Houses of Multiple Occupation (HMO)

In this blog we discuss houses of multiple occupation (HMO) in respect of the need for fire doors, whether or not a HMO can be considered low risk and who should do your fire risk assessment. We also discuss some of the key points of the main guidance document used for HMO’s, LACORS (2008): Guidance on fire safety provisions for certain types of existing housing (LACORS).

We assume the following:

1) You understand your local authorities (LA) licence requirements (Mandatory, Additional or Selective).

2) Your property falls under the requirement of the Regulatory Reform (Fire Safety) Order 2005 (FSO). In other words, we are not counting a shared house as defined by LACORS paragraph 35.2.

Do I need fire doors on bedrooms in my HMO?

In short, there is no straight answer to this question, and a suitable and sufficient fire risk assessment needs to be undertaken by a competent person to confirm what arrangements for fire protection are adequate. In low-risk properties, you might be able to relax a requirement of fire doors if you have adequate escape windows on the highest occupied floor (below 4.5m) or some other additional means of escape, enhanced fire detection and warning above the requirements of the current standards and/or water suppression (sprinklers).

Note that whether or not you need to have ‘certified’ fire doors, conventional doors do need to be of adequate construction – this is discussed further below.

Is my HMO low risk?

This depends on a number of factors including, in no particular order:

1) The size of the HMO. Barnet Council specify that a larger HMO is any HMO with more than 6 occupants, with a small HMO providing accommodation for 3-6 people (forming 2 or more households). Larger HMOs are not considered low risk.

2) The height of the building and size of the rooms. Taller buildings with larger rooms will not be low risk and will need additional provisions to be considered normal risk. This includes flats in multiple occupation that are in larger purpose built or converted blocks of flats.

3) The availability of fire protection systems that exceed the minimum package of fire protection measures required for the specified premises.

4) The complexity of layouts, particularly the means of escape and the availability of additional means of escape.

5) The type of occupants and any additional risk they might present / their presence might present.

6) If bedrooms are considered risk rooms (Note – bedsits are normally always considered risk rooms).

This is not an exhaustive list, and no further information is provided here, but the examples are provided to give an idea of some of the things that might be considered.

Why does my HMO fire risk assessment say bedroom are risk rooms?

Caution should be applied when interpreting the guidance. When LACORS was written and then published in 2008, a HMO occupant may have had a low powered mobile phone and possibly a laptop on charge, with a TV in the corner. Jump forward to 2025 and the occupant might have a mobile, a tablet, a laptop, a home-made vape, and an e-scooter and/or bike all charging at the same time, such is our reliance now on battery powered equipment. If any of these items or their charging equipment is in poor condition it may fail and L-ion battery failure is a significant cause of fires, especially where equipment is in poor condition or has been modified. The London Fire Brigade say that they attend a battery related fire every two days. Add to the list of devices on charge and throw in a lamp, a TV and maybe a PlayStation and we’re now potentially seeing too many devices for the available number of wall sockets, so possible we are going to witness daisy chaining of extension leads. All of this pressure on single outlets within the mains wired system increases risk of failure of the fixed electrical installation. Multiply this by the number of bedrooms and the whole system really is under pressure for what it was probably designed for.

It may sound implausible, but tenants aren't necessarily transient and may remain in one room of one property for many years and they accrue goods and equipment over time. And why not? Who would deny them? It's their home.

Ignition in a small room with relatively larger volumes of combustible materials, commonly found in bedrooms and bedsits within HMO dwellings, will likely reach a full involved fire in 2-4 minutes. Occupants leaving the room may not shut the door behind them or if an inadequate door fails quickly, fire and smoke will enter the means of escape rapidly cutting off the internal way out. These factors should be considered in any assessment. For the protection of persons, the worst-case scenario must be considered.

Furthermore, it should be considered that there is an inability to control the tenant’s demise or their behaviours that could impact the fire safety of the rest of the property, such as hoarding combustible material, smoking, introducing untested electrical equipment, charging L-ion batteries, and so on. Rules included in tenancy agreements, such as to prevent smoking and vaping, cannot guarantee violations by tenants won’t occur.

Though our focus is on life safety, property damage and loss can be significant to a HMO. In a scenario where there is a fire and firefighting response, there would be a significant impact on you as the property owner and for the tenants. Aside from escaping a fire, tenants would have been through a traumatic ordeal and potentially suffered loss of possessions as well as potentially their home. You will have lost your asset, or it will have suffered significant damage, either from the fire or from water damage of any firefighting response.

Can I fire risk assess my HMO myself?

If you're competent then yes, however, a common issue is Licensees, managing agents, and so on, who have little expertise in fire protection apply LACORS incorrectly. They apply the black and white. LACORS itself discusses 'grey areas'. Experience, knowledge and other standards and guidance often need to be applied. Any guidance requires expertise to make a judgement on what is required as every property differs, as do the risks and the methods to control those risks.

The law, i.e., the FSO says you need to be competent. Competence is the combination of SKEB - skills, knowledge, experience and behaviours. Realistically, how competent are you in fire protection? Equally, will your skills and qualifications meet the requirements of the LA? It’s a lot to think about but bear in mind that a ‘suitable and sufficient’ fire risk assessment is a legal requirement and there are potentially severe consequences for failure to meet your legal obligations. Further to this, you may not be adequately insured if your fire risk assessment is inadequate.

