HMO Fire Regulations in 2021 (Everything You Need To Know)

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You’ve bought your first HMO, or you’re thinking about buying one.

After all, it’s a good investment and provides consistent cash flow and income protection against inflation.

But, the regulations are more complicated than a Buy-To-Let (BTL) or some other investment properties.

There’s a good reason for this.

When different people live in the same house, risks skyrocket.

So, the Government needs to take precaution, to ensure our safety and wellbeing.

You’ve looked around to find out about fire regulations, how to put them in place and the cost, but it’s all scattered.

Everything you need to know about HMO fire regulations, I’ve got it covered here, and it’s regularly reviewed.

As a bonus, I’ve also included the internal HMO fire standards that we use at HMO Architect in designing hundreds of fire compliant HMO’s.

HMO Fire Regulations — What The Law Says

What Is A Fire Risk Assessment?

Do HMOs Need Fire Risk Assessments?

How To Do A Fire Risk Assessment?

Does An HMO Need Fire Doors?

How To Make Your HMO Fire Regulation Compliant? (Our Internal Standards)

What Happens If You Don’t Comply With HMO Fire Regulations?


HMO Fire Regulations — What The Law Says

According to the Sleeping Accommodation Guide published by the Government,

In 2004 (England and Wales) fire and rescue services attended over 33,400 fires in non-domestic buildings. These fires killed 38 people and injured over 1,300.

In 2004, the costs as a consequence of fire, including property damage, human casualties and lost business, were estimated at £2.5 billion.

So as you can see the potential damage caused by fires cause can be immense.

The purpose of fire regulations is to protect your tenants and give them the best and fastest chance of an exit in the case of a fire.

The Housing Act of 2004 includes Health and Safety Rating System (HHSRS), licencing for HMOs, and management regulations for HMOs.

The main regulation for Fire Safety in HMO’s is the Regulatory Reform (Fire Safety) Order 2005 (FSO).

As an HMO landlord, it is your duty to carry out fire risk assessments in your HMO to minimise the risk of a fire.

What Is A Fire Risk Assessment?

The Regulatory Reform (Fire Safety) Order 2005 (FSO) requires the person responsible for the accommodation to take reasonable precaution to ensure the safety of the premises and people living within.

The Sleeping Accommodation Guide defines a Fire Risk Assessment as

An organised and methodical look at your premises, the activities carried on there and the likelihood that a fire could start and cause harm to those in and around the premises.

The aims of a Fire Risk Assessment are

  1. Identify any fire hazards
  2. Reduce the risk of any of these hazards to as low as possible
  3. Install safety precautions to ensure the safety of the residents and premises

“Hazard” is anything that has the potential to cause harm.

“Risk” is the chance of harm occurring.

Do HMOs Need Fire Risk Assessments?

According to the Health and Safety Rating System (HHSRS), Yes, HMO’s need a Fire Risk Assessment.

A Fire Risk Assessment identifies possible fire hazards and helps put in place precautions and general measures to ensure safety.

It means that either you (the landlord) or your managing agent needs to complete a fire assessment and apply the recommendations.

Alternately, you can hire or contract a qualified person to do it.

How To Do A Fire Risk Assessment?

OK, now you know a bit about the regulation and that you need to ensure your HMO is fire complaint.

If you want to do it yourself, here’s what you need.

As a first step, maintain a fire safety logbook and document a record of all maintenance activities carried out.

The 5 main steps of a Fire Risk Assessment Are:

1. Identifying fire hazards

The first step of a Fire Risk Assessment is identifying hazards. After all, prevention is better than cure.

In order to identify potential fire hazards you need to identify sources of ignition, fuel and oxygen. Some examples include:

Sources of ignition

  • Cooking Equipment
  • Faulty electrical appliances
  • Gas or oil-fired heaters
  • Lighting equipment
  • Boilers

Sources of fuel

  • Wooden furniture
  • Textiles
  • Laundry
  • Waste
  • Flammable liquids and gases

Sources of oxygen

  • Oxygen supplies from cylinder storage
  • Fireworks containing oxidizing material

2. Identifying people at risk

A big part of the assessment is knowing who is likely to be at risk.

This may include

  • People asleep
  • Employees and contractors at work alone
  • Unaccompanied children
  • Disabled people
  • People whose senses may have been impaired due to drugs or alcohol
  • People in the vicinity of the building

Identifying these people in advance and thinking of all possible situations is necessary.

3. Check, remove, reduce and protect the people and premises from risk

Check the risk of a fire occurring, the risk to people from fire and lastly remove and reduce the risks to protect people.

Some ways to do this include

  • Fire detection systems
  • Emergency lighting
  • Clearly marked escape routes

We go into great detail about this later on in this article.

