Fire safety in HMOs: LACORS, alarm grades, and what an officer checks

Fire safety is where HMO enforcement is most active and where the requirements are least written down in one place. There is no single statute setting out "the fire standard for an HMO" — there are four overlapping regimes and one guidance document that everybody actually uses.

What actually binds you

1. The Housing Act 2004 and the HHSRS. Fire is Hazard 24. A council assesses it and can serve an improvement notice or a prohibition order on any HMO, licensed or not.
2. The management regulations. Regulation 4 of the 2006 Regulations puts a specific duty on the manager to maintain fire safety measures and keep escape routes free of obstruction. Breach is an offence under section 234(3). See the management regulations.
3. The Regulatory Reform (Fire Safety) Order 2005 applies to the common parts of an HMO and requires a fire risk assessment. It is enforced by the fire and rescue authority, not the council.
4. Licence conditions, where the property is licensed, which typically restate a specific alarm and door specification.

LACORS is the document to work from

"Housing – Fire Safety: Guidance on fire safety provisions for certain types of existing housing" — the LACORS guidance, published 2008 and still the working benchmark. It is not legislation. It is what councils and fire authorities use to decide what is reasonable, and demonstrating you followed it is the practical route to showing you met the duty.

It works by property type and risk, which is why generic advice fails: a two-storey shared house and a four-storey bedsit HMO get materially different answers.

Alarm grades and categories

This is the vocabulary officers use, from BS 5839-6, and getting it wrong is the most common specification error.

Grade describes the system’s engineering:

• Grade D — mains-powered detectors with battery backup. D1 has a tamper-proof standby supply, D2 a user-replaceable one.
• Grade A — a full fire alarm system with a control panel, sounders and detection, installed and maintained to BS 5839-1.

Category describes the coverage:

• LD3 — detection in escape routes only.
• LD2 — escape routes plus higher-risk rooms.
• LD1 — detection in all circulation spaces and all rooms where a fire might start.

A specification is a pair: Grade D1 LD2, Grade A LD2. LACORS maps property types to the pair. A typical two-storey shared house sits around Grade D LD3 with interlinked detection; larger or higher-risk bedsit-type HMOs move to Grade A. Take the grade and category from your council’s standards or a competent assessor, not from an article — including this one.

Note this is a different and higher requirement from the Smoke and Carbon Monoxide Alarm Regulations that apply to all rentals — see the 2022 amendment. Meeting those does not meet the HMO standard.

Fire doors

Generally FD30 — thirty minutes' resistance — to rooms opening onto the escape route, usually self-closing. What officers check is rarely the door leaf:

• Intumescent strips and cold smoke seals present and undamaged;
• the gap around the leaf, typically 2–4mm;
• the self-closer actually closing the door onto the latch from any angle;
• no wedges, and no closer disconnected because a tenant found it heavy;
• correct hinges, and glazing that is fire-rated where present.

A certified door that does not close is not a fire door. It is the single most common failure found on inspection.

Escape routes

Protected where LACORS requires it — fire-resisting construction to the route, doors as above, and nothing stored in it. Bicycles, boxes and prams in a hallway are a regulation 4 breach on their own. Final exit doors must open without a key from inside: thumb-turn locks, never a deadlock needing a key.

Emergency lighting and signage

Required where the escape route would be unusable in the dark, which in practice means most HMOs above two storeys and any with internal windowless corridors. Signage to LACORS where the route is not obvious.

What an officer actually checks, in order

1. Alarm system — present, correct grade and category, tested, with a log.
2. Fire doors — closing, sealed, undamaged, not wedged.
3. Escape route — clear, protected, final exit openable without a key.
4. Emergency lighting — present and tested where required.
5. Extinguishers and fire blankets where conditions require them, in date.
6. The fire risk assessment — current, and acted upon.
7. Records — the logbook is what turns all of the above from an assertion into evidence.

England and Wales

The Housing Act, HHSRS and the Fire Safety Order apply in both. LACORS is used in both. The management regulations are made separately for each country, and in Wales the fitness regime adds its own route — alarms are a condition of fitness there, so a failure makes the dwelling unfit as a matter of law. See fitness in Wales.

Information tool, not legal advice. Fire safety specification is property-specific — use a competent assessor and your council's standards.