HMO Fire Risk Assessments for Landlords Before a Licence Renewal

An HMO licence renewal is a good point to check whether the fire risk assessment still reflects the property. Tenants change, rooms are used differently, fire doors receive regular wear and alarm systems need ongoing maintenance. A report completed several years earlier may no longer describe the building as it is today.

Not every council asks for exactly the same information during an HMO licence application or renewal. In England, an HMO generally requires mandatory licensing where it is occupied by five or more people forming more than one household, while councils can also introduce additional licensing schemes that cover other HMOs. Landlords should therefore check the current requirements of the local authority where the property is located.

ClearFire carries out HMO fire risk assessments for landlords and managing agents who want to establish whether the current arrangements still suit the property before a renewal progresses. The assessment is about the building and its occupants, not simply producing another item for a licensing file.

Why licence renewal is a useful review point

An HMO may change considerably during a licence period. Several tenants may have moved in and out, furniture may have been replaced, repairs may have been carried out and communal areas may be used differently. A new managing agent may also have taken responsibility for the property.

These changes do not automatically mean there is a problem, but they can make an older assessment less reliable. A report should describe the property that exists now rather than the one that existed when the previous licence was granted.

Reviewing the position before renewal also gives the landlord time to deal with outstanding work. If a door needs attention, records are missing or an escape route has changed, it is better to identify that before the property is under the pressure of a renewal deadline or inspection.

HMO licensing and the fire risk assessment have different roles

An HMO licence covers more than fire risk. Licensing can also consider occupancy, management standards, room sizes, amenities and other housing requirements. A fire risk assessment concentrates on the risks from fire and whether the measures protecting occupants remain suitable.

One does not replace the other. A landlord can hold a valid HMO licence and still need to review the assessment where circumstances have changed. Equally, having a current assessment does not remove the need to satisfy the council’s licensing requirements.

This distinction matters because fire safety needs to be managed throughout the licence period. Doors continue to be used, warning systems need maintenance and shared areas can change through normal tenant behaviour.

What to check before an HMO licence renewal

Sleeping accommodation needs closer consideration

People are more vulnerable when they are asleep. They may take longer to notice a problem, and tenants can be behind closed doors when something happens elsewhere in the property.

An HMO also contains people living independently under one roof. One tenant may work nights, another may work from home and others may cook or use electrical equipment at very different times. New occupants may know little about the building when they first move in.

The assessment therefore needs to consider the HMO as a shared home rather than applying the same assumptions used for an office or ordinary commercial premises.

Fire doors can change during a licence period

Doors in an HMO are used repeatedly every day. Bedroom doors, kitchen doors and doors protecting staircases may all form part of the fire safety arrangements depending on the layout.

Closing devices can stop working correctly, hinges can loosen and seals can become damaged. Tenants may interfere with closers because they find them inconvenient, while replacement locks or other alterations can change the door set.

A review before licence renewal gives the landlord an opportunity to identify visible concerns and arrange repairs or further inspection where needed rather than assuming a door remains suitable because it was satisfactory several years earlier.

Alarm records should tell a clear story

The alarm system may look satisfactory during a visit, but the landlord should also be able to establish how it has been tested and maintained. Records can show when checks were completed, whether faults occurred and when repairs were carried out.

If responsibility has moved between landlords, agents or contractors, gaps in those records can make it difficult to establish what happened. The system also needs to remain appropriate for the property, because HMO size, layout and occupancy can affect the arrangements required.

Where there is uncertainty, the report should identify the point and make clear when further specialist advice is needed rather than making unsupported assumptions.

Escape routes can change without refurbishment

Not every change involves building work. Day-to-day use can gradually alter shared routes. Bicycles, drying racks, shoes, parcels, furniture and household belongings may begin to appear in hallways or on landings.

One item can encourage others, particularly where expectations about communal storage have never been explained clearly. A landlord or managing agent therefore needs a consistent approach to shared areas rather than relying on tenants to judge for themselves what is acceptable.

