The 'responsible person' for a multi-occupied residential building is typically: for a leasehold block, the freeholder or the management company; for an HMO, the landlord or the manager; for purpose-built rental blocks, the landlord or their managing agent. The responsible person is required to carry out fire risk assessments covering the whole building (including external walls and flat entrance doors), implement the Fire Safety (England) Regulations 2022 obligations, maintain firefighting equipment and facilities, and provide fire safety information to residents.
For landlords of HMOs (houses in multiple occupation), the fire safety obligations are layered — the RRFSO 2005 (as amended by the Fire Safety Act 2021) applies to any common parts; the Housing Act 2004 and HMO Management Regulations 2006 impose additional specific fire safety standards (interconnected smoke alarms; fire blankets; fire extinguishers; fire-resistant room separations; fire doors throughout; illuminated emergency lighting in HMOs with 5+ storeys); and local authority licensing conditions for mandatory HMOs (with 5+ occupants from 2+ households) typically include specific fire safety requirements tailored to the building.
Fire Safety Act 2021 scope, Fire Safety (England) Regulations 2022 obligations and HMO fire safety
The complete fire safety framework for landlords of multi-occupied residential buildings and HMOs:
- Fire Safety Act 2021 — FRA scope and responsible person obligations: The Fire Safety Act 2021 (in force for England and Wales) amended Article 6 of the RRFSO 2005 to provide that the RRFSO applies to: (a) the structure and external walls of the building (including any doors, windows, balconies, or decoration forming part of the external walls — critically: cladding panels, insulation systems, and balconies); and (b) all doors between the common parts and a domestic premises — i.e., the flat entrance doors (front doors of self-contained flats). Before the Fire Safety Act 2021, it was unclear whether the RRFSO extended to external walls and flat entrance doors — these doubts arose after the Grenfell Tower fire in June 2017. The 2021 Act resolved this ambiguity. Responsible person (RP): under the RRFSO 2005, the RP is the person who has control of the premises (in the context of their role as employer; owner; occupier). For a multi-occupied residential building: the building owner/freeholder; the management company; or the landlord or their managing agent (for HMOs). For residential blocks with a Right to Manage company (RTM), the RTM company is the RP for common parts. The RP is required to: (a) carry out a fire risk assessment of the building (covering all common parts, structure, external walls, and flat entrance doors); (b) implement and maintain appropriate fire safety measures; (c) keep the fire risk assessment under review; (d) record the fire risk assessment in writing if the building has 11 or more employees or if 5 or more persons are present (including in residential blocks — RRFSO 2005 Art.9(6)). Fire Safety (England) Regulations 2022: the Regulations impose specific obligations on the RP of buildings containing two or more sets of domestic premises with common parts; they do NOT apply to single-family houses (even BTL) or to blocks with no common parts. Buildings over 11 metres in height (multi-storey blocks with floors above 11 metres ground level): (i) FIRE DOOR CHECKS — COMMUNAL: the RP must carry out quarterly checks of all communal fire doors (doors in common parts that are designed to resist the passage of fire — fire-resistant doors in the stairwells, corridors, and plant rooms): checking automatic closing mechanism (self-closing device — must close fully without assistance); gaps around the door (not exceeding 3mm); condition of hinges; intumescent seals (cold smoke seals and fire seals); fire door handles; and any fire-rated glazing panels. (ii) FIRE DOOR CHECKS — FLAT ENTRANCE DOORS: the RP must carry out monthly checks of all fire doors to individual domestic premises (flat entrance doors): the check involves using the building's resident notification system to ask residents to check and report any faults with their flat entrance doors — the RP is NOT required to gain access to each individual flat monthly but must have a system in place for residents to report faults (e.g., written instructions to residents); the RP must also visually check flat entrance doors from the common parts where possible. Buildings 11 metres or below in height: the quarterly communal fire door check still applies (but not the monthly flat entrance door check).
