Last updated: April 2026 · 30 min read
The Complete Guide to Fire Risk Assessments in the UK (2026)
A fire risk assessment is a legal requirement under Article 9 of the Regulatory Reform (Fire Safety) Order 2005 for almost every non-domestic premises and the common parts of most residential buildings in England and Wales. Since October 2023, Section 156 of the Building Safety Act 2022 requires every Responsible Person to record their assessment in full, regardless of business size. This guide explains who needs one, what the law says, how the process works, what it costs, and how to choose a competent assessor.
We are an independent fire risk assessment practice serving Hampshire, Dorset, Surrey, and West Sussex. This is the guide we wish every Responsible Person had read before we walked onto their premises. It covers the legal framework, the assessment process, real costs, what a good assessment actually looks like, and the common findings we see on jobs every week. It is written for the person who has been told they need a fire risk assessment and is trying to work out what that actually means, what it should cost, and who to trust with the work.
What is a fire risk assessment?
A fire risk assessment is a structured inspection of your premises that identifies fire hazards, evaluates who is at risk, judges the adequacy of existing fire safety measures, and records a prioritised action plan to bring any residual risk down to an acceptable level. For non-domestic premises and the common parts of residential buildings, it is a legal duty, not a best-practice option.
The legal foundation sits in Article 9(1) of the Regulatory Reform (Fire Safety) Order 2005, which requires the Responsible Person to make a “suitable and sufficient assessment of the risks to which relevant persons are exposed for the purpose of identifying the general fire precautions he needs to take.” That phrase — suitable and sufficient — is not defined in the legislation, but it is the phrase enforcement officers, insurers, and courts will use to judge whether the assessment you produced genuinely covers what it needs to cover.
The methodology most fire risk assessors work to is PAS 79-1:2020 for non-domestic premises (offices, retail, warehouses, industrial, education, healthcare) or BS 9792:2025 for housing (HMOs, blocks of flats, student accommodation, specialised housing). PAS 79-1 sets out a nine-step process that goes considerably deeper than the Home Office’s simplified five-step checklist. The five-step version is designed for Responsible Persons who feel competent to carry out their own assessment on the simplest types of premises. For anything beyond a single small shop or office, the professional nine-step methodology is the standard that a competent assessor will follow.
A fire risk assessment is not the same thing as a fire safety audit carried out by a Fire and Rescue Service. The audit checks whether you are complying with your duties under the Order. The fire risk assessment is the document that proves you are. They are connected — an enforcement officer inspecting your premises will ask to see your assessment first — but they are carried out by different people for different reasons.
Who needs a fire risk assessment?
If you own, manage, or have control of any non-domestic premises, or the common parts of a building containing two or more domestic premises, you are legally required to have a current fire risk assessment. This covers employers, building owners, landlords, HMO managers, managing agents, and anyone else with control over the premises. The duty sits with the “Responsible Person” — and in bigger companies, that is often a director who does not realise they have the duty.
The Fire Safety Order defines the Responsible Person in Article 3. In workplaces, it is the employer. Where there is no employer, it is the person who has control of the premises in connection with a trade, business, or undertaking. In multi-occupancy buildings, there can be more than one Responsible Person — a landlord or managing agent with responsibility for the common parts, and individual businesses with responsibility for their own demised areas. The Order requires you to identify other Responsible Persons and cooperate with them.
In practice, the people we meet who are carrying the legal duty fall into three groups. The first is small business owners who know they are the Responsible Person because there is no one else. The second is HMO landlords and letting agents. The third — and this is where we see the biggest gap — is directors of larger businesses. A director of a limited company holds the Responsible Person duty automatically by virtue of their directorship and their control of the premises. But in our experience, many directors have never been told what that actually means in fire safety terms. The day-to-day management sits with a health and safety manager or a facilities manager, but the legal duty sits with the director. It is a surprisingly common gap, and it is one we try to close gently during the assessment itself.
The Order does not apply inside individual private dwellings — your own home, if it is a single-family house, is not covered. But it does apply to the common parts of HMOs, flats, and maisonettes. If your building is divided into more than one household, the shared hallways, stairwells, and landings are subject to the same duty as an office or a shop.