4. Record, plan, inform, instruct and train

Document and record significant findings and the action that’s taken to rectify any risk.

Have an emergency plan, inform and instruct tenants to cooperate and coordinate.

Provide training to tenants and a management company (if you’re not self-managing).

5. Review

Always keep your assessments under review and revise where necessary.

The Government Sleeping Accommodation Guide covers Fire Safety Assessments in greater detail.

Does An HMO Need Fire Doors?

Yes, an HMO needs fire doors.

According to regulations, HMOs should be fitted with self-closing fire doors that are always kept shut with clear notice…

“Fire Door Keep Shut”.

It’s important you use good quality well-designed fire doors that protect the corridor and keep it safe for exit in an unfortunate event of a fire.

HMO Fire Door Shut

How To Make Your HMO Fire Regulations Compliant? (Our Internal Standards)

You’ve now got a basic idea of what a Fire Risk Assessment involves.

What are some proactive actions you can take to make your HMO fire regulation compliant?

I’ve included some internal standards that we use here at HMO Architect and Windsor Patania Architects.

Fire Doors

The primary purpose of a fire door is to contain the spread of fire and smoke across the house.

Fire doors should be fire rated and comply with the 30-minute fire resistance criteria (which means they can contain a fire for at least 30 minutes).

All fire doors should have self-closing arms or door closers and clearly marked for an easy exit.

They should be installed on each doorway leading on to the escape route (except bathrooms and WCs — unless they contain the boiler).

All fire doors should be supplied with intumescent strips with combined cold smoke seals.

This is beneficial when the room, as well as the escape route, has smoke detection.

All bedroom fire doors and the main building entrance doors should be supplied with a thumb-turn on the inside to allow escape in case of fire.

Please note that self-closing hinges do not meet this need.

In our other post, we go into great detail on what to look for when buying HMO fire doors, the exact specifications and how to get them for cheaper.

HMO Fire Door Open

Escape Windows

A fire escape window is an unobstructed window that allows escaping from the property in an event of an emergency.

There are specifications and requirements to allow a safe exit onto the ground below.


According to Hertsmere Council, the specifications for escape windows are:

The window must have an unobstructed openable window area that is at least 0.33msq with at least the width or height dimension being a minimum of 450mm.

The bottom of the openable area (window cill level) must be not more than 1100mm, and not less than 800mm above floor level.

Windows are suitable for means of escape where the drop from the window to ground level is one storey only (not exceeding 4.5m from first-floor level to outside ground level).

Note: The ground below the windows must be flat and free from hazards (low walls, railings etc).

Where security is provided on windows, means of the opening must be readily available within the room.

Where primary access to a sleeping room is through a high-risk room (i.e. communal, kitchen or living room) an alternative suitable means of escape must be provided via a door or escape window directly to the outside.

As you can see there are specifications to adhere to as part of the fire regulations.


Escape Routes

In an emergency, easy to use, clear unobstructed escape routes can make the difference between life and death.

Escape routes should be free from any obstructions or obstacles which may hinder their use.

Don’t store anything in these routes and ensure there are no electrical or telephone wires running across the floor that could be a trip hazard.

Signs and Notices

Clearly mark and display all exits with a sign that makes it easy to identify an exit.

Specifications include green background with a white figure and clearly visible “EXIT” written alongside an arrow.

These must be of size 100mm x 500mm and placed at each landing level and above the final exit door (front and rear exit doors).

Place fire signs between 2m and 2.5m from floor level throughout the property to identify fire doors, escape routes etc.

Clearly marked fire exit sign

Fire Detection And Alarm Systems

Depending on the number of floors in the HMO, there are recommendations on what type of fire detection and alarm system to use

Here are the minimum standards:

1. For one or two-storied HMO’s

In one or two-storied HMOs where the floor area is less than 200 sqm, a Grade D, Category LD3 smoke alarm system should be installed.

Grade D means these alarms are mains powered, have a built-in backup battery system and interconnected by wire or radio signal.

Fire alarm panels are not required. It’s required that these alarms form part of the escape routes i.e. hallways and landings.

During a fire risk assessment, the category of cover may be raised to LD2 which means the alarm may need to be installed in high fire risk rooms like the kitchen, living rooms and bedrooms.

2. For HMO’s of three storeys or higher

In the case of larger HMO’s, there are 2 options available

a) Grade A — This includes a conventional fire alarm panel with fire alarm detectors, call points, sounders and beacons specified according to the layout of the property.

b) Mixed System — This includes a combination of Grade A and LD3 fire alarm system where Grade A is used in the communal area while category LD2 or LD3 is used in the individual rooms or dwellings.

Both of these options have pros and cons. The best thing is to consult and seek advice from building control within your local authority.