- Resident information, firefighting lifts and equipment, wayfinding and HMO fire safety: Information to residents (Fire Safety (England) Regulations 2022): for buildings containing two or more sets of domestic premises with common parts, the RP must provide residents with: (a) information about the importance of communal fire doors (keeping them closed; not propping them open; reporting faults immediately); (b) the name and contact details of the responsible person (so residents know who to report fire safety concerns to); (c) fire safety instructions — what to do in case of fire; evacuation procedures (stay put vs simultaneous evacuation vs phased evacuation); assembly points; (d) instructions on the use of fire alarm systems; (e) information about checking and reporting faults with their own flat entrance doors; (f) in buildings with storeys over 11 metres: notice about firefighting lifts; instructions about fire safety equipment in the building. Firefighting lifts and equipment (Regulations 2022): for buildings over 11 metres, the RP must regularly inspect and test all firefighting lifts and firefighting and evacuation equipment (including firefighters' communication systems; emergency generators; smoke ventilation systems). A record of these inspections and tests must be kept and made available to the fire and rescue authority on request. Wayfinding signage: in buildings over 11 metres, the RP must ensure that the floors of the building are marked with floor numbers clearly visible to firefighters — on all staircases at every landing and lift lobbies. HMO fire safety — additional obligations beyond RRFSO: landlords of HMOs have additional fire safety obligations under the Housing Act 2004 (Part 1 — HHSRS) and the Management of Houses in Multiple Occupation (England) Regulations 2006 (SI 2006/372) and Management of Houses in Multiple Occupation (Wales) Regulations 2006 (SI 2006/1702). Specific obligations include: (a) interconnected smoke alarms in all rooms and corridors (mains-wired with battery backup for mandatory HMOs — 5+ occupants/3+ storeys); (b) fire blanket in every kitchen; (c) fire extinguisher on every floor of the common parts; (d) fire doors throughout the HMO (including between the kitchen and other areas); (e) illuminated emergency lighting in common parts (for HMOs with 3 or more storeys). Local authority HMO licensing conditions commonly add further specific requirements tailored to the building. England only — note: the Fire Safety (England) Regulations 2022 apply in England only; Wales has separate fire safety legislation (Fire Safety Wales (Class D Buildings) Regulations — in development post-Grenfell)
Frequently asked questions
Who is the 'responsible person' under the Fire Safety Act 2021 for a block of flats?+
The responsible person (RP) under the Regulatory Reform (Fire Safety) Order 2005 (as amended by the Fire Safety Act 2021) is the person who has control of the premises. For a block of flats: the freeholder or the management company (for a leasehold block); the Right to Manage company (for the common parts, if a RTM company has been formed); or the landlord or their managing agent (for blocks held as a single investment). The RP is responsible for the fire risk assessment, fire safety measures, fire door checks, firefighting equipment maintenance, and providing fire safety information to residents.
How often must a landlord check fire doors in a multi-occupied building?+
Under the Fire Safety (England) Regulations 2022 (in force 23 January 2023), for buildings over 11 metres: communal fire doors (in shared corridors, stairwells, and plant rooms) must be checked QUARTERLY; flat entrance doors (front doors of individual flats) must be checked MONTHLY — this is done through a resident notification system asking residents to check and report faults, plus a visual check from common parts where possible. For buildings 11 metres or below with common parts, quarterly checks of communal fire doors still apply.
Do the Fire Safety Act 2021 obligations apply to HMOs?+
Yes — HMOs are subject to both the RRFSO 2005 (as amended by the Fire Safety Act 2021) for common parts, and additional fire safety obligations under the Housing Act 2004 (HHSRS) and the HMO Management Regulations 2006. These additional obligations include: interconnected smoke alarms throughout; fire blanket in every kitchen; fire extinguisher on every floor of common parts; fire doors throughout; and illuminated emergency lighting in common parts for HMOs with 3+ storeys. Local authority HMO licensing conditions often add further specific fire safety requirements.
What did the Fire Safety Act 2021 change about the scope of the fire safety order?+
The Fire Safety Act 2021 amended Article 6 of the Regulatory Reform (Fire Safety) Order 2005 to clarify — beyond doubt — that the RRFSO applies to: (1) the structure and external walls of the building, including cladding, insulation, and balconies; and (2) flat entrance doors — the front doors of individual flats that open into the common parts. Before the 2021 Act, there was ambiguity (following Grenfell Tower in 2017) about whether these elements fell within the RRFSO. The 2021 Act resolved this, meaning the responsible person's fire risk assessment must now cover external walls and flat entrance doors.
- Fire door regulations — specification and maintenance requirements →
- Fire risk assessment — RRFSO 2005 obligations for landlords →
- HMO fire safety — interconnected alarms, extinguishers and fire doors →
- Building Safety Act 2022 — higher-risk buildings and accountable persons →
- Cladding remediation — Building Safety Act 2022 funding and leaseholder protections →
- EICR — Electrical Installation Condition Report requirements →