Since Section 156 of the Building Safety Act 2022 came into force on 1 October 2023, the recording requirement has tightened considerably. Previously, only Responsible Persons with five or more employees were required to record their assessment in full. That threshold has been removed. Every Responsible Person must now record the fire risk assessment in full, record the fire safety arrangements, and record the identity of anyone they appoint to help carry out or review the assessment. A sole trader running a small shop is now under exactly the same documentation requirement as a multi-site retailer.
What does the law require?
UK fire safety law imposes four core duties on the Responsible Person: carry out a suitable and sufficient fire risk assessment, record it in full, implement and maintain the fire safety measures it identifies, and review it whenever the premises or the risks change. Since October 2023, fines for non-compliance have risen from a maximum of £1,000 to unlimited amounts determined by the court.
The Regulatory Reform (Fire Safety) Order 2005
The Fire Safety Order (commonly called the RRO) is the principal fire safety legislation for England and Wales. It came into force on 1 October 2006, replacing more than seventy earlier pieces of fire legislation with a single, risk-based framework. Article 9 sets the duty to assess, Article 11 sets the duty to maintain fire safety arrangements, Article 13 requires appropriate firefighting equipment and detection, and Article 14 covers means of escape. Article 32 sets out the offences and penalties for failing to comply.
The Fire Safety Act 2021
The Fire Safety Act 2021 clarified that the external walls, flat entrance doors, and the structure of buildings are all covered by the Fire Safety Order and must be accounted for in fire risk assessments. This was a direct response to the Grenfell Tower fire and closed an ambiguity in how the Order applied to the building envelope of multi-occupied residential premises.
The Building Safety Act 2022, Section 156
Section 156 of the Building Safety Act 2022 amended the Fire Safety Order and came into force on 1 October 2023. It introduced four significant changes that every Responsible Person needs to understand.
First, the duty to record the assessment in full was extended to all Responsible Persons regardless of employee count or premises type. Previously, only businesses with five or more employees (or premises subject to licensing) had to record anything more than the “significant findings.” That threshold is gone. If you are a Responsible Person, you must now record the assessment in full.
Second, the identity of any person appointed to carry out or review the assessment must be recorded, along with their organisation where applicable. This creates a traceable record of who actually did the work — and a clear audit trail for enforcement officers, insurers, and future owners of the building.
Third, the Act introduced a future legal requirement that any person appointed to make or review the assessment must be competent. This specific provision has not yet been brought into force — the government has committed to publishing guidance and setting a commencement date in due course. In the meantime, current guidance from the Home Office and every Fire and Rescue Service strongly recommends that Responsible Persons satisfy themselves of an assessor’s competence before appointing them. The duty to ensure the assessment is suitable and sufficient remains with the Responsible Person regardless of who carries it out.
Fourth, the maximum fine for specified offences — including failing to provide a copy of the fire risk assessment when requested by an inspector — was raised from Level 3 (£1,000) to Level 5 (unlimited). Enforcement authorities have acted on the new powers: prosecutions related to fire safety violations rose by 79% year-on-year in the most recent published figures.
The Housing Act 2004 and HMO-specific duties
For HMOs, the Fire Safety Order sits alongside the Housing Act 2004 and the Housing Health and Safety Rating System (HHSRS). The Fire Safety Order applies to the common parts. The HHSRS applies to the individual rooms and considers fire as one of twenty-nine assessed hazards. Mandatory and additional HMO licence conditions add a third layer. Underpinning all of this is the LACORS Housing Fire Safety Guidance, published in 2008 — not legislation, but treated as the de facto benchmark by virtually every local housing authority and fire and rescue service in England. Councils such as Eastleigh Borough Council explicitly state that they use LACORS as the minimum standard that will be accepted for HMO fire safety.
HMO fire risk assessments sit under BS 9792:2025 — the current British Standard for housing fire risk assessments, published in August 2025 — alongside LACORS. The assessment methodology comes from BS 9792; the practical fire precaution standards that councils and fire services judge your premises against come from LACORS. A competent HMO fire risk assessor works across both. We go into more detail on the HMO side later in this guide and on our dedicated HMO fire risk assessment page.
How does a fire risk assessment work in practice?
A professional fire risk assessment follows the nine-step methodology set out in PAS 79-1:2020 (or BS 9792:2025 for housing). The steps cover everything from gathering information about the building and its occupants through to formulating a prioritised action plan and setting a review cycle. The on-site visit is typically two to three hours for a standard commercial premises. The written assessment takes considerably longer — often twice as long as the visit itself. A good report should read as a narrative of how the premises operates, not a checklist.
