirming that the emergency lighting system adheres to the required standards.


  • Emergency lighting plays a vital role in ensuring the safety of occupants in HMOs, providing illumination during power outages and emergencies to facilitate a secure exit.
  • The legal obligations and regulations governing emergency lighting in HMOs are stringent, stemming from an imperative to protect residents in their living environments.
  • For HMO landlords, managers, and investors, compliance with these regulations is not optional but a mandatory requirement.
  • As an HMO landlord, it is your legal responsibility to implement all necessary measures to protect your tenants during a power outage and its associated risks.

Whether acquiring an HMO property for the first time or renovating your existing portfolio, we can help you get your project the best chance to succeed with the highest standards. Reach out for a free discovery call to discuss your project with us.


Ensure Fire Safety Compliance: Download Our Fire Testing & Maintenance Guide for free

Neglecting proper fire testing can cost lives and lead to hefty fines. Ensure your HMO property is fully compliant with our detailed guide & checklist.

Why Download?
✅ Detailed checklist focusing on fire testing and maintenance.
✅ Proactive measures to prevent non-compliance and hazards.
✅ Get the peace of mind every landlord deserves.

Type your name and email address below for instant access, the guide will be sent directly to your email.

* indicates required

Picture of Giovanni Patania

Giovanni Patania

(Architect Director, Co-Founder)

Giovanni Patania is the Lead Architect and Co-Founder at HMO Architect and Windsor Patania Architects.

Originally from Siena, Italy, Giovanni worked as a Project Lead Architect at Foster+ Partners, designing Apple stores across the world,

An HMO Investor himself, Giovanni understands property thoroughly, both from an investor's perspective and technically, as an Architect.

With over 15 years of HMO development experience, working on over 150+ HMOs and a 95% Planning and Building Regulation success rate, Giovanni has the expertise and credentials to help you on your HMO journey."



Other Recommended Articles For You