Landlord Fire Risk Assessment UK 2026 — HMO and Common Parts Obligations

A fire risk assessment (FRA) is not the same as general fire safety compliance — having working smoke alarms, fire doors, and an escape route. The FRA is a formal, documented process that identifies fire hazards, evaluates the risk to occupants, and records what precautions are in place and what additional measures are needed. The responsible person must review the FRA periodically and whenever there is a material change to the premises.

For HMO landlords and freeholders of blocks of flats, the obligation to carry out and maintain a documented FRA has existed since 2006. The Fire Safety Act 2021 and the Building Safety Act 2022 have since extended and clarified these obligations, particularly for higher-rise buildings. The consequences of non-compliance — criminal prosecution, unlimited fines, and civil liability in the event of a fire — make a current, properly documented FRA one of the most important safety documents a landlord can hold.

When a formal fire risk assessment is required

The RRO 2005 applies to the 'non-domestic' parts of residential premises. In practice, this means:

HMOs (Houses in Multiple Occupation): The entire HMO — every room, communal area, and shared space — is within scope of the RRO 2005. The landlord or licence holder is the responsible person and must carry out and maintain a documented FRA for the whole property
Common parts of blocks of flats: The freeholder, managing agent, or resident management company controlling the common parts (entrance lobby, corridors, stairwells, plant rooms, roof) must carry out an FRA for those areas. The Fire Safety Act 2021 now explicitly includes flat entrance doors and the external walls (including cladding) within the scope of the FRA
Houses let to a single family: A self-contained house let to one household is domestic premises and the RRO 2005 does not apply. However, working smoke alarms on every floor are still required under the Smoke and Carbon Monoxide Alarm (England) Regulations 2015 (as amended 2022)
Purpose-built bedsits and studio blocks: If the building has common parts (shared corridors, shared kitchens, or shared bathrooms), it is likely to be within scope even if individual units have their own front doors
If in any doubt whether the RRO 2005 applies to your property, assume it does and commission an FRA — the cost of compliance is modest compared to criminal prosecution or liability in the event of a fire

What a fire risk assessment must cover

A suitable and sufficient FRA under the RRO 2005 must:

Identify fire hazards: Sources of ignition (cooking appliances, electrical equipment, smoking), sources of fuel (soft furnishings, stored combustibles, paper waste), and sources of oxygen (ventilation, open windows)
Identify people at risk: All occupants and their relevant characteristics — including people with mobility impairments, young children, or other vulnerabilities who may need evacuation assistance
Evaluate and reduce risk: Assess the risk from identified hazards and record what controls are already in place and what additional controls are needed to reduce the risk to an acceptable level
Record findings and action plan: The FRA must be recorded in writing for any premises with 5 or more employees — but for landlords, a written record is effectively mandatory in all cases as it is the only evidence of compliance in the event of inspection or prosecution
Means of escape: Adequacy of escape routes, fire doors (self-closing, intumescent strips, correct FD30 or FD60 specification), emergency lighting, and assembly points
Firefighting equipment: Appropriate type and number of fire extinguishers, fire blankets (in kitchens), dry risers (higher buildings)
Fire detection and warning system: Grade and category of alarm system (from Grade D battery-operated detectors to Grade A full-address LD1 systems for complex HMOs)

Who can carry out a fire risk assessment

The RRO 2005 requires the FRA to be carried out by a 'competent person'. There are two options:

Self-assessment: For simple, low-risk premises, a responsible person with relevant knowledge and training may carry out their own FRA using a structured assessment tool. For simple single-storey HMOs with straightforward layouts, self-assessment by a trained landlord may be adequate
Competent assessor: For larger, more complex HMOs, multi-storey premises, or buildings with vulnerable occupants, a third-party assessor should be instructed. A competent assessor should be a member of a professional body — such as the Institute of Fire Safety Managers (IFSM), the Fire Industry Association (FIA), or the Institution of Fire Engineers (IFE). BAFE SP205 third-party accreditation is the preferred standard for life safety systems
The responsible person remains liable even if a third-party assessor is used — if the assessor misses a critical hazard due to poor briefing, the responsible person is still the duty holder for compliance
For blocks of flats with external cladding, the FRA must now specifically assess the external wall system and flat entrance doors. Many standard FRA firms lack the competence to assess cladding — a specialist is required
The cost of an FRA ranges from £200–£400 for a simple 3-bedroom HMO to £600–£1,200 for a large, complex HMO or a block of flats