The Home Office publishes a simplified five-step checklist for Responsible Persons who feel competent to carry out their own assessment on the simplest types of premises. That checklist is a useful starting point for very small, low-risk operations, but it is not the methodology a professional fire risk assessor uses. PAS 79-1:2020 sets out nine steps, each of which requires professional judgement rather than a tick-box response.
The PAS 79-1 nine-step process
Step 1: Obtain information about the premises and their occupants. Before the site visit, we review any previous assessments, building plans, servicing certificates, EICRs, fire alarm and emergency lighting records, and fire door inspection reports. On site, we establish the building’s construction, use, occupancy patterns, and any processes that introduce fire risk.
Step 2: Identify fire hazards and the means for their elimination or control. We walk the premises from outside in, looking at ignition sources (electrical equipment, cooking appliances, heating, smoking areas, hot work), fuel sources (paper, textiles, furniture, waste, flammable liquids, stock), and anything that could allow fire to start or spread unexpectedly. This is where we often find things the Responsible Person has stopped noticing — daisy-chained extension leads running under desks, aerosol cans stored loose in workshops instead of in a flammable cabinet, lithium-ion batteries charging on carpet. The hazards are rarely exotic. The skill is in spotting the ordinary ones that have become invisible through familiarity.
Step 3: Assess the likelihood of fire. We evaluate how probable it is that the identified hazards could result in a fire, given the control measures currently in place.
Step 4: Assess fire protection measures. This covers detection and alarm systems, emergency lighting (coverage, condition, testing records), fire extinguishers (type, location, servicing), fire doors (condition, self-closing mechanisms, intumescent strips and smoke seals), compartmentation, signage, and means of escape.
Step 5: Assess fire safety management. We look at emergency plans, fire drill records, staff training, maintenance regimes, and the management structure for fire safety. This is where we test whether the plan has ever actually been tested under real conditions — or only when the building is empty.
Step 6: Assess the likely consequences of fire. Who would be affected, how quickly would a fire develop, and would the existing measures give people enough time to escape? This step requires professional judgement about fire development, smoke spread, and human behaviour — not a calculation a template can produce.
Step 7: Assess the overall fire risk. We bring together the likelihood of fire (Step 3) and the likely consequences (Step 6) to produce a qualitative risk rating, with clear reasoning that explains why the risk level is what it is.
Step 8: Formulate an action plan. The actions are prioritised by urgency and significance, with realistic timescales and clear ownership. The action plan is the part of the assessment that actually makes people safer — but only if it is acted on. Having an assessment is not the same as being compliant. You are compliant when the actions have been completed.
Step 9: Periodic review. Article 9(3) of the Fire Safety Order requires the assessment to be reviewed regularly, and specifically whenever there is reason to suspect it is no longer valid or after a significant change. We recommend a review at least every twelve months and a fresh assessment every three to five years.
A good fire risk assessment is a bit like assembling a puzzle: it is about understanding how the premises functions structurally, operationally, and against the relevant regulations, and then working out where the pieces do not fit as well as they should. The written report should tell a story. When an enforcement officer, an insurer, or a new Responsible Person reads your assessment in three years’ time, they should be able to understand the building, understand the risk, and understand the reasoning.
What counts as a “significant change”?
“Significant change” is broader than many Responsible Persons realise. Installing rooftop solar panels is a significant change. Changing the occupancy pattern is a significant change. Adding a mezzanine floor, converting a storage area to office use, introducing electric vehicle charging, or setting up lithium-ion battery charging stations for equipment — all significant changes that trigger a duty to review. If the premises, the people, or the processes have changed since your last assessment, the assessment needs reviewing.
How much does a fire risk assessment cost?
Fire risk assessments in the UK typically cost between £150 and £700 for small-to-medium commercial premises, with HMO assessments starting lower for simple shared houses. Our own prices start at £199 for small retail and small HMOs and rise to £649 for commercial premises up to 4,000 square metres. Pricing is driven primarily by building complexity, not floor area. If you are being offered an assessment at £45 or £90, something is missing.
Honest pricing is one of the reasons we started the business. The fire risk assessment market in the UK includes providers at every price point, from DIY templates at £25 to boutique consultancies charging four-figure sums for large complex premises. Understanding what actually drives the price helps you compare like with like.
