Fire safety for HMOs and shared areas: fire risk assessments, fire doors and who is responsible

In England, the shared parts of a residential building with more than one home, such as the hallways, stairs and landings of a block of flats or a house converted into flats, are covered by the Regulatory Reform (Fire Safety) Order 2005, and the landlord, freeholder or managing agent is the responsible person who must carry out a written fire risk assessment and act on it. HMOs carry further fire duties through their licence and the HMO management regulations. This guide sets out the rules in England: which apply where, what the assessment covers, what changed in 2022 and 2023, and what to keep on file. The Fire Safety Order also applies in Wales, while Scotland and Northern Ireland have their own fire safety laws; all three are summarised near the end.

Two regimes, two enforcers

• The Fire Safety Order covers non domestic premises, which GOV.UK says include the common areas of multi occupied residential buildings. It is enforced by the local fire and rescue authority.
• Housing law covers the homes themselves. The council assesses fire as one of the hazards in the Housing Health and Safety Rating System, and for an HMO it also enforces the licence conditions and the HMO management regulations.

Whether the shared parts of a particular house let to sharers count as common parts under the Order can depend on how it is occupied and let. If you are unsure for a specific property, ask the local fire and rescue authority, and keep their answer on file.

Who the responsible person is

For common or shared areas, GOV.UK names the responsible person as the landlord, freeholder or managing agent. Where more than one person has control, for example a freeholder and a managing agent, they must work together, and since October 2023 they must share fire safety information with each other in writing and with anyone who takes over the role. The management agreement should say which of them carries out and reviews the assessment.

What the fire risk assessment must cover

The GOV.UK steps are to identify the fire hazards, identify the people at risk, evaluate and remove or reduce the risks, record the findings and prepare an emergency plan, then review and update the assessment regularly. Along the way it considers:

• escape routes and exits, and keeping them clear;
• fire detection and warning systems;
• fire fighting equipment;
• removing or safely storing anything that could start or feed a fire;
• the evacuation plan for the building;
• people who would need help to get out, such as older or disabled residents and young children;
• the information residents are given.

You can do the assessment yourself with the government’s fire safety risk assessment guides, which include ones for sleeping accommodation and for purpose built blocks of flats, or appoint a competent person such as a professional fire risk assessor. The fire and rescue authority can advise, but cannot carry it out for you.

What changed: flat entrance doors, external walls and written records

• 16 May 2022: the Fire Safety Act 2021 confirmed that, in a building with two or more homes, the Order covers the structure, the external walls, the common parts and every door between a flat and the common parts. Flat entrance doors are part of the assessment.
• 23 January 2023: the Fire Safety (England) Regulations 2022 require, in every multi occupied residential building with two or more homes and common parts, fire safety instructions for residents and information on why fire doors matter, given when residents move in and then every year. In buildings with storeys over 11 metres, communal fire doors and their closers must be checked every three months, and flat entrance doors once a year on a best endeavours basis. High rise buildings carry further duties.
• 1 October 2023: under section 156 of the Building Safety Act 2022, the whole assessment, all its findings and the fire safety arrangements must be recorded in writing in every case, not just the significant findings. If an assessor helped, their name and organisation are recorded too. Residents of buildings with two or more homes must be given relevant fire safety information in a form they can understand, including the risks the assessment found and the measures in place.

The extra duties for an HMO

• Licence conditions: a licensed HMO must have smoke alarms installed and kept in working order, the gas safety certificate sent to the council every year, and any fire safety conditions the council adds. The HMO licensing guide covers the rest.
• The HMO management regulations apply to every HMO in England, licensed or not. The manager must keep every means of escape from fire clear of obstruction and in good repair, keep fire fighting equipment and fire alarms in good working order, display notices showing the escape routes where there are more than four occupiers, and display their own name, address and phone number for the occupiers.
• Alarms in the homes themselves: the smoke and carbon monoxide alarm rules apply to rented homes, with licensed HMOs meeting them through their licence conditions.

Reviewing the assessment

The law asks for the assessment to be reviewed regularly and does not set a fixed interval. Review it whenever something significant changes: building work, a new layout, more occupiers, a change in who lives there, or a fire or near miss. Record the date of each review, what you looked at and what changed, and choose a next review date you can justify.

Penalties

Fire and rescue authorities inspect premises and can serve notices requiring changes. Failing to comply with the main duties of the Order is a criminal offence, and on conviction in the Crown Court carries a fine, up to two years in prison, or both. For an HMO, breaches of licence conditions and of the management regulations are enforced by the council, with the figures on the landlord fines and penalties page.

What to keep on file

• The written fire risk assessment in full, its date, and the name of the assessor and their organisation.
• The actions it raised, who owns each one and when it was done.
• Each review, with its date and what changed.
• Fire door checks, where required, with dates and any access attempts for flat entrance doors.
• Alarm and emergency lighting tests and servicing records.
• The fire safety information given to residents, and when.
• Written agreements and information shared with any other responsible person.

Wales, Scotland and Northern Ireland

• Wales: the Fire Safety Order applies in Wales too, covering buildings with two or more homes such as blocks of flats, so a responsible person must assess the fire risk, and fire and rescue authorities can serve enforcement notices. Every HMO, licensed or not, falls under the Welsh HMO management regulations, which require the manager to keep the means of escape clear and to keep fire fighting equipment and fire alarms in good working order. A licensed HMO in Wales also carries a licence condition to install smoke alarms and keep them working.
• Scotland: fire safety duties come from the Fire (Scotland) Act 2005. An HMO that must be licensed is not treated as domestic premises under that Act, so a fire risk assessment must be carried out and reasonable fire safety measures taken. Every home in Scotland must also have satisfactory equipment to detect and warn of fire and of carbon monoxide, part of the tolerable standard since 1 February 2022.
• Northern Ireland: the Fire and Rescue Services (Northern Ireland) Order 2006 does not treat an HMO as domestic premises, so a fire risk assessment must be carried out and reasonable fire safety measures taken. A licensed HMO must also have an adequate means of escape, smoke alarms and fire extinguishing equipment.

Where this lives in Verixad

Verixad has a Fire Risk document type, and HMOs come set up to need a fire risk assessment, so an HMO without a current one shows as a gap on its record. A letting agency can set the same requirement for any other type of property it manages, file each assessment with its date and next review date, and turn each action the assessment raises into a task with an owner and a due date. The free compliance check reads HMO fire risk assessment dates from a spreadsheet as well as Gas Safety, EICR and EPC dates.

General information rather than legal advice. The England rules were checked on 23 October 2026 against GOV.UK, the Home Office fact sheets on the Fire Safety (England) Regulations 2022 and legislation.gov.uk; the Wales, Scotland and Northern Ireland summary on 26 and 27 October 2026 against the Welsh Government, nidirect and legislation.gov.uk.