RRFSO compliance for HMOs and student accommodation: what’s required and who’s responsible

If you’re a landlord, managing agent or accommodation provider, you’ll know that fire safety in shared housing comes with legal responsibilities. What is less clear is exactly which rules apply, especially for student halls.

In England and Wales, the Regulatory Reform (Fire Safety) Order 2005 (RRFSO) applies to the shared areas of HMOs and to student accommodation, including university halls that are exempt from HMO licensing. The Responsible Person must assess the fire risk, record it and put the right fire safety measures in place.

In this guide, we will clarify HMO licensing, explain who the Responsible Person is and what a fire risk assessment must cover, and explore where fire suppression systems fit alongside fire doors and alarms.

What does the RRFSO require?

The RRFSO applies to almost every building except private homes. In shared housing, it covers the areas residents share, such as hallways, stairs and communal kitchens. Since October 2023, every Responsible Person in England must record their full fire risk assessment, not just its key findings.

For these areas, the Responsible Person must:

• Carry out a suitable and sufficient fire risk assessment and record it in full.
• Put fire safety measures in place that the assessment identifies.
• Keep fire safety equipment, including alarms, emergency lighting and any suppression system, in good working order.
• Give residents clear information about fire risks and what to do in a fire.
• Review the assessment regularly, and whenever anything significant changes.

Since the Fire Safety Act 2021, the RRFSO also explicitly covers the structure, external walls and flat entrance doors of multi-occupied residential buildings. 

Does the RRFSO apply to student accommodation?

The Housing Act 2004 decides whether a building counts as an HMO and whether it needs a licence. 

Many halls managed by universities and colleges, and some student buildings run under approved codes of practice, are excluded from the HMO definition. However, as the RRFSO is fire safety law, it applies to any building that is not a private home, which includes student halls. 

Who is the Responsible Person?

The Responsible Person is usually the person or organisation that controls the building, such as the landlord, university or accommodation provider. A managing agent can also be a Responsible Person for the areas it controls under its contract.

Where more than one party has control, each one has legal duties, and they must work together and share information. We recommend writing down who is responsible for what, including who services the fire alarm, who checks fire doors and who looks after any suppression system.

What must a fire risk assessment cover?

For an HMO or student building, a fire risk assessor will look at:

• Fire hazards, such as cooking, electrical equipment, heaters and the charging of e-bikes and e-scooters.

• The people at risk, including residents who may be asleep, unfamiliar with the building or have a disability.

• Escape routes, and whether they are protected, kept clear and lead to a place of safety.

• Fire detection and warning systems.

• Emergency lighting and signage.

• Compartmentation, including fire doors, fire-stopping and separation between rooms and floors.

• Management and maintenance.

Escape routes, fire doors and compartmentation

In shared housing, a fire in one room puts everyone else at risk, so the building needs to hold back fire and smoke while residents get out. This relies on fire doors on rooms off the escape route, a fire alarm that warns everyone in the building, and fire-stopping that seals the gaps where pipes and cables pass through walls and floors.

Student accommodation also faces a growing modern risk: lithium-ion batteries in e-bikes and e-scooters charged in bedrooms and corridors. iMist was the first in the UK to test water mist fire suppression against a lithium-ion battery fire, using an electric bike.

Where does water mist fit in?

A fire suppression system doesn’t replace a fire alarm or protected escape route. Instead, it adds another layer of protection by controlling a fire in the room where it starts, keeping heat and smoke down and giving residents more time to escape.

Your fire risk assessment may recommend suppression where a protected escape route cannot be achieved without major alterations, in listed or heritage buildings where fire doors would affect historic features, or where large shared kitchens and open-plan cluster flats make compartmentation difficult.

Water mist is well suited to occupied shared buildings. It can be installed with minimal disruption, needs no stored water tank and uses up to 80% less water than traditional sprinklers, so a fire in one room will not flood the rooms below.

Once installed, the system becomes part of the fire safety measures the Responsible Person must maintain, so it’s important to book an annual service and keep your records up to date.

Speak to our team

Find out more about our work in HMOs, student accommodation and care homes.

If your fire risk assessment or fire report has recommended suppression, or you’re planning a conversion, get in touch using our free, no-obligation contact form and our specialist team will help you find the right solution.

Frequently asked questions

Does the RRFSO apply to HMOs?

In England and Wales, the RRFSO applies to the shared areas of a multi-occupancy house, such as hallways, stairs and communal kitchens. 

The landlord or manager is usually the Responsible Person and must carry out a fire risk assessment.

Do HMOs need sprinklers or a water mist system?

HMOs don’t need sprinklers or a water mist system by law, but they can be used to support fire safety measures if indicated by a fire risk assessment. 

Suppression is often recommended where a protected escape route can’t be achieved, or in larger and higher-risk buildings.

How often should a fire risk assessment be reviewed?

Fire risk assessments should be reviewed regularly, and whenever something significant changes, such as building work, a change in how the building is used or a fire. 

Many Responsible Persons choose to review their assessment every year.

What happens if a landlord does not comply with the RRFSO?

If a landlord or building manager doesn’t comply with the RRFSO, the local fire and rescue service can issue enforcement or prohibition notices. Serious offences can lead to unlimited fines and up to two years in prison.