What drives the price
Floor area is the easiest variable to price against, which is why most providers (including us) publish pricing bands based on square metres or room count. But floor area is a proxy for complexity, not the real driver. The things that genuinely affect the work involved are:
- Compartmentation — how the building is divided into fire-resisting zones and whether those zones can be judged reliably on a non-intrusive inspection. Cable and pipe penetrations through compartment walls are a common weak point.
- Sleeping risk — premises where people may be asleep require a fundamentally different escape analysis, including waking time, navigation in smoke, and protected routes that work in the dark.
- Protected route architecture — the stairwell and escape corridor that occupants rely on to reach a place of safety. In most premises, and especially HMOs, the protected staircase is the single point on which the entire escape plan depends.
- Occupancy pattern — a warehouse with ten employees is not the same job as a retail premises with 400 members of the public on a peak day, even at the same floor area. Reaction speed and crowd behaviour change the analysis completely.
- Specialist features — kitchen ductwork, solar PV systems, compressed gas storage, lithium-ion battery charging, hot work areas, and flammable substance storage all add layers that have to be assessed against the appropriate standards.
- Document review — previous assessments, servicing certificates, EICRs, fire alarm and emergency lighting records, and fire door inspection reports all need to be cross-checked against what is actually present on site.
A typical commercial site visit takes two to three hours. Writing the assessment up properly takes considerably longer — often twice as long as the visit itself. That is where the professional judgement happens: turning observations into a reasoned risk analysis, cross-checking findings against the relevant standards and legislation, and producing an action plan that is genuinely prioritised rather than a flat list of recommendations. If the written report does not reflect that level of thought, you have not had a proper fire risk assessment.
Why you should be suspicious of £45 and £90 fire risk assessments
At the bottom of the market, we see fire risk assessments advertised at £45, £90, and £150. The honest question to ask about these prices is this: what is the provider valuing their own knowledge and professional judgement at? A thorough assessment involves five or six hours of work when you include travel, site inspection, document review, and report writing. At £90, that is not even minimum wage — and that is before insurance, professional development, software, and overheads.
What tends to arrive is a templated report — often generated in part by an AI tool — with generic findings that do not reflect the specific building, a tick-box action plan, and no substantive risk reasoning. We have been called in to replace these after Fire and Rescue Service audits have rejected them, after insurers have refused to accept them, and after HMO licensing officers have served improvement notices. The saving is false. The replacement assessment costs the same as a proper one would have done in the first place, and the Responsible Person has lost time, money, and credibility.
A fair price for a small commercial premises or a small HMO in 2026 is in the £200 to £400 range. For larger or more complex premises, £400 to £700 is normal. Anything significantly below that warrants very careful questions about what you are actually getting. You can see our own pricing on our commercial fire risk assessment and HMO fire risk assessment pages — we publish it openly because transparent pricing is how we think this market should work.
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How do I choose a competent fire risk assessor?
Look for recognised qualifications (Level 3 FRA or above), membership of a professional body such as IFSM or IFE, appropriate experience for your premises type, full professional indemnity insurance, and a methodology based on PAS 79-1:2020 or BS 9792:2025. Ask for a redacted sample report. A good assessor will be clear about the type of premises they are competent to assess and will decline or refer work that falls outside their scope.
The National Fire Chiefs Council publishes guidance on finding a competent fire risk assessor, and Dorset & Wiltshire Fire and Rescue Service — which covers part of our service area — specifically recommends appointing an assessor with third-party accreditation by a professional body. The criteria below are what we would suggest any Responsible Person should check before appointing anyone, including us.
Qualifications and professional membership
At a minimum, expect a Level 3 Certificate in Fire Risk Assessment or equivalent. For more complex premises, Level 4 or Level 5 qualifications become appropriate. Look for membership of a recognised professional body — the Institute of Fire Safety Managers (IFSM), the Institution of Fire Engineers (IFE), or IOSH for the wider health and safety context. Third-party certification schemes such as BAFE SP205 provide an additional layer of independent verification.
The new BS 8674:2025 competence framework
In August 2025, the British Standards Institution published BS 8674:2025 — the first formal British Standard defining competence for individual fire risk assessors. It sets three tiers: Foundation (low-complexity premises such as small shops and small offices), Intermediate (moderate-complexity premises including hotels, shops, offices, small schools, apartment block common areas, and HMOs with standard layouts), and Advanced (complex or high-risk premises including care homes, large multi-occupancy residential, healthcare, and high-rise buildings).
