An HMO inspection is a structured assessment against HHSRS hazard categories and HMO Management Regulations. Category 1 hazards trigger mandatory enforcement — there is no discretion for the council to overlook them.
Understanding the HHSRS — what inspectors are scoring
The Housing Health and Safety Rating System (HHSRS) assesses 29 hazard categories introduced by the Housing Act 2004. Each hazard is scored by combining the likelihood of harm with its potential severity. Hazard scores above 1,000 are Category 1 (mandatory enforcement); scores of 1–999 are Category 2 (discretionary action). In HMOs, the five most frequently cited Category 1 hazards are:
- Excess cold: Every habitable room must have adequate controllable fixed heating capable of maintaining 21°C in living areas and 18°C in bedrooms. Portable heaters alone are not acceptable.
- Damp and mould: Any visible mould growth, rising damp, penetrating damp, or significant condensation will be scored. Address all damp sources before the inspection — blocked gutters, failed window seals, inadequate extraction.
- Fire: The most heavily weighted HHSRS hazard in HMOs. Covers fire detection system, fire doors, escape routes, emergency lighting, and the absence of combustible materials near ignition sources.
- Falls on stairs: Handrails must be present, securely fixed, and run the full length of every stairway. Stair nosings must be visible. Loose carpets or worn stair surfaces will be cited.
- Electrical hazards: EICR must be in date (5-year maximum). All sockets and light fittings must be safe and appropriately protected. Consumer unit must have RCD protection.
Fire safety — the inspector's primary focus
Fire safety accounts for the highest HHSRS weighting in HMOs. Before the inspection, systematically check:
- Fire detection system: Grade D1 or D2 interlinked mains-powered smoke alarms with battery backup. Smoke alarms in each habitable room and corridor. Heat alarm in kitchen. Carbon monoxide detector where gas appliances are present. All alarms must be interlinked so one trigger sets off all.
- Fire doors: Every door off an escape route must be a self-closing FD30 fire door. Check: fire door label or plug present; functioning self-closer; intumescent strip and cold smoke seal intact; no gaps at the frame exceeding 3mm; door closes and latches fully.
- Escape routes: Must be clear of obstruction at all times. Where escape is via a window, it must open without a key to a sufficient size for egress. External fire escapes must be structurally sound and signed.
- Written fire risk assessment: Must be current, specific to the property, and reviewed at least annually or after significant alteration. The inspector will ask to see it.
Room sizes — national minimums and how to measure
| Room type | Minimum floor area (England) | Notes |
|---|---|---|
| Single bedroom | 6.51 m² | Above 1.5m ceiling height only |
| Double bedroom | 10.22 m² | Above 1.5m ceiling height only |
| Rooms 4.64–6.51 m² | Children under 10 only | Must not be used as adult sleeping space |
| Rooms under 4.64 m² | Must not be used for sleeping | Absolute prohibition |
Measure internal clear floor area only — exclude built-in wardrobes or cupboards that project into the room. Exclude any floor area where the ceiling height is below 1.5m. Use a laser measurer and record measurements in writing. Many councils impose higher local standards in their licence conditions — check your council's specific requirements.
Amenity provision — kitchens, bathrooms, and WCs
The national minimum amenity standard requires one set of facilities per 5 occupants. Many councils require more. The most common inspection failures in shared amenity provision are:
- Missing or broken mechanical extraction to outside in kitchens and bathrooms — creates damp/mould and is a direct Management Regulations breach.
- Insufficient fridge space or worktop area for the number of occupants.
- Bathroom ventilation fan does not have a run-on timer — extract must continue for several minutes after the light is switched off.
- Shared bathrooms and WCs in poor decorative or hygienic condition — Regulation 7 requires communal areas to be in good and clean repair.
HMO Management Regulations — what inspectors check
The Management of Houses in Multiple Occupation (England) Regulations 2006 impose day-to-day management duties on HMO landlords. Inspectors assess:
- Regulation 3: Manager's name, address, and telephone number must be prominently displayed inside the HMO.
- Regulation 4: The landlord must take all reasonable steps to protect occupiers from injury arising from structural weakness or defect. Repair any defective structure promptly.
- Regulation 5: Water supply and drainage must be in good repair. Legionella risk assessment must be current. Hot water must be supplied at safe temperatures.
- Regulation 7: All communal areas must be maintained in good and clean repair, adequately lit, and safe to use. This is the most commonly cited Management Regulations breach — dirty or damaged shared kitchens and bathrooms.
- Regulations 8–11: Each bedroom must have adequate natural light, working ventilation, and be free from damp when first occupied.
Pre-inspection document checklist
Have the following documents ready in a folder for the inspector:
- Gas safety certificate (current — less than 12 months old)
- EICR (valid — less than 5 years old, or sooner if the report specifies)
- Written fire risk assessment (reviewed within the past 12 months)
- Smoke alarm test records (monthly testing records recommended)
- HMO licence application form and supporting documents
- Any planning permission, permitted development certificate, or Article 4 Direction documentation
- Legionella risk assessment (if required for the property size and water system)
Use the HMO Licensing Application Pack (LS-E-027) to compile your licence application documents and prepare your property file before the inspection. The pack includes checklist, template notices, and guidance on completing the licence form.