Many landlords prefer mixed systems as they can be isolated and a nuisance alarm going off in one area doesn’t affect the entire property.

Here at HMO Architect, we recommend

All HMOs should be installed with an LD1 smoke alarm system.

In our experience, all HMOs need smoke detectors in bedrooms and communal areas. Plus emergency lights.

Below is what we use.

Automatic Fire Detection System (What We Use)

An Automatic Fire Detection system conforming to BS5839: Part 6: 1995 with LD1 level should be installed to Grade A specification.

A copy of the commissioning certificate should be supplied upon completion of the work.

The design and installation should follow the recommendations of BS5839 standards.

The control and testing equipment should be powered by the mains and interlinked with battery backup in the following areas:

  • All common escape staircases on each landing
  • Corridors (all)
  • Bedrooms (all)
  • The lounge

The control and indicating system to BS EN 54–5 must have a power backup of at least 24hours.

The control equipment should be within the common staircase near the main entrance at least 1500mm above the finished floor level (FLL).

Once completed, the commissioning engineer should provide the relevant certificates and user manuals.

Emergency Lighting

The use of emergency lighting helps people find their way to the exit in case of an emergency.

Emergency lighting must be provided on each floor — within and outside.

In smaller HMOs (floor area is less than 200 sqm), it’s acceptable to use borrowed lighting from a dependable source (like an outside street lamp or torch).

But, larger HMOs need a more comprehensive lighting system based on the layout. It must be designed in compliance with the BS 5266 Part 1 standards.

The system should provide no less than 3 hours duration and be a non-maintained system.

The system must operate in the event of a circuit failure to follow BS 5266:2016 standards.

All wiring should follow I.E.E. Wiring Regulations (PVC or sheathed cable).

Upon completion of the work, get a copy of the verification and completion certificates.

Firefighting Equipment And Facilities

Providing firefighting equipment is a must on the property.

Portable firefighting equipment like a fire extinguisher can reduce the risk of a small fire turning into a big one.

For example, safe use of a portable fire extinguisher prevents a dustbin fire turning into a much bigger one.

Basic training to staff and tenants helps avoid injury as untrained use of firefighting equipment may cause harm.

The number and location of all fire extinguishers will depend on the size and layout of the property.

The following is a good guide:

  1. A multi-risk fire extinguisher of 13A rating situated in the kitchen area.

2) A fire blanket in each room used for cooking following BS 6575.

A carbon dioxide (CO2) extinguisher next to any incoming mains electric supply cupboard.

Install and maintain Extinguishers as per BS EN-3: Part 3 and BS 5306 Part 3 (1985).

[Please note: As per Regulation 38, plans showing all fire safety information is provided to assist in your obligation to carry out a Fire Risk Assessment as defined in the Regulatory Reform (Fire Safety) Order 2005.]

Fire Extinguisher to comply with HMO Fire Regulations

Residential Compartmentation

The area around the stairs should be made of fire-resistant construction with 30 minutes of fire resistance.

This includes the soffit to the ground floor staircase and any door in the stair enclosure.

It excludes bathrooms, W/C or shower compartments, if they have no fire risk.

Fire should not spread via the bathroom, W/C or shower compartment to the escape route.

Also, any electrical or gas meter cupboards should also be rated for 30 minutes fire resistance.

Any ductwork passing through the wall and floor need to be fire-rated and fitted with fire dampers.

Commissioning Certificates

The electrical subcontractor should be an approved member of the NICEIC or ECA.

They should provide certificates of installation, test and completion to the client and Building Control.

Lastly, they should complete all work under current building regulations.

Fire Blanket

Provide a fire blanket complying with the requirements of BS 6575: 1985 within the kitchen area.

Fix a fire blanket retainer to the wall 1500mm from FFL (Finished Floor Level).

Enclose any new gas or electric panels, meters or fuse boxes with 30 min fire-resistant material and lockable doors.

What Happens If You Don’t Comply With HMO Fire Regulations?

So, now that you know a lot more about HMO fire regulations, what’s the downside if you don’t comply?

Well, the worst-case scenario is there could be a fire with fatal consequences for your tenants and yourself.

HMO fire regulation negligence is a punishable offence that may lead to arrest and even jail time.

Also, not to mention guilty conscience for the rest of your life.

So always put the safety of your tenants first and make sure you follow the legislation.


I hope this article helped you understand the importance of HMO fire regulations and how to make your HMO fire compliant.

We take fire safety very seriously here at HMO Architect and gladly shared our safety standards above. 

Pledge to adhere to the best standards possible and keep your tenants safe. 

If you’d like to talk to an architect, we’ve helped hundreds of people with HMO fire regulation across the country, please get in touch.

We’d love to help you.

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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."



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