BS 8674 is not yet law, but it is already being used by insurers, enforcement authorities, and certification bodies as the benchmark for “competent.” A well-run practice will be clear about which tier they are competent to work at and will not take on work above that tier. At Clear Fire Compliance, we work at the Foundation and Intermediate tiers — standard commercial premises up to around 4,000 square metres, and HMOs assessed under BS 9792:2025 (Type 1 and Type 3 non-intrusive methodology) with reference to LACORS guidance for practical fire precaution standards. We do not take on care homes, complex healthcare, large blocks of flats, or high-rise residential work, because those premises require Level 4 or Level 5 qualifications and a different methodology. When someone asks us to carry out work that falls outside our scope, we say so and refer them on. Scope discipline protects our clients, their premises and occupants, and us.
Experience in your type of premises
Qualifications set a floor. Experience in similar premises to yours is what makes the assessment useful. A competent assessor who has never walked a HMO should not be assessing yours; a specialist in HMO common parts may not be the right choice for a 3,000 square metre distribution warehouse. When you request a quote, ask how many similar premises the assessor has worked on recently and what typical findings they see.
Professional indemnity insurance
Any competent fire risk assessor should carry professional indemnity insurance appropriate to the value of the premises they assess. Ask for evidence. If they do not have it, or cannot show you the certificate, that is a red flag.
A sample report that tells a story
Ask for a redacted sample report before you appoint. A good report reads as a narrative. It describes how the premises is laid out, how it operates, where the hazards concentrate, who is at risk and why, how the existing measures perform against the relevant standards, what the residual risk rating is and why, and what actions will bring the risk down. If the sample is a tick-box document with no reasoning, you are looking at the work product of someone whose value proposition is low price rather than professional judgement.
What do we find on real jobs?
The deficiencies we identify most often on Hampshire and Dorset commercial and HMO assessments are rarely exotic. They are the familiar ones that have become invisible through daily use: uncontrolled electrical risks, unread servicing certificates, blocked or untested escape routes, emergency lighting that is missing, inadequate, or never tested in darkness, compartmentation failures at cable penetrations, and the growing set of risks introduced by lithium-ion batteries and rooftop solar.
Most fire risk assessment failings we find on site are not dramatic. They are the small, steady accumulations of ordinary use that no one is actively watching for. Here are the ones that come up on almost every job.
Electrical and charging risks
Daisy-chained extension leads are something we pick up on near enough every commercial job. Office desks become spaghetti. Workshop power boards get plugged into other power boards. Kitchen appliances share sockets with coffee machines and phone chargers. It looks harmless because it is normal, but overloaded sockets and chained extensions remain a significant cause of workplace electrical fires.
Lithium-ion battery charging is a rapidly growing concern, and one where best practice is evolving fast. UK fire services recorded approximately 1,330 lithium-ion battery fires in 2024 — a 93% increase over 2022, according to data compiled by QBE Insurance through Freedom of Information requests to forty-two fire services. E-bikes alone accounted for 362 fires, double the 2022 figure. The Office for Product Safety and Standards recorded 211 notified e-bike and e-scooter fires in 2024, resulting in 86 injuries and 8 fatalities. When a lithium-ion battery goes into thermal runaway, it burns at between 700°C and 1,000°C — hotter and faster than conventional fires, and almost impossible to extinguish once it has started.
For a fire risk assessment, this means looking at where staff charge phones, vapes, e-bikes, e-scooters, mobility scooters, power tools, and any other battery-powered equipment. It means asking whether there are charging policies, whether charging happens on or near combustibles, whether there is any building-wide restriction on where charging can happen, and whether staff have been made aware of the risks of counterfeit chargers and aftermarket conversion kits. This is an area where we expect practice to tighten significantly over the next few years.
Rooftop solar panels that trigger a review
Rooftop photovoltaic installations are a significant change under Article 9(3) of the Fire Safety Order, which means they trigger the duty to review the fire risk assessment. This is not widely understood by Responsible Persons, and in fairness, Approved Document B does not currently contain specific provisions for building-applied PV systems — a gap that RICS and major insurers have flagged publicly.