How often must the FRA be reviewed

The FRA must be reviewed regularly and whenever certain events trigger a review:

Regular review: The RRO 2005 does not specify a fixed review period, but the generally accepted standard is every 1 year for higher-risk premises (larger HMOs, multi-storey blocks) and every 3–5 years for lower-risk premises. In practice, annual review is strongly recommended for any HMO to maintain a current, defensible document
After material change: Review must take place whenever there is a significant change — works to the building (extensions, alterations, new staircase layout), change of use of a room, increase in occupancy, change in the number of vulnerable occupants, or installation of new plant or equipment
After a fire or near-miss: Any fire incident (however minor) or near-miss should trigger an immediate review
After change of responsible person: If the property is sold or the managing agent changes, the new responsible person should review and update the FRA
Buildings over 11m: Under the Fire Safety (England) Regulations 2022, responsible persons of buildings over 11m must carry out monthly checks of lifts for firefighting/evacuation use, and quarterly checks of all fire doors in the building. These are additional to the formal FRA review

Enforcement and penalties

Fire and Rescue Authorities are the primary enforcement body for the RRO 2005. They have extensive powers:

Fire inspectors can enter and inspect premises at any reasonable time without prior notice
Alteration notice: the responsible person must notify the fire authority before making structural alterations that may affect fire safety
Enforcement notice: requires the responsible person to remedy deficiencies within a specified period
Prohibition notice: immediate prohibition on the use of all or part of the premises if there is a serious and imminent risk to life
Criminal prosecution: Failure to carry out an FRA, failure to implement required precautions, or obstruction of a fire inspector is a criminal offence. On conviction in the Crown Court the fine is unlimited; a custodial sentence of up to two years may be imposed
Civil liability: if a tenant or visitor suffers injury or death in a fire and the FRA was absent or inadequate, the landlord faces unlimited civil liability

Frequently asked questions

My HMO has 4 tenants — do I definitely need a formal fire risk assessment?+

Yes. An HMO is non-domestic premises for RRO 2005 purposes regardless of the number of occupants. Even a small 3-bedroom HMO with shared kitchen and bathroom is within scope. You must carry out and record a suitable and sufficient FRA. For a simple HMO you may be able to carry out the FRA yourself using a structured tool, but given the criminal penalties for non-compliance, many landlords prefer to use a third-party accredited assessor.

I own a leasehold flat — am I responsible for the FRA of the block?+

No — as a leaseholder of an individual flat, you are not responsible for the common parts. The responsible person for the common parts is the freeholder, managing agent, or resident management company that controls those areas. However, from 2021, the FRA must include flat entrance doors and the external walls, which the freeholder/managing agent must assess. As a flat owner, you are responsible for fire safety within your own flat (which is domestic, so RRO 2005 does not apply), including ensuring your flat entrance door is compliant fire door specification.

How do I prove my fire risk assessment is up to date?+

Keep the written FRA report, any action plans arising from it, and records of completed actions. For HMOs, the FRA should be available at the property for inspection by the fire authority or the local authority licensing team. Dating and signing the FRA, and any review dates, provides evidence of regular compliance. If you use a third-party assessor, retain their report and any correspondence about actions taken. Digital records are acceptable — the key is that they can be produced quickly on demand.

Does my block of flats need a fire risk assessment even if it is only 2 storeys?+

Yes. The RRO 2005 applies to the common parts of any multi-occupancy residential building regardless of height — a 2-storey block of 4 flats with a shared entrance corridor requires an FRA for those common parts. Height only becomes relevant for the additional requirements (monthly lift checks, quarterly fire door checks) under the Fire Safety (England) Regulations 2022, which apply to buildings over 11m, and the higher-risk building regime under the Building Safety Act 2022, which applies to buildings over 18m.

Landlord Fire Risk Assessment UK 2026 — HMOs and Common Parts