Where can I get a fire risk assessment for my HMO?

We always recommend you appoint a reputable fire risk assessor or fire risk consultancy to undertake your fire risk assessment for your HMO. Being able to read LACORS is not enough. You have to be able to make informed judgements based on relevant experience, knowledge and expertise.

All Health, Safety & Fire Consulting Ltd fire risk assessors / fire risk consultants are skilled, experienced and qualified practitioners, who are able to undertake your fire risk assessment for you, giving you the peace of mind that your tenants are safe and you are fully compliant with the law.

HMO Case Study

This is a real-world example of where one of our clients had, on the surface, a small, low risk, shared house. It demonstrates how the interpretations of guidance by the client fell short and how the fire risk assessment process informed the requirements of further fire protection measures.

The property is a 2-storey detached house (G, 1), purposed as a general needs dwelling and converted to a HMO). The property has five or more residents forming more than two households, with shared facilities and is licensed under the mandatory scheme for HMO’s. It has pitched tile roof and brick external leaf with upvc framed glass windows and doors. It has wooden floors and a single set of wooden stairs. Access is at ground floor level via the properties driveway. The property has eight bedrooms but only six are given to housing residents, with the remaining two bedrooms purposed as storage and drying rooms. There is a communal toilet, kitchen-diner and living room on the ground floor incorporating a laundry room, with access to the enclosed rear garden. There is a communal bathroom, drying room and store on the upper floor. There is gated access via the side of the house from the rear of the property to the front of the property. A pretty standard HMO.

The client had questions raised by the LA regarding fire safety during the approval of a renewal of the HMO License. The LA were concerned that the property was not low-risk, there were no fire doors on bedrooms and had indicated potential options of either providing FD30 fire doors to bedrooms to protect the means of escape, or, provide enhanced (LD1) fire detection and warning (AFD) in order to progress the renewal of the license to operate a HMO, subject to the findings of a risk assessment. The LA were of the view that the property was not a low risk shared household and the existing AFD was inadequate (Grade D Category LD2 in common parts with Grade D F2 in bedrooms) to compensate for this fact. Much of the clients argument in respect of adequate fire safety arrangements relating to LACORS guidance hinged on the view of the property being ‘low risk’.

Health, Safety & Fire Consulting Ltd fire risk assessors were asked to provide a risk assessment and define the requirements of the property. Always note that a life safety risk assessment is an assessment of risk and not simply a ‘compliance audit’.

The property did not meet the definition of a 'shared house', when considering LACORS paragraph 35.2 as the occupants of the property do not have the defined characteristics as stated in the document and do not share a tenancy jointly. Although some of the conditions were met to achieve a shared house status, the lower risk perceived in guidance to be consistent with a shared house was not considered applicable to this property.

However, enhancing fire detection to a Grade D1 Category LD1 system would reduce the ‘risk level’ of the premises, in accordance with LACORS paragraph 9.12, ‘If there is a suitable second staircase or exit or if there are additional fire safety measures (an enhanced system of fire detection and warning, for example, or a water suppression system), the premises may be considered lower risk and the travel distances and levels of protection may be adjusted accordingly where this lower risk can be demonstrated.’

Note - The system should be installed by a competent person and should comply with the requirements of BS 5839-6:2019 ‘Fire detection and fire alarm systems for buildings Part 6: Code of practice for the design, installation, commissioning and maintenance of fire detection and fire alarm systems in domestic premises’.

Conventional doors present on bedrooms did not meet the criteria of guidance. LACORS states in paragraph 21.6, ‘that it should be possible to accept existing, well fitted and constructed solid doors, providing they are in sound condition. Solid timber doors and panelled doors of substantial construction may be adequate in these lower risk situations. Non fire-resisting glazed doors, doors of flimsy construction or hollow infill-type doors (commonly known as ‘eggbox’) should not be accepted’. The doors at the property were 35mm at their thickest and were significantly thinner in the panelled sections.

In conclusion, the consultant took the view that the minimum package of fire protection requires an upgrade in the AFD system to lower the risk of the property to achieve consideration as a low-risk property. Once provided, fire doors to bedrooms will not be necessary. However, though fire doors would be negated on the basis of an enhanced AFD system being present, they still need to meet the requirement of the guidance. It is not clear in LACORS what constitutes an adequate level of construction of a conventional door.

To assist, reference was given to advice provided for conventional doors in government guidance for fire risk assessment of similar properties posing a similar level of risk.

‘A Guide to making your small paying-guest-accommodation safe from fire’ (2024) states in the means of escape section, ‘In most instances, it should be possible to accept solid, conventional doors that are a good fit in their frames. This will typically comprise a 44mm thick door of solid timber or with a core comprising flaxboard or chipboard.’

In some instances, where the property contains a higher risk, you might be required to have both an enhanced level of detection and ‘certified’ fire doors’.

The overarching message of this blog is that on the surface the simplicity of a HMO, may not be as simple as it seems and there is a clear danger in reading the guidance and coming to the wrong conclusion. It will always be in yours and your tenants’ best interests to get a suitable and sufficient fire risk assessment completed and regularly reviewed by a competent fire risk assessor. Contact Health, Safety & Fire Consulting Ltd to discuss how we can help you.

© Health, Safety & Fire Consulting Ltd – October 2025.