The real issue is that PV systems introduce new risks that the original assessment would not have considered. Panels generate their own electricity in any light, meaning parts of the system are always live — making firefighting considerably more difficult. The air gap between panels and the roof can create a stack effect that accelerates fire spread. PV inverters are a recognised ignition source, particularly when installed in combined plant rooms alongside gas meters and main electrical supplies without compartmentation. Insurers such as Zurich have published explicit guidance that a suitable and sufficient fire risk assessment should be carried out for all industrial, commercial, and domestic PV installations under the Fire Safety Order.
If you have had solar panels installed in the last three years and your fire risk assessment has not been updated since, you almost certainly have a live compliance gap.
Emergency lighting — internal and external
Internal emergency lighting tends to be in place, but we regularly find three problems with it. The first is servicing: monthly functional testing is either not being done, not being recorded, or being done by someone who does not know what a correct test result looks like. The second is coverage: the emergency lighting that is installed does not actually illuminate the full escape route. There are dark spots on corridors, at changes of direction, at fire exit doors, and at final exits that would leave people navigating blind in a power failure. The third is that emergency lighting is rarely tested in actual darkness. We almost always recommend that clients turn the mains lighting off and walk the escape route in the dark, under emergency lighting alone, to see what is actually covered. Clients never think about what darkness plus a smoke-filled room actually looks like until they try it.
The bigger gap, particularly across rural and semi-rural premises in Hampshire and Dorset, is external emergency lighting. Many premises have no external lighting at all once you leave the building. On a winter evening with no borrowed light from streetlamps, people evacuating a premises into a dark car park or yard are effectively walking blind. Very few assessments produced by non-specialist providers pick this up.
Servicing certificates that no one has read
Almost every commercial premises we visit has servicing certificates for fire extinguishers, fire alarms, and emergency lighting. Very few Responsible Persons have actually read them. The certificate says the extinguishers have been inspected — but does not say the type or rating of every unit. The fire alarm certificate carries an engineer’s additional notes recommending follow-up actions — which have not been read, let alone acted on. The EICR is in a folder on a shelf, but it carries an unsatisfactory status from three years ago and no remedial works have been completed. “Serviced” is not the same as “compliant.”
Compartmentation failures at service penetrations
Compartmentation is the passive fire protection that buys people time to escape. Walls, floors, and ceilings designed as fire-resisting barriers do their job — until a cable, a pipe, or a ductwork penetration passes through them without proper fire stopping. We find this most often in service cupboards, above suspended ceilings, and around kitchen extract ductwork. A small unsealed penetration turns a thirty-minute compartment into something considerably less useful. On a non-intrusive inspection we cannot open every void, so we flag the areas we cannot see and recommend intrusive follow-up where the risk warrants it.
Fire drills that have never been tested under real conditions
This one surprises people. Large retail and hospitality premises often have comprehensive fire drill records — but when we ask, the drills are always carried out before opening or after closing. The evacuation has never actually been tested with members of the public on site. If your drill has never been run with 200 customers in the building, you do not know how long evacuation will actually take, how many people will ignore the alarm, how the fire wardens will cope, or whether the final exits will be usable when people are trying to reach them under stress. An e-learning certificate is not the same thing as a tested evacuation plan.
Portable heaters, flammable storage, and the ordinary
The cost-of-living pressure has pushed many businesses and HMOs from gas heating to electric portable heaters, which get moved around, left unattended, placed next to cardboard or paper, and knocked over. Flammable aerosols and solvents are stored loose in workshops without flammable cabinets. Waste paper accumulates in exit routes. Wedged fire doors, blocked final exits, and broken emergency lighting made up more than 10,000 of the breaches recorded in English Fire and Rescue Service audits in 2024/25. These are the ordinary failings, and they are still the most common ones.
Why this work matters — a story from a recent assessment
The strongest argument for a thorough fire risk assessment is not a regulation. It is the realisation — usually quiet, usually on site — that if a fire did start on a particular day with particular people in the building, the existing arrangements would not be enough. A recent garden centre assessment we carried out is one we still think about.
The premises was a Hampshire garden centre with a main retail building, an attached warehouse, and a separate restaurant building. It was popular, well-run, well-loved locally, and the staff took fire safety seriously. It had all the right certificates. Everything looked fine on paper.
