HMO fire safety in London: what licensing actually requires

Fire doors and escape routes in converted properties

Converted HMOs are frequently older buildings retrofitted for multi-occupation, which is where most fire door and compartmentation issues arise — original lath-and-plaster ceilings, timber stud partitions and old staircases were not built with 30-minute separation in mind, and decades of subsequent alterations by different owners have often quietly undermined whatever separation did exist. We regularly find bedroom doors that look like fire doors but have no certification, closers that have been removed because tenants found them inconvenient, and gaps around frames well outside tolerance.

• 30-minute (FD30) fire doors, self-closing, to all habitable rooms opening onto the common escape route.
• Fire doors to any high-risk room such as a kitchen shared between households.
• Escape route protected by fire-resisting construction where it passes through or alongside higher-risk rooms.
• A single external final exit door usable without a key from inside at all times.
• Emergency lighting on escape routes in larger or more complex HMOs, particularly where there are internal (borrowed light) routes.
• Intumescent strips and cold smoke seals present and undamaged around the full perimeter of every fire door.

What licensing officers actually check on inspection

Borough licensing officers carry out physical inspections as part of both mandatory licensing (five or more people, two or more households sharing facilities) and additional or selective licensing schemes that many London boroughs now run, which can pull in smaller properties that would not otherwise need a licence. An officer's visit is not a paperwork exercise; they walk the building the same way an assessor does, testing doors, checking alarm panels and looking for evidence of what is actually happening day to day rather than what is written down.

• Alarm system category and evidence of servicing and testing, usually via a logbook kept on site.
• Fire door condition, closers, seals and any unauthorised alterations to doors or frames.
• Escape route clearance and final exit door operation, tested by hand where possible.
• Kitchen facilities relative to occupant numbers (often a separate amenity standard, but frequently inspected at the same visit).
• General management standards, including whether a written fire risk assessment for the specific property exists and is current.
• Electrical safety certificate (EICR) and gas safety certificate where applicable, since both link directly to ignition risk.

Common reasons HMO licence applications stall on fire safety

In practice a small number of issues account for most delays and licence conditions attached by boroughs, and nearly all of them are things a landlord could have fixed before the inspection with a modest amount of preparation and cost. We see the same handful of problems repeatedly across very different boroughs and property types.

• Alarm system installed to a domestic (Grade F, battery-only) standard rather than the LD2 mains-wired standard expected for shared housing.
• Bedroom doors that are not fire-rated, or fire-rated doors without a functioning self-closer.
• Kitchen doors missing entirely where the kitchen opens directly onto the escape route.
• No written, property-specific fire risk assessment — a generic template for a different building is not sufficient.
• Storage or clutter in the means of escape at the time of inspection, from bikes to bins to boxed deliveries.
• Loft or basement conversions used for sleeping accommodation without the corresponding upgrade to alarm coverage and escape provision.

Additional and selective licensing across London boroughs

Many London boroughs run additional licensing schemes covering smaller HMOs that fall below the mandatory five-person threshold, and some run selective licensing across entire wards covering any rented property regardless of occupancy type. The fire safety standard expected under these schemes is broadly similar to mandatory licensing, but the thresholds and specific conditions vary noticeably between boroughs — a property just over a borough boundary can face a materially different set of requirements. Landlords with portfolios spanning more than one borough should never assume the conditions that applied in one authority automatically transfer to another.

How this interacts with the wider Fire Safety Order duties

Meeting borough licensing conditions and complying with the Fire Safety Order are related but not identical exercises — a property can technically meet licensing conditions at the point of inspection and still need updates to its fire risk assessment following a change of occupancy, added tenants, or a change in furniture and layout that happens months later. Licensing is periodic; the Fire Safety Order duty is continuous. Landlords running licensed HMOs should treat the licence conditions as a floor, and keep the fire risk assessment itself under regular review as the primary ongoing compliance document, updated whenever the property or its occupants change materially rather than only when a licence comes up for renewal.

What we recommend before applying or renewing

The most efficient route for most landlords is to commission a property-specific fire risk assessment before submitting or renewing a licence application, rather than waiting for the licensing officer's visit to surface problems. An assessment carried out by someone who understands both the Fire Safety Order and LACORS-based licensing expectations will flag alarm category mismatches, door defects and layout concerns in a single visit, with a prioritised action list that distinguishes urgent fixes from longer-term improvements — which is far cheaper than a failed inspection, a delayed licence, or a licence granted with conditions that then need re-inspecting.