HMO fire doors: what actually applies, and are surveys worth it?

Fire doors are where HMO landlords get the most conflicting advice. One contractor says the doors are fine, the next quotes four figures to replace them all, and somewhere in between a council officer asks for something neither of them mentioned.

Most of that confusion comes from one thing: landlords are being told about rules that do not apply to their building. So it is worth separating them properly before you spend anything.

The 11-metre line that catches people out

The Fire Safety (England) Regulations 2022 came into force on 23 January 2023 and are the source of the "quarterly fire door checks" you will have read about. The headline duties are:

• Buildings over 11 metres: the responsible person must check communal fire doors at least every three months, and make a best endeavour to check every flat entrance door annually.
• Buildings under 11 metres: those specific quarterly and annual duties do not apply.

Eleven metres is roughly a building of four or more storeys. A typical converted-house HMO is below it. So if you are being quoted for a quarterly fire door inspection regime on a three-storey terrace, ask which regulation it is being carried out under before you sign.

That does not mean nothing applies. It means a different set of rules applies.

Whichever rules apply, the house still has rooms to let and rent to collect. From £7.99 a month, LetCompliance gives each room its own rent and deposit, holds the HMO licence with reminders 90, 30 and 7 days before it expires, and keeps the fire risk assessment in the property's documents. Get started

What actually governs a normal HMO

For most HMOs the fire safety framework is three overlapping things:

• The Regulatory Reform (Fire Safety) Order 2005. It covers the common parts (hallways, stairs, shared kitchens). It requires a fire risk assessment, and it requires the fire safety measures to be kept in working order. Maintenance is a continuing duty, not an annual event.
• Your HMO licence conditions. A licensable HMO almost always carries fire safety conditions, and these vary by council. Read this document first, because it's the one you're actually judged against.
• LACORS fire safety guidance (2008). It isn't law, but it's the practical standard councils use to decide whether an HMO's fire precautions are adequate. If a council officer disagrees with your contractor, LACORS is usually the reason.

Behind all of it sits the council's hazard rating system (the Housing Health and Safety Rating System, or HHSRS). A council can act on a fire hazard whether or not a specific regulation names it.

What an HMO fire door has to be

The usual standard is an FD30 door: a doorset designed to hold back fire for 30 minutes. Landlords tend to focus on the leaf (the door itself) and forget that a fire door is a system. All of these matter:

• The door leaf itself, certified and undamaged. Holes drilled through it for old locks, or a leaf trimmed too far down to clear new carpet, can void its rating.
• Intumescent strips and, where required, cold smoke seals. The strips swell in heat to seal the gap. They're fitted into the leaf or frame and should be unpainted and unbroken.
• A self-closing device that actually closes the door onto the latch from any angle, not one that stops an inch short.
• Correct gaps: typically around 3mm at the sides and top. A gap you can see daylight through is the most common real-world failure.
• The frame and hinges: the right number of hinges, fire-rated, properly fixed. A perfect door in a weak frame is not a fire door.
• Nothing propping it open, unless it's on a compliant hold-open device linked to the alarm.

These doors normally sit on rooms that open onto the escape route: bedrooms, kitchens, and the route to the final exit.

Are fire door surveys reliable?

Honest answer: the quality varies enormously, and the price tells you very little.

There is no single licence a person must hold to inspect a fire door. Independent competence schemes do exist, and the ones councils recognise are the Fire Door Inspection Scheme (FDIS) and BM TRADA's Q-Mark inspector scheme. But plenty of "surveys" are carried out by people with no accreditation at all, and some are really a sales visit for a door replacement quote.

Before you book one, ask for:

• The inspector's accreditation, by name and number, not a company logo.
• What the report will contain. A photographed, door-by-door schedule with specific defects and remedial actions is useful. A pass/fail sheet with no evidence is not.
• Whether they also sell and fit the doors. Not automatically a problem, but a surveyor whose income depends on finding failures deserves a second opinion before a five-figure spend.
• Which standard they're assessing against: LACORS, your licence conditions, or the 2022 Regulations. If they can't answer, that is your answer.

A good survey is genuinely valuable: it gives you a dated, photographed record that a door was checked and what was found. That record is what protects you if there is ever a fire or a council inspection. A bad one is a PDF that proves nothing.

The check you can do yourself

None of this replaces a competent inspection, but you can catch most real-world failures in ten minutes per door:

1. 1Close it and look for daylight around the edges. Consistent, thin gaps are what you want.
2. 2Check the strips are present in the leaf or frame, continuous, and not painted over or torn out.
3. 3Open it fully and let go. It should close completely and latch. A door that rests against the frame is failing.
4. 4Look for damage: holes, deep gouges, a leaf that has been cut down.
5. 5Check the hinges are secure, with no missing screws.
6. 6Confirm nothing is holding it open: no wedges, no hooks, no "we only prop it in summer".

Photograph each door with the date. Doing this quarterly costs you nothing and builds exactly the evidence trail a survey would sell you.

Where landlords actually get caught

In practice the failures councils find are rarely exotic:

• Self-closers removed by tenants because the door slams, and never refitted.
• A new carpet fitted, the door trimmed to clear it, the gap now too large at the bottom.
• Strips painted over during a redecoration.
• A cheap "fire door" bought online with no certification evidence.
• A perfectly good door held open with a fire extinguisher.

Every one of those is cheap to fix and expensive to be found with.

Keeping the evidence

Fire safety is a continuing duty, which means the question is never only "is the door compliant today" but "can you show it has been maintained". Dated checks, photographs, the fire risk assessment, the alarm servicing record and any inspector's report belong together, per property.

LetCompliance, as HMO property management software, keeps that record per property. Your door checks go in as dated inspections with photos, and the fire risk assessment and any inspector's report sit in the property's documents. The HMO licence is tracked next to your gas, electrical and EPC dates, which get email reminders at 90, 30, 14, 7 and 1 days (and SMS on paid plans), and room-by-room rent and repairs live in the same place. When the council asks, it's a file you already have rather than a weekend of searching. Get started: your first property is free.

Sources

• legislation.gov.uk: The Fire Safety (England) Regulations 2022
• legislation.gov.uk: Regulatory Reform (Fire Safety) Order 2005
• GOV.UK: Fire safety in purpose-built blocks of flats and the 2022 Regulations
• LACORS: Housing – fire safety guidance (2008)
• GOV.UK: HMO licensing and standards