On a busy weekend the combined site could hold around 400 customers, with an average age somewhere between sixty and seventy-five. The restaurant had a new solar PV installation on the roof, with the kitchen extract ductwork running through the void directly beneath it. The plant room contained the main electrical supply, the gas meter, and the PV inverter — all together, with no compartmentation between them. Fire drills had been carried out diligently and recorded, but always when the site was closed. The evacuation had never been tested with a single customer in the building.
As we worked through the assessment, the picture built up piece by piece. The solar panels introduced an ignition source directly above the unprotected ductwork in the kitchen void. The combined plant room meant that a fire starting in any of three sources could compromise all of them. The open-field siting of the site meant that lightning was a credible low-probability ignition path for the rooftop electrical equipment. And the real complication was human: an older customer base, many of them seated with a cup of tea, some with mobility limitations, none of them expecting to be told to leave. How quickly would they actually move? Would they believe the alarm was real? How many fire wardens would be needed to move everyone through a single unrehearsed evacuation? How much time would the fire have to develop while people finished their drinks?
Writing the assessment, I kept coming back to the same question. If my own grandmother had gone to that garden centre to buy a potted plant and have a slice of cake, and a fire had started in the wrong place at the wrong time, what would I expect to be in place for her to get out safely? That is the test I apply to every assessment I carry out. It is a test you can apply yourself to any premises you are responsible for.
Is HMO fire risk assessment different?
Yes — and substantially so. HMO fire risk assessments sit under BS 9792:2025 and LACORS 2008 guidance rather than PAS 79-1, they use a Type 1 to Type 4 intrusiveness framework, and they have to account for sleeping risk, human behaviour dynamics that commercial premises do not have, and an enforcement regime that runs from two directions — the fire and rescue service and the local housing authority.
BS 9792:2025 was published by the British Standards Institution on 1 August 2025 and came into effect on 31 August 2025, replacing the withdrawn PAS 79-2:2020. It is the current British Standard for housing fire risk assessments and covers HMOs, blocks of flats, student accommodation, and specialised housing. It introduces a formal Type 1 to Type 4 framework that matches the depth of inspection to the risk profile of the building. Alongside BS 9792, the LACORS Housing Fire Safety Guidance (2008) remains the practical standard that local authority licensing teams and fire and rescue services use to judge whether the fire precautions in an HMO are proportionate to the risk. A good HMO fire risk assessment reads off both — the methodology comes from BS 9792, and the practical benchmarks come from LACORS.
At Clear Fire Compliance we carry out Type 1 and Type 3 HMO fire risk assessments — both non-intrusive. A Type 1 covers common parts only; a Type 3 covers common parts plus a sample of individual let rooms. We do not carry out Type 2 or Type 4 intrusive inspections, which require destructive opening-up work and a different competence profile. For older buildings with multiple extensions, former hotel conversions, or complex escape routes, we refer the work to assessors equipped for intrusive inspection.
The single most important feature of any HMO fire risk assessment is the protected staircase. In most HMOs the main staircase is the only route of escape from every upper floor. If the compartmentation between the staircase and the letting rooms fails — wedged fire doors, unsealed service penetrations, missing intumescent strips, door closers that have been removed because they are annoying — the entire escape plan fails with it. For a third-floor sleeper, the time budget to wake, recognise the alarm, leave their room, navigate a corridor possibly filling with smoke, descend two flights of stairs, and reach a final exit is tight enough without any of those failures. It is why we spend a disproportionate amount of time on fire door condition, compartmentation, and alarm coverage in HMO assessments.
HMO fire risk assessment also has to account for something commercial premises largely do not: the behaviour of people in their own living space. Occupants smoke, charge personal devices unsupervised, overload sockets in rooms the landlord rarely sees, leave flammables on windowsills, put candles near curtains, cook at odd hours with the smoke alarm temporarily disconnected. Some are strangers to each other; some are friends; the evacuation dynamics are completely different between those two cases. A good HMO fire risk assessment acknowledges that the landlord cannot control occupant behaviour, but it does evaluate whether the physical fire safety measures are robust enough to tolerate realistic behaviour.
HMO licensing and why fire risk assessments are now required with your application
Two of the largest councils in our service area now require a fire risk assessment as part of the HMO licence application — not as an afterthought, not on request, but as a standard documentation requirement.
