Fire Risk Assessments for Flats and HMOs in London: Who Needs One and How Often

Who needs a fire risk assessment for flats and HMOs, and how often?

Every block of flats, converted house with shared areas and house in multiple occupation (HMO) in London needs a fire risk assessment of its common parts. Under the Regulatory Reform (Fire Safety) Order 2005, the ‘responsible person’ for those parts must carry out a suitable and sufficient fire risk assessment and review it regularly.

The law does not set a fixed renewal date. Guidance and common practice are to review the assessment regularly, typically at least once a year, and after any significant change such as building works, a change in occupancy or a fire. A house or flat let to a single household is a private dwelling and is not usually covered by the Fire Safety Order, although the smoke and carbon monoxide alarm rules still apply inside it.

This guide covers who the responsible person is, how the Fire Safety Act 2021, the Building Safety Act 2022 and the Fire Safety (England) Regulations 2022 changed the duties, what applies at each building height, and what an assessor checks in a typical London building.

Who is the responsible person for a block or HMO?

The responsible person is whoever has control of the common parts. In London this is usually the freeholder, a right-to-manage or residents’ management company, a managing agent acting for one of them, or the landlord of an HMO or converted house.

A converted Victorian house with two or three flats and a shared hallway is easy to overlook, but its hallway and stairs are common parts in exactly the same way as the corridors of a large block. In mixed-use buildings, such as a shop with flats above, there can be more than one responsible person, and they need to coordinate their fire safety arrangements.

The responsible person can carry out the assessment personally, but anyone appointed to assist must be competent. In practice, many freeholders and landlords appoint a professional assessor. At BritCertify, fire risk assessments are carried out by NEBOSH-qualified fire risk assessors.

What did the Fire Safety Act 2021 and Building Safety Act 2022 change?

They widened what the assessment must cover and tightened how it is recorded. The Fire Safety Act 2021, which commenced on 16 May 2022, clarified that the Fire Safety Order applies to the building’s structure, external walls (including windows and balconies) and flat entrance doors in multi-occupied residential buildings.

Section 156 of the Building Safety Act 2022, in force from 1 October 2023, then added three duties for all responsible persons:

• Record the full assessment: the whole fire risk assessment must be recorded, not just the significant findings, along with the name of the person or organisation that carried it out.
• Use competent help: anyone appointed to assist the responsible person must be competent.
• Share information: responsible persons must provide fire safety information to residents.

An assessment written before these changes may not reflect them. If your current document does not mention the external walls or flat entrance doors, or only lists significant findings, it is due for review.

What do the Fire Safety (England) Regulations 2022 require by building height?

The Fire Safety (England) Regulations 2022, in force since 23 January 2023, set duties in three tiers: all multi-occupied residential buildings, buildings over 11 metres, and high-rise buildings of 18 metres or 7 storeys and above. The table brings these together with the other main duties.

Most London converted houses and low-rise blocks fall into the second row. Some mansion blocks and post-war blocks exceed 11 metres, so it is worth measuring rather than assuming. The London Fire Brigade guidance explains each duty in more detail.

What fire safety rules apply to HMOs in London?

HMOs carry an extra layer of duties because occupants are separate households sharing escape routes. The common parts fall under the Fire Safety Order 2005, and councils benchmark fire safety against the LACORS Housing Fire Safety guidance (2008), which sets out a risk-based approach to fire detection, fire doors and protected escape routes.

The Management of Houses in Multiple Occupation (England) Regulations 2006 require HMO managers to keep fire alarms and escape routes maintained. Mandatory HMO licensing applies where 5 or more people forming 2 or more households live in the property, and many London boroughs run additional or selective licensing schemes as well. Licence conditions commonly require a satisfactory EICR and annual gas and alarm certificates, so check your borough’s conditions.

Our HMO fire risk assessment starts at £149 inc. VAT for 1–2 bedrooms, £199 for 3–4 bedrooms and £249 for 5–6 bedrooms.

How often should a fire risk assessment be reviewed?

Regularly, and in practice at least once a year for most flats and HMOs. The Fire Safety Order requires the assessment to be kept under review rather than renewed on a fixed date, so the triggers below matter as much as the calendar.

What does a fire risk assessor check?

