London landlords must have a working smoke alarm on every storey and a carbon monoxide alarm in any room with a fixed combustion appliance, and must keep gas and electrical safety checks up to date. HMOs and blocks of flats also need a written fire risk assessment, safe escape routes, maintained fire doors, fire alarms and emergency lighting. Buildings over 11 metres carry extra duties, including quarterly fire door checks in the common parts, and high-rise blocks need resident evacuation plans from April 2026.
The key laws are the Smoke and Carbon Monoxide Alarm (England) Regulations 2015 (amended 2022), the Regulatory Reform (Fire Safety) Order 2005, the Fire Safety Act 2021, the Fire Safety (England) Regulations 2022, the Building Safety Act 2022 and the Housing Act 2004. At the centre sits the “Responsible Person”, the person or organisation in control of the common parts, who must assess fire risks, put precautions in place and keep records. This guide explains what each rule means in practice, includes a landlord fire safety checklist, and draws on UpKeep UK’s work maintaining blocks of flats and rental properties across London.
What are the primary fire safety responsibilities for landlords under the Fire Safety Act 2021?
The Fire Safety Act 2021 clarifies that the Regulatory Reform (Fire Safety) Order 2005 applies to structural elements, external walls including cladding, and flat entrance doors in multi-occupied residential buildings. This means your fire risk assessment must now explicitly cover these elements, not just communal corridors and stairwells.
The Responsible Person must carry out a suitable and sufficient fire risk assessment and keep it updated whenever circumstances change. In practice, this means reviewing the assessment after any structural alteration, change in occupancy, or significant maintenance work. Leases often divide fire safety responsibilities between the demised premises and common parts, so you must map your control precisely to avoid compliance gaps, particularly where a managing agent or freeholder is also involved.
Your core maintenance obligations as a landlord include:
- Escape routes: All corridors, stairwells, and exits must remain unobstructed and clearly signed at all times.
- Fire doors: Doors must be inspected, maintained, and self-closing mechanisms kept in working order.
- Fire detection and alarm systems: Systems must be tested regularly and faults rectified without delay.
- Emergency lighting: Adequate lighting on escape routes must function independently of the main power supply.
- Firefighting equipment: Extinguishers and hose reels in communal areas must be serviced annually.
Non-compliance carries serious consequences, from remedial notices and civil penalties to prosecution, plus the cost of emergency remediation works carried out under an enforcement notice.
Pro Tip: Review your fire risk assessment every 12 months as a minimum, even if nothing has changed. Assessors and enforcement officers treat an undated or stale assessment as evidence of neglect, not compliance.
How do smoke and carbon monoxide alarm regulations affect landlords?
Private landlords in England must have at least one working smoke alarm on every storey used as living accommodation, and since 1 October 2022 a carbon monoxide alarm in any room with a fixed combustion appliance (such as a gas boiler or wood burner, but not a gas cooker). Since the same date, landlords must also repair or replace any alarm once told it is faulty. The rules apply to all tenancies.
The practical compliance steps are straightforward but must be followed in order:
- Install alarms before the tenancy begins. Smoke alarms on every habitable floor; CO alarms in every room with a fixed combustion appliance.
- Test all alarms on the first day of each new tenancy. This is a landlord obligation, not a tenant one.
- Repair or replace faulty alarms promptly. Once a tenant reports a fault, the landlord is responsible for rectifying it. Tenants are responsible for testing during the tenancy, but not for replacing units.
- Keep records. Document installation dates, test results, and any replacements with dates and model references.
Enforcement is carried out by local councils. If a council believes the rules have been breached it can serve a remedial notice, which the landlord must comply with within 28 days; failing to do so can lead to a civil penalty of up to £5,000. HMOs face additional licensing conditions and can be prosecuted under the Housing Act 2004.
Key figure: A single missed CO alarm in a room with a gas appliance is sufficient grounds for a formal enforcement notice. That one oversight can trigger a full property inspection covering every other compliance area.
Mains-wired, interlinked alarms are not legally required in most private rented properties, but they are strongly recommended by the London Fire Brigade for properties with three or more storeys. Battery-operated alarms with sealed, long-life batteries satisfy the legal minimum in most cases.
What are the fire door and communal area obligations for HMOs and blocks?
Fire door compliance is one of the most frequently cited failures in London inspections, and the rules depend on the building. Since 23 January 2023, the Fire Safety (England) Regulations 2022 require the Responsible Person in any building with two or more flats to give residents fire door information, and in buildings over 11 metres tall to check communal fire doors at least every three months and flat entrance doors at least once a year (using best endeavours to get access). Our fire door inspection checklist covers what to check.
| Building type | Fire door checks | Who is responsible |
|---|---|---|
| Communal fire doors, buildings over 11 metres | At least every three months | Responsible Person or managing agent |
| Flat entrance doors, buildings over 11 metres | At least every 12 months (best endeavours) | Responsible Person |
| Buildings with two or more flats (any height) | Fire door information to residents; checks as set by the fire risk assessment | Responsible Person |
| HMOs | Regular checks under the fire risk assessment and licence conditions, and at each change of occupier | Landlord |
For HMOs, fire door obligations go beyond inspection frequency. Every habitable room must have a fire-rated door with an intumescent strip and cold smoke seal. Self-closing devices must be fitted and functional. Propped-open fire doors are one of the most common causes of rapid fire spread in HMO properties and are treated as a serious breach during licensing inspections.