Portsmouth City Council launched its Additional HMO Licensing Scheme on 1 September 2023, running until 31 August 2028. The scheme is city-wide and covers all HMOs with three or more occupants from two or more households. A fire risk assessment must be submitted with the application. If you do not have a current FRA at the time of application, Portsmouth will issue a one-year licence with a special condition requiring you to obtain one — and will not grant a full five-year licence until you have one in place.
Southampton City Council launched its Additional HMO Licensing Scheme on 1 October 2025, running until 30 September 2030. The scheme covers smaller HMOs (fewer than five occupants) and HMOs within purpose-built accommodation blocks in nine designated wards: Banister & Polygon, Bevois, Bargate, Portswood, Swaythling, Bassett, Freemantle, Shirley, and Millbrook. Those nine wards contain approximately 86% of all known HMOs in Southampton. A fire risk assessment is a required part of the licence application alongside gas safety, electrical safety, and floor plans.
Other councils in our service area — including Eastleigh Borough Council — require fire risk assessments for all HMOs under mandatory licensing and explicitly reference LACORS as their minimum standard. Whether or not your council has an additional licensing scheme in place, a fire risk assessment of the common parts of any HMO is a legal requirement under the Fire Safety Order. The additional licensing schemes simply mean that councils are now actively checking, rather than relying on self-declaration.
If you are an HMO landlord in Hampshire or Dorset and you do not currently have a fire risk assessment that meets the LACORS benchmark and BS 9792:2025, you have a live compliance gap — and if you are in Portsmouth or Southampton, that gap is also blocking your licence. We cover this in more detail on our HMO fire risk assessment service page.
How widespread are fire safety failures?
More widespread than most Responsible Persons realise. In 2024/25, English Fire and Rescue Services carried out 51,020 fire safety audits and only 58% returned a satisfactory outcome — the lowest rate in fourteen years. Missing or inadequate fire risk assessments were the third most common reason for audit failure, with 8,471 recorded breaches.
The national compliance picture, based on the most recent published figures from the Ministry of Housing, Communities and Local Government, is worth knowing before you take your own fire safety arrangements for granted. In the year ending March 2025, Fire and Rescue Services completed 51,020 fire safety audits. Only 29,714 of those — 58% — were judged satisfactory. That is the lowest satisfactory rate since March 2011.
The three most common reasons audits failed, drawn from the same published data, were breaches of emergency routes and exits (10,323 recorded instances), maintenance failures including untested alarms and non-operating fire doors (8,666), and inadequate or missing fire risk assessments (8,471). Houses converted to flats were the worst-performing premises category at 59% unsatisfactory. Purpose-built blocks of flats of four or more storeys were rated unsatisfactory in 45% of audits, and even high-rise buildings of ten storeys and above returned a 34% unsatisfactory rate.
The direction of travel on enforcement is equally clear. Formal enforcement notices rose to 2,823 in 2023/24 — the highest figure since 2013. Prosecutions for fire safety violations rose by 79% year-on-year. And since October 2023, the maximum fine for specified offences under the Fire Safety Order has been unlimited. The practical risk of being on the wrong side of a fire safety audit is higher now than it has been at any point in the last decade.
Bringing it together
A fire risk assessment is not a document you obtain to make a compliance officer go away. It is the one piece of work that forces you to look at your premises the way a fire would. It asks a direct and unsentimental question: if a fire started here tomorrow, with the people who are actually in the building tomorrow, would the arrangements you have in place be enough?
The legal framework — the Fire Safety Order, the Building Safety Act, the Housing Act, the current British Standards — is the scaffolding around that question. It is important scaffolding, and we have spent the last few thousand words walking through it. But the scaffolding is not the point. The point is whether the answer to the question is yes. And the uncomfortable truth is that for a significant proportion of non-domestic premises in England, the honest answer today would be no, or at best not quite.
That is fixable. A thorough fire risk assessment, carried out by someone competent for your type of premises, will identify what needs to change, prioritise it, and give you a defensible record of how fire safety is being managed. It will stand up to an enforcement officer, an insurer, a tribunal, and — if it ever comes to it — a fire investigation.
If you are a business owner, landlord, or managing agent in Hampshire, Dorset, Surrey, or West Sussex, and you are not sure whether your current fire risk assessment is fit for purpose, we can help. Our commercial fire risk assessments and HMO fire risk assessments are priced openly, carried out by a qualified assessor, and delivered as proper narrative reports rather than tick-box documents. You can see our scope and pricing on the service pages, or get in touch directly to talk about your premises.
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