The assessor looks at how a fire could start, who it would affect, how people would escape and how well the building would contain it. In a typical London block or HMO, that covers:

• Fire hazards: sources of ignition and fuel, such as electrical intake and meter cupboards, stored items and waste.
• People at risk: residents, visitors and anyone who may need help to leave the building.
• Means of escape: corridors, stairs, final exit doors and locks, and whether routes are kept clear.
• Compartmentation: walls, floors, risers and service penetrations that should stop fire and smoke spreading.
• Fire doors: flat entrance and communal doors, checked against BS 8214:2016 for the certification label, gaps (typically 2–4 mm), intumescent and smoke seals, self-closers, hinges (minimum three), glazing and signage.
• Detection and alarm: the type of system and its servicing records; BS 5839-1:2025 systems are typically serviced every 6 months.
• Emergency lighting: coverage and the BS 5266-1:2025 test regime of monthly flick tests and an annual full-duration test.
• Firefighting equipment: where extinguishers are provided, annual servicing to BS 5306-3:2017 and monthly visual checks.
• Management and information: the evacuation strategy, signage, logbooks and the information given to residents.

What do assessors typically find in London buildings?

Most findings are about maintenance and alterations rather than design. In London’s converted houses and purpose-built blocks, our assessors commonly see:

• Flat entrance doors replaced by leaseholders with doors that are not fire-rated, or with self-closers removed.
• Gaps around cables and pipes passing through walls and ceilings in risers and meter cupboards, often left after later works.
• Bicycles, buggies and rubbish stored in corridors and stairwells that form the escape route.
• Communal fire doors with damaged or painted-over intumescent seals, or closers that no longer shut the door fully.
• Emergency lighting that is fitted but has no record of monthly tests.
• Fire action notices and resident information that are missing or out of date.

Fire doors are a frequent source of actions on London assessments. Our fire door inspection costs £70 per door inc. VAT for up to 3 doors, £60 per door for up to 6 and £50 per door for up to 12.

What should residents and leaseholders be told?

Residents must receive clear fire safety information. In every building with two or more domestic premises, the Fire Safety (England) Regulations 2022 require the responsible person to give residents fire safety instructions and information about the importance of fire doors, and section 156 of the Building Safety Act 2022 requires fire safety information to be shared with residents.

In practice, that information should explain the evacuation strategy for the building, what to do on discovering a fire, and why flat entrance doors and communal doors must close fully on their own. It should be written in plain language and kept up to date when the assessment changes.

Flat entrance doors need particular care in leasehold blocks. The door may form part of the leaseholder’s demise, but since the Fire Safety Act 2021 it falls within the scope of the responsible person’s assessment. Agreeing access for door checks, and asking leaseholders not to replace doors or remove closers without consent, avoids many of the findings listed above.

How should I prioritise the action plan?

By risk to life. A good assessment ends with an action plan that gives each finding a priority and a timescale, and the responsible person is accountable for completing it. The assessment alone is not compliance; the completed actions are.

1. High priority: anything that could stop people escaping or allow fire to spread quickly, such as a blocked escape route, a faulty alarm or a missing fire door on a protected route. Act immediately.
2. Medium priority: defects that weaken protection, such as damaged door seals, missing closers or breached fire stopping. Complete within the timescale the assessor sets.
3. Lower priority: improvements to signage, records and information. Build these into planned maintenance.

Record each completed action with the date and evidence, such as an invoice, certificate or photograph. Because section 156 requires the full assessment to be recorded, keeping the action plan and its completion record together gives you a clear audit trail if the London Fire Brigade or your council asks for it.

What does a fire risk assessment cost in London?

For blocks and converted houses, a communal area fire risk assessment starts at £119 inc. VAT for a single storey, £149 for 2 storeys, £189 for 3 storeys and £225 for 4 storeys. A studio flat assessment starts at £79. There is no single legal ‘fire safety certificate’ for most residential buildings: compliance is shown through the recorded assessment plus servicing certificates for alarms, emergency lighting, extinguishers and fire doors. For the full list of certificates a rental needs, see our London landlord compliance checklist.

How we wrote this guide: this article was written and reviewed by BritCertify’s technical team, including Gas Safe registered engineers, NICEIC/NAPIT registered electricians and NEBOSH-qualified fire risk assessors. It was checked against the cited legislation and official guidance from GOV.UK, legislation.gov.uk and the London Fire Brigade, and was last reviewed in October 2026.