The Responsible Person role may be shared between a landlord and a managing agent in multi-occupied buildings, which creates a coordination challenge. Both parties must understand precisely which areas fall under their control. A written agreement setting out these boundaries is not a legal requirement, but it is the clearest way to prevent gaps.
Pro Tip: When commissioning a fire door inspection, use a third-party assessor certificated under the FDIS (Fire Door Inspection Scheme) or BRE scheme. Their reports carry significantly more weight with enforcement officers than a self-assessment.
What do the Building Safety Act 2022 and 2025 evacuation regulations require?
The Building Safety Act 2022 introduced the concept of the “golden thread,” a requirement for landlords of higher-risk buildings to maintain a digital record of building safety information throughout the building’s lifecycle. This includes fire risk assessments, maintenance records, structural drawings, and details of any changes to fire safety systems. The golden thread must be accurate, coherent, and continuously maintained so that it remains useful for both day-to-day management and emergency response.
Since 6 April 2026, the Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 apply to residential buildings that are at least 18 metres or seven storeys tall, and to buildings over 11 metres that have a simultaneous evacuation strategy. In those buildings the Responsible Person must:
- Make reasonable efforts to identify residents who may not be able to evacuate without help because of a disability or impairment.
- Offer those residents a person-centred fire risk assessment, and carry one out if they agree.
- Put reasonable and proportionate measures in place and agree a Residential Personal Emergency Evacuation Plan (RPEEP) with each resident.
- With the resident’s consent, share minimal information (flat number and the help likely to be needed) with the fire service via the building’s secure information box.
- Prepare a building evacuation plan, share it with the fire service and review plans at least every 12 months.
The consent and data-sharing requirements matter. Residents’ medical details should not be shared with the fire service, only the minimum information needed for firefighters, and only with explicit consent. Build the process into onboarding and annual reviews. Since 1 October 2023, all Responsible Persons must also record their full fire risk assessment in writing and share relevant fire safety information with residents.
| Regulation | In force | Applies to |
|---|---|---|
| Smoke and Carbon Monoxide Alarm (Amendment) Regulations 2022 | 1 October 2022 | All rented homes |
| Fire Safety Act 2021 | 16 May 2022 | Structure, external walls and flat entrance doors in multi-occupied residential buildings |
| Fire Safety (England) Regulations 2022 | 23 January 2023 | Buildings with two or more flats, with extra duties over 11 and 18 metres |
| Building Safety Act 2022 fire safety changes | 1 October 2023 | All Responsible Persons, plus higher-risk buildings over 18 metres or seven storeys |
| Residential Evacuation Plans Regulations 2025 | 6 April 2026 | Buildings 18 metres or seven storeys plus, and over 11 metres with simultaneous evacuation |
Landlord fire safety checklist
Use this as a quick annual check across your London properties:
- Smoke alarm on every storey and CO alarm in every room with a fixed combustion appliance, tested on the first day of each tenancy
- Annual gas safety check and an EICR at least every five years
- Fire risk assessment recorded in full for HMOs and the common parts of blocks, reviewed at least annually or after any change
- Escape routes clear, signed and free of stored items
- Fire doors self-closing, undamaged, with intact seals; checked at the required frequency
- Emergency lighting and fire alarm systems tested and serviced, with logbooks kept up to date
- Fire safety information given to residents and evacuation plans in place where required
- Records of every check, repair and replacement kept with dates and photos
What steps should landlords take after a fire risk assessment flags issues?
A fire risk assessment that identifies problems is not a liability. It is the starting point for demonstrating active compliance. The critical mistake most landlords make is filing the report and taking no further structured action.
Follow these steps to manage identified risks effectively:
- Create a prioritised action log. List every finding with a severity rating, a named responsible person, a completion deadline, and a column for close-out evidence. Link each action directly to the relevant section of the fire risk assessment.
- Address life-safety issues within 24 to 48 hours. Blocked escape routes, non-functional alarms, and failed fire doors are immediate risks. These cannot wait for a scheduled maintenance visit.
- Schedule medium-priority works within 30 days. Items such as damaged intumescent strips, missing signage, or faulty emergency lighting fall into this category.
- Document every repair. A robust audit trail links each finding to a named contractor, a completion date, and photographic evidence. This is what enforcement officers examine during inspections.
- Trigger a reassessment when major works are complete. The fire risk assessment must reflect the current state of the property, not the state it was in when the assessor visited.
Reviewing your landlord maintenance checklist alongside your action log helps prevent fire safety tasks from being absorbed into general property maintenance and losing their urgency.
