In short: a licensed HMO is a "relevant premises" under Part 3 of the Fire (Scotland) Act 2005, so the licence holder must carry out a fire risk assessment, act on it and keep it under review. Because a licence is required, the significant findings must be recorded in writing. Councils consider fire safety when deciding licence applications, and many ask for the assessment or a declaration that a competent person carried it out.
When a property is an HMO in Scotland
Under the Housing (Scotland) Act 2006, a property needs an HMO licence when it is occupied as their only or main residence by three or more people from three or more families, who share a toilet, washing or cooking facilities. Operating an HMO without the required licence is a criminal offence.
Ordinary private homes are not covered by Part 3 of the Fire (Scotland) Act 2005. Licensed HMOs are the exception. The Scottish Government's guidance explains that houses within the scope of HMO licensing are excluded from the definition of domestic premises, which makes them relevant premises with full fire safety duties.
What councils look for
Each council runs its own HMO licensing scheme, but fire safety comes up in every application. A licensing authority can take into account the level of fire safety in the HMO, the extent of compliance with the Fire (Scotland) Act 2005 and advice from the fire and rescue service, and may refuse a licence on that basis. Typical requests include:
The fire risk assessment
A copy submitted with the application, or a signed declaration that one has been carried out by a qualified and competent person.
Alarm certification
Installation and test certificates for the fire detection and alarm system.
Emergency lighting records
Where emergency lighting is fitted, evidence that it has been tested.
Fire doors and escape
Self-closing fire doors to rooms off the escape route, and an escape route that does not pass through a high-risk room.
Requirements differ between councils, and some publish their own HMO fire safety standards. Tell us which council you are applying to and we will make sure the report covers what they ask for.
What we check in an HMO
Our HMO assessments follow BS 9792:2025, the British Standard for fire risk assessment in housing, which replaced PAS 79-2:2020 in August 2025. Alongside the standard building checks, we pay particular attention to the issues that come up repeatedly in shared houses:
| Area | What we look for |
|---|---|
| Bedroom doors | Whether doors to bedrooms off the escape route are suitable fire doors, close fully on their own, and have not been fitted with locks that need a key to open from inside. |
| Kitchen | Heat detection, a fire door to the kitchen, whether the escape route passes through it, and whether a fire blanket is provided. |
| Detection | The type and coverage of smoke and heat detection, whether it is interlinked, and how it is tested. |
| Escape route | Whether the hall and stair are kept clear of bikes, furniture and storage, and whether there is a protected route to the outside. |
| Ignition sources | Overloaded sockets, extension leads, portable heaters, smoking, and e-bikes or e-scooters being charged in bedrooms or the hall. |
| Management | Tenant information on what to do in a fire, how faults are reported, and how often the landlord or agent checks the property. |
Common findings in Scottish HMOs
Most HMOs we see are fixable with modest, low-cost actions. The findings that come up most often are:
Fire doors that do not close
Self-closers removed, disconnected or adjusted so the door no longer latches.
Clutter in the escape route
Bikes, prams and recycling stored in the hall or common stair.
Charging in the wrong place
E-bike and e-scooter batteries charged overnight in bedrooms or hallways.
No testing record
Alarms that work but with no log to show they are tested.
Licence holder, agent and tenant duties
The fire safety duty sits with whoever has control of the premises to any extent, which usually means the licence holder and, depending on the management agreement, the letting agent. Tenants have a part to play too, which is why the report includes clear information for them on keeping fire doors shut, keeping the escape route clear and what to do if the alarm sounds.
Every home in Scotland, HMO or not, must also meet the Tolerable Standard for fire detection that came into force on 1 February 2022: interlinked, ceiling-mounted smoke alarms in the most-used living space and every circulation space on each storey, a heat alarm in every kitchen, and a carbon monoxide alarm where there is a carbon-fuelled appliance or flue. HMOs usually need more than this minimum, and the assessment will say what.
Frequently asked questions
Do I need a fire risk assessment for an HMO licence in Scotland?
Yes. A licensed HMO is a relevant premises under Part 3 of the Fire (Scotland) Act 2005, so a fire risk assessment is a legal requirement, and because a licence is needed the significant findings must be written down. Most councils ask for the assessment, or a declaration that one has been carried out by a competent person, as part of the application.
How much is an HMO fire risk assessment?
Our HMO assessments start from £225 + VAT for a typical HMO flat or small house. Larger HMOs, buildings with several HMO flats, and properties outside the central belt are quoted individually. Landlords and agents with several properties can ask for one quote covering the whole portfolio.
How often does an HMO fire risk assessment need to be reviewed?
It must be reviewed regularly and whenever there is a significant change, such as new tenants with different needs, building work, or an extra bedroom. Many licensing schemes expect an up-to-date assessment at each renewal. We recommend an annual review for most HMOs.
Can you assess an HMO before the licence application goes in?
Yes, and it is the best time to do it. An assessment before you apply gives you time to complete any actions, so the application is submitted with a clean report rather than an action list.
What standard do you use for HMOs?
BS 9792:2025, the British Standard code of practice for fire risk assessment in housing, together with the Scottish Government's Practical Fire Safety Guidance for Existing Premises with Sleeping Accommodation, which covers all types of HMO.
Sources
- Practical fire safety guidance for existing premises with sleeping accommodation, Scottish Government
- Practical fire safety guidance for existing specialised housing and similar premises, Scottish Government
- Fire safety, Shelter Scotland
- Fire detection in private rented properties: guidance, Scottish Government
- BS 9792:2025 Fire risk assessment. Housing, BSI
Written and reviewed by Raj Chall BSc, lead fire risk assessor at Fire Risk Scotland, listed on the Institution of Fire Engineers fire risk assessor register. Last reviewed 12 November 2026. This page is general guidance, not legal advice.