Do I need a fire risk assessment for my HMO?

Yes. The common parts of an HMO are non-domestic premises under the Regulatory Reform (Fire Safety) Order 2005, so the Responsible Person must carry out and maintain a suitable and sufficient fire risk assessment. Greater Manchester councils will also ask to see a current assessment when you apply for or renew a mandatory HMO licence.

Does my HMO need a licence?

A mandatory HMO licence is required where the property is occupied by five or more people forming two or more separate households who share facilities such as a kitchen or bathroom. Some Greater Manchester councils also operate additional or selective licensing schemes covering smaller HMOs in designated areas, so always check with the local authority for the specific address.

Can I do my own HMO fire risk assessment?

Legally you may, if you are competent to do so. In practice, if a licensing officer, an insurer or a court challenges your assessment, the liability rests with you personally as the Responsible Person. For a licensable HMO, most landlords find a certified assessor’s report is the safer and faster route to licence approval.

What do councils most often pick up on in HMOs?

The recurring issues are fire doors that do not close properly or have been altered, missing or inadequate interlinked detection, escape routes used for storage, locks on final exit doors that need a key, and assessments that are out of date or too generic to be useful.

How often should an HMO fire risk assessment be reviewed?

There is no fixed statutory interval, but the assessment must be reviewed regularly and whenever there is a material change — new layout, change of occupancy, building work, or after a fire or near miss. Annual review is the common standard for HMOs and is what most licensing teams expect to see.

HMO Fire Risk Assessment Manchester

If you let an HMO anywhere in Greater Manchester, the fire risk assessment is the document that sits at the centre of your compliance — and it is the one licensing officers look at hardest. Get it right and licence applications move smoothly. Get it wrong and you face delays, conditions, or enforcement.

This guide covers what is legally required, what Greater Manchester councils actually expect to see, and the issues that most often hold landlords up.

⚖️ It Is a Legal Duty, Not a Formality

The common parts of an HMO are non-domestic premises under the Regulatory Reform (Fire Safety) Order 2005. As the Responsible Person you must carry out a suitable and sufficient fire risk assessment, act on its findings, and keep it under review. Failure to do so is a criminal offence carrying an unlimited fine.

Which HMOs Need a Licence?

A mandatory HMO licence is required where a property is occupied by five or more people forming two or more separate households, sharing facilities such as a kitchen or bathroom.

Beyond that, several Greater Manchester authorities operate additional licensing (covering smaller HMOs) or selective licensing (covering all private rented homes in designated areas). These schemes vary by borough and change over time, so always check the position for your specific address with the relevant council — Manchester, Salford, Bolton, Stockport, Oldham, Bury, Rochdale, Tameside, Trafford and Wigan all set their own.

Whether or not the property is licensable, the fire risk assessment duty under the Fire Safety Order applies regardless.

What the Assessment Must Cover

A suitable and sufficient HMO assessment goes well beyond a walk-through with a clipboard. It should systematically address each of the following.

Ignition sources and fuel

Cooking facilities, heating, electrical installations and appliances, smoking, and the accumulation of combustible material in shared areas.

People at risk

Everyone who sleeps in the building, plus visitors and contractors. Sleeping risk is the reason HMOs are treated more seriously than daytime-only premises — occupants may be asleep, unfamiliar with the layout, or need assistance to escape.

Means of escape

Protected escape routes of adequate width, travel distances, final exit doors openable without a key from the inside, and routes kept permanently clear.

Fire detection and warning

An appropriate, interlinked system covering escape routes and rooms, so that a fire detected anywhere raises the alarm everywhere in the building.

Compartmentation and fire doors

Fire-resisting construction between bedrooms and escape routes, correctly specified and fitted fire doors with intumescent strips and cold smoke seals, and self-closing devices that actually work.

Emergency lighting and signage

Appropriate to the building — particularly where escape routes have no borrowed light, or where the layout is not immediately obvious to a new occupant.

Management arrangements

Testing and servicing regimes, records, and how occupants are told what to do if the alarm sounds.

🚪 Fire Doors Are the Number One Issue

More HMO assessments are held up by fire doors than by anything else. Common problems: self-closers removed or disconnected because they slam, gaps around the door leaf that are too large, missing or painted-over intumescent strips, doors wedged open, and ordinary internal doors fitted where a fire door is required. All are fixable — but only if they are identified.

What Holds Licence Applications Up

From the recurring themes across HMO licensing in Greater Manchester, the issues that most often cause delay are:

An out-of-date assessment — carried out years ago, or before building work that changed the layout.
A generic template report that could apply to any property and shows no evidence of an actual inspection.
No prioritised action plan — a list of observations with no indication of what is urgent.
Actions identified but never closed out — the assessment found the problems, and nothing was done.
Detection that does not match the building — for example a system that does not cover the full escape route, or unlinked battery units where an interlinked system is needed.
Escape routes used for storage — bikes, bins, furniture and boxes in a protected hallway.
Key-operated locks on final exits — occupants must be able to get out without hunting for a key.

Who Is the Responsible Person?

For most HMOs this is the person in control of the premises — usually the landlord, or the managing agent where they have taken on that control. It is not the tenants, and it is not automatically the letting agent who simply finds tenants.

This matters because the duty, and the liability, follow the Responsible Person. If you own the HMO and hold the licence, an assessment produced by someone else does not transfer your legal responsibility — which is why the quality of the assessment is very much your problem.

🔍 Councils Can Inspect Without Notice

Local authority licensing and housing teams, and the fire and rescue service, can inspect HMOs and require production of the fire risk assessment. Enforcement can include improvement notices, prohibition notices restricting use of part or all of the building, and prosecution. A prohibition notice on a let property is immediate and costly.

How Often to Review

The Fire Safety Order requires the assessment to be kept up to date rather than setting a fixed interval. In practice you should review it:

At least annually for a licensable HMO — this is what most licensing teams expect.
After any building work, layout change or change of use.
When occupancy changes materially — more occupants, or occupants needing assistance to escape.
After a fire, a false alarm pattern, or any near miss.
Ahead of a licence application or renewal, so the document you submit is current.

📋 What We Provide

A certified assessor visits the property, produces an RRO 2005-compliant written report with a prioritised action plan, and delivers it within 48 hours of the survey. Reports are formatted for Greater Manchester licensing teams, insurers and lenders. Fixed fee quoted within 2 hours of your enquiry.

Practical Steps Before Your Assessment

You can make the visit faster and the outcome better with a little preparation:

Clear escape routes and communal areas of stored items.
Gather any existing documentation — previous assessments, alarm and emergency lighting certificates, electrical and gas safety records.
Make sure the assessor can access every room, including the loft and any plant or meter cupboards.
Note any building work carried out since the last assessment.
Have your licence reference and the council contact to hand if a renewal is pending.

An assessment is most useful when it reflects the building as it actually operates — so it is better for the assessor to see the property as it normally is than as a staged version of itself.

HMO Fire RiskAssessment Manchester —The Landlord’s Guide