If you’re a landlord, letting agent, or property manager in Surrey — whether that’s in Guildford, Woking, Epsom, Camberley, or Reigate — there’s one question that comes up again and again:
“Do I legally need a Fire Risk Assessment for my flats or HMO?”
The short answer is yes.
The long answer is