The assessment records what is found during the visit, while routine management is what keeps the route suitable afterwards.

Room use should match the assessment

A room previously used for storage may later become occupied. A communal space may change purpose, or refurbishment may alter part of the layout. Even modest works can affect how occupants move through the property.

Landlords should tell the assessor about significant alterations rather than relying on the site visit alone to reveal the building’s history. Previous reports, plans and details of completed work can help establish what has changed.

Where substantial changes have taken place, a fresh assessment may provide a clearer baseline than continuing to update a report written for a materially different property.

Previous recommendations should be closed properly

Old reports are useful when they show what was found and what happened afterwards. They are less useful when the same recommendation appears year after year without any record of completion.

Some actions take time, particularly where specialist contractors are involved. The landlord should still be able to establish whether the matter remains open, whether work has been completed or whether later advice changed the original recommendation.

Before renewal, previous assessments can be checked alongside invoices, certificates and contractor records. This gives the next visit better context and helps reveal where action has stalled.

New tenants need current information

An HMO licence may stay with the same landlord while most occupants change. Information given to tenants several years ago cannot be assumed to have reached the people living there now.

New occupants need information relevant to the property and should understand what is expected in shared areas. If doors are repeatedly held open or hallways are repeatedly used for storage, it may show that the reason behind the management rule has not been understood.

Clear and consistent communication is usually more effective than repeatedly dealing with the same issue after it returns.

Local licensing requirements can differ

HMO licensing is administered by local authorities, so processes and additional licensing schemes can vary between council areas. A landlord with properties in more than one location should therefore avoid relying on one standard renewal checklist.

Application procedures, supporting documents and licence conditions can differ. The fire risk assessment supports the landlord’s wider property record, but it should not be presented as a substitute for checking the current requirements of the relevant council.

This local variation is particularly important where a property falls outside mandatory licensing but may still be covered by an additional scheme.

Does licence renewal mean you need a completely new assessment

Not necessarily. If the existing assessment is recent, clearly written and still matches the property, a review may be enough. The assessor can check whether previous findings remain relevant and update anything that has changed.

A very old report, a poorly written assessment or a document that no longer describes the property is different. Trying to repeatedly update a weak report can make the record harder to follow.

The decision should be based on the building and the quality of the existing information rather than the licence renewal date alone.

Managing agents need a complete handover

Where an HMO is professionally managed, a change of agent can create gaps in the property record. The new agent should receive the current assessment, relevant alarm and emergency lighting records, information about fire door works and evidence relating to previous recommendations.

If those records are incomplete, the gap should be identified rather than assuming everything was dealt with by the previous agent. Licence renewal often exposes missing documents because the property file has to be reviewed more closely.

ClearFire works with both landlords and managing agents, so the report can be written with the person who will actually progress the actions in mind.

What landlords should expect from the report

The report should help the landlord decide what to do next. It should explain the findings clearly enough to separate straightforward management matters from work requiring a contractor or further specialist advice.

HMO landlords already have several compliance responsibilities running at the same time. A useful assessment should make decisions easier rather than add another document that takes hours to interpret.

Clear recommendations also make it easier to keep the property record updated when work is completed and provide a stronger history for the next renewal.

HMO fire risk assessments with ClearFire

Jon and Kevin carry out ClearFire’s HMO assessment work themselves. They consider the current property, how it is occupied and the condition of relevant fire safety measures. Existing reports and records can also be reviewed where these are available.

ClearFire works across Bedfordshire, Buckinghamshire, Berkshire, Oxfordshire, Wiltshire and Gloucestershire. The service is suitable for landlords approaching an HMO licence renewal as well as those whose property has changed or whose existing assessment is no longer reliable.

Arrange an HMO fire risk assessment before renewal

If your HMO licence is approaching renewal and the existing assessment is old, incomplete or no longer matches the property, reviewing the position before submitting the application can help avoid unnecessary uncertainty later.

Contact ClearFire to request a quote for an HMO fire risk assessment.