The Regulatory Reform (Fire Safety) Order 2005 requires the responsible person of non-domestic premises to carry out a 'suitable and sufficient' fire risk assessment. For landlords, this applies to HMOs (the whole property), the common parts of blocks of flats (entrance hall, corridors, stairwells), and any other multi-occupancy premises with shared areas.
Criminal offence
Failure to carry out an FRA, or carrying out an inadequate FRA, is a criminal offence under the RRO 2005. Penalties: unlimited fine on Crown Court conviction, up to two years' imprisonment. Fire authorities can also serve Prohibition Notices immediately closing the premises.
When an FRA is required
- All HMOs (entire property — all rooms and communal areas)
- Common parts of any block of flats (corridors, stairwells, plant rooms, roof voids, entrance lobby)
- Shared-access buildings even if below HMO threshold
- Self-contained houses let to a single family: domestic premises, RRO 2005 does not apply — but smoke alarm regulations still apply
What the FRA must cover
- Identification of fire hazards: ignition sources, fuel sources, oxygen sources
- Identification of people at risk and their vulnerabilities
- Evaluation of existing controls and adequacy of escape routes, fire doors, emergency lighting, alarm systems
- Written action plan with timescales
- For blocks over 11m (Fire Safety (England) Regulations 2022): monthly lift checks, quarterly fire door checks also required