Landlords ask us this constantly, usually in one of two forms: “my assessment is three years old, is that a problem?” or “do I really need this doing again every year?” The law’s answer is annoyingly vague, so here’s the practical one.
What the law actually says
The Regulatory Reform (Fire Safety) Order 2005 requires the responsible person (for an HMO, normally the landlord or managing agent) to make a suitable and sufficient fire risk assessment and to keep it up to date. That’s the whole requirement. There is no sentence anywhere in the legislation that says “every 12 months”.
The review duty is triggered whenever there’s reason to suspect the assessment is no longer valid or there’s been a significant change to the premises or how it’s used.
What “kept up to date” means in practice
Because the law doesn’t set an interval, good practice (and most enforcing authorities) fill the gap. The widely accepted position is:
- Review annually. A documented check that nothing significant has changed and the existing assessment still holds. This doesn’t necessarily mean a full re-assessment from scratch.
- Re-assess fully every few years, or immediately when something significant changes.
Many HMO licence conditions turn the soft convention into a hard requirement. It’s common for a licence to require the fire risk assessment to be reviewed at least annually and available for inspection. Check the conditions on your own licence; that document outranks any blog post, including this one.
Events that should trigger a review straight away
Regardless of when the last assessment was done, review it now if any of these have happened:
- Change of occupancy type or numbers: more sharers, a switch to bedsit-style letting, a family let becoming a shared let
- Building works: loft conversions, new partitions, moved kitchens, a new storey in use
- Changes to the fire precautions themselves: a new alarm system, replaced fire doors, an altered escape route
- A fire, a near miss, or repeated false alarms
- Enforcement contact: a housing officer’s schedule of works, an improvement notice, licence renewal
- New information: for example, a fire door inspection or alarm service that flags defects the assessment assumed were fine
If none of that has happened and your assessment is under a year old, you’re generally in good shape. If it’s several years old and pre-dates your current tenants, treat it as stale even though nothing dramatic has changed. Occupancy drifting over time is itself a change.
Who can do the review?
For a straightforward HMO, the responsible person can legally review the assessment themselves, but the review is only worth what the reviewer knows. The pattern we recommend to landlords in Hounslow: have a competent assessor produce the baseline assessment, then either have it professionally reviewed annually (it’s quick, and cheap relative to the original) or bundle the review into the property’s scheduled servicing so it never gets forgotten.
An out-of-date assessment is treated by councils much like a missing one, and with licence renewals that’s an expensive way to save a small fee.
Need yours done or reviewed? See our HMO fire risk assessment service or get a quote. We cover the whole borough of Hounslow and surrounding West London.