Compliance for HMO landlords

Compliance for HMO Landlords — What You Actually Need

You let rooms to three or more people from more than one household who share facilities. HMOs carry more statutory compliance than any other residential letting, and most of it is inspected by the council. Here is what applies, in order, and what you can do yourself.

Your risk profile

High. People sleep there, they do not know each other, cooking happens in shared kitchens, and escape depends on a shared staircase. HMOs are where residential fire deaths cluster, which is why licensing exists. The compliance is specific, statutory, and inspected. It is also mostly cheap once the building is right.

What applies to you

In the order it matters. Each links to a plain-English guide.

Required by lawYou must do this. Not doing it is an offence.

Required if…Required in some situations, not others. Depends on your premises and how you use them.

Good practiceNot written into law, but it is the recognised way to show you have met a legal duty.

Insurers, landlords or clients ask for itNot a legal requirement. A contractual one. Check the wording of what is actually being asked.

Optional, often oversoldNobody is making you buy this. Suppliers will still try.

Fire Risk AssessmentRequired by law

The Fire Safety Order requires it for the common parts and it must be recorded in full. In practice it must cover the whole house because the council judges fire safety in the rooms too under the Housing Act 2004. The council's licensing conditions and the LACORS fire safety guidance set what is expected: fire doors, protected escape route, detection, emergency lighting on the stairs in larger HMOs. A registered assessor who knows HMOs is worth every penny of £250 to £500.

Gas SafetyRequired by law

Annual gas safety check by a Gas Safe engineer, CP12 to every tenant within 28 days and before new tenants move in, kept for two years. Statutory, and a licence condition.

Electrical (EICR)Required by law

Statutory every five years in England under the 2020 Regulations and a mandatory licence condition there. Wales and Scotland have their own five year rules. Copy to tenants within 28 days, to the council within seven days of a request, C1 and C2 remedial work within 28 days.

Fire Alarm SystemsRequired by law

A Grade and Category set by the fire risk assessment and the licence conditions under BS 5839-6, typically a Grade A or D interlinked system with heat detection in kitchens and smoke detection on the escape route and in bedrooms. A Grade D system needs a monthly test by you and annual maintenance. A Grade A panel system needs a weekly test and a six monthly service.

Emergency LightingRequired if…

The LACORS guidance recommends it on the escape route in HMOs of five storeys or more. At three or four storeys it is needed where the route is long or has no light from outside. Monthly test by you, annual duration test.

Fire ExtinguishersRequired if…

Usually a fire blanket in each kitchen and an extinguisher on each floor in larger HMOs, per the assessment and the licence conditions. Annual service.

Legionella Risk AssessmentRequired by law

Required, and for a domestic-type system the landlord can do it: identify the system, note any stored water or little-used outlets, set the controls, record it. No certificate exists or is needed.

PAT TestingGood practice

Landlord-supplied appliances (white goods, kettles, heaters) need to be safe. A PAT test at each change of tenancy and periodically is the accepted way to show it. Tenants' own appliances are theirs.

Asbestos ManagementRequired if…

Pre-2000 houses often have textured coatings, floor tiles and insulating board. The duty to manage applies to common parts; a management survey before any refurbishment is the practical step.

The HMO is the one letting where the fire risk assessment covers the whole house, not just the hall and stairs, and where the council will check. Get that assessment from someone who knows HMO licensing, do what it says, keep the gas and electrical certificates on the statutory dates, and the rest is routine. Where HMO landlords overspend is on services the assessment did not call for and on agents who sell "compliance packs" of certificates the law does not recognise.

In England the Renters' Rights Act 2025 adds a register. The Private Rented Sector Database opens on 15 December 2026 and rolls out region by region. Each let property must be registered with its gas, electrical and EPC certificates and its HMO licence status. The fee is £65 a property a year and the London deadline is 14 October 2027.

Common questions

What does the council actually inspect?

For licensing: room sizes, amenities, fire precautions (doors, detection, escape route, lighting), the gas certificate, the EICR, and management standards. The fire risk assessment is what ties the fire items together and is the first document a licensing officer asks for. Keep every certificate in one folder.

Which fire alarm grade do I need?

BS 5839-6 grades run from Grade A (a panel-based system) to Grade F (battery alarms). Most licensed HMOs need Grade D1 (mains-powered interlinked alarms with battery back-up) at minimum, with Grade A in larger or higher-risk houses. The fire risk assessment and the licence conditions say which. Do not let an installer decide.

Do I need a legionella certificate?

No such document exists. You need a risk assessment, which for a normal house you can write yourself in an hour, and simple controls: flush little-used outlets, keep hot water hot, note it. Letting agents who demand a certificate are asking for something the law does not.

What should this cost?

Annually: the gas check (£60 to £120), the alarm service (£60 to £150), extinguisher service if you have them. Five-yearly: the EICR (£150 to £300). Every three to five years: the fire risk assessment (£250 to £500). Once: the alarm system if you do not have one (£400 to £1,500 for a Grade D system, more for Grade A). Everything else is your time. HMO compliance is cheap to run once the building is right; it is expensive only when the council finds it missing.

Not sure how this applies to your premises?

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Written by David SmithFounder & Editor, Compliance Buyer

Updated 29 October 2026

General information to help you understand your obligations and judge your own risk. Not legal advice.

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