Pro Tip: Set calendar reminders tied to your action log deadlines. Missed deadlines on a documented action log are treated by enforcement officers as evidence of wilful non-compliance, which carries heavier penalties than an undocumented oversight.
Key takeaways
London landlords face overlapping fire safety duties under multiple laws, and the Responsible Person who fails to document, maintain, and review compliance faces fines, prosecution, and enforcement notices.
| Point | Details |
|---|---|
| Fire risk assessment is mandatory | Every landlord must carry out a suitable and sufficient FRA under the 2005 Fire Safety Order and keep it updated. |
| Alarm installation has a legal standard | Smoke alarms on every storey and CO alarms in rooms with fixed combustion appliances (not gas cookers). |
| Fire door checks above 11 metres | Buildings over 11 metres need quarterly communal fire door checks and annual flat entrance door checks. |
| The golden thread applies to higher-risk buildings | Landlords of buildings over 18 metres must maintain a digital record of all building safety information. |
| Evacuation plans since April 2026 | In buildings 18 metres plus (or over 11 metres with simultaneous evacuation), residents needing help must be offered an assessment and evacuation plan. |
Fire safety compliance: what I have learned working with London landlords
I have worked alongside London landlords managing everything from single Victorian conversions to large purpose-built blocks, and the pattern I see most often is not ignorance of the law. It is a misunderstanding of where one person’s responsibility ends and another’s begins.
The dual responsibility problem in leasehold buildings is genuinely complex. A landlord may own the flat but not the building. The freeholder may own the structure but have appointed a managing agent. The managing agent may have subcontracted fire safety inspections to a third party. In that chain, it is entirely possible for fire door inspections to fall through the cracks because everyone assumed someone else had it covered. The Responsible Person framework exists precisely to prevent this, but it only works if every party maps their control area in writing.
What I find most encouraging about the 2025 RPEEP regulations is that they force landlords to think about residents as individuals, not just occupants. That shift in mindset, from building compliance to resident safety, is where the real value lies. A landlord who knows which tenants need evacuation assistance is also a landlord who is more likely to notice when something is wrong.
The enforcement trend in London is clear. Councils are prosecuting rather than warning, and the fines are increasing. The landlords who avoid trouble are not necessarily the ones with the newest properties. They are the ones with the best records.
Drahim Hasula, Founder & CEO, UpKeep UK
How UpKeep UK helps landlords stay fire safe across London
UpKeep UK helps landlords, managing agents and freeholders across London act on their fire risk assessments. Our NAPIT-approved electricians install and test smoke, heat and CO alarms, fire alarm systems and emergency lighting, and our team repairs and replaces fire doors, closers and seals, clears and makes good escape routes and carries out remedial works flagged by your assessor, all with photo-evidenced reports for your audit trail.
We can schedule recurring checks through our planned maintenance service, and our emergency repairs team responds within 1-3 hours when a fault can’t wait. We are Gas Safe registered, NAPIT approved, TrustMark endorsed and members of the Federation of Master Builders, with SafeContractor and SSIP accreditation. If your last fire risk assessment flagged actions you haven’t closed out, call 020 3148 8884 or request a quote. Day-to-day faults such as broken door closers or damaged seals can be booked through our reactive maintenance service.
Frequently asked questions
Do landlords need a fire risk assessment?
Yes. Under the Regulatory Reform (Fire Safety) Order 2005, every landlord of a non-domestic or multi-occupied residential building must carry out a suitable and sufficient fire risk assessment and keep it updated. Single-occupancy private lets are not exempt from general fire safety duties, but the formal FRA requirement applies primarily to HMOs, blocks of flats, and shared houses.
How often should fire doors be inspected?
In buildings over 11 metres, communal fire doors must be checked at least every three months and flat entrance doors at least once a year under the Fire Safety (England) Regulations 2022. In lower buildings and HMOs, follow the frequency set by your fire risk assessment, with six-monthly checks and a check at each change of occupier being sensible practice.
What are the fire safety rules for HMOs in London?
HMOs require fire-rated doors with intumescent strips and cold smoke seals on all habitable rooms, usually mains-wired, interlinked smoke alarms on every floor, CO alarms where applicable, clear escape routes, and an up-to-date fire risk assessment. HMO licences issued by London boroughs include fire safety conditions, and failure to meet them can result in licence revocation as well as prosecution.
What is the Responsible Person in fire safety law?
The Responsible Person is the individual or organisation with control over a building or part of a building, typically the landlord, freeholder, or managing agent. They are legally accountable for carrying out fire risk assessments, implementing precautions, and maintaining records. In multi-occupied buildings, the role may be shared, requiring a written agreement to define each party’s area of control.
When do the RPEEP regulations come into force?
The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 came into force on 6 April 2026. They apply to residential buildings at least 18 metres or seven storeys tall, and to buildings over 11 metres with a simultaneous evacuation strategy. Responsible Persons must offer residents who need help an assessment and evacuation plan, and review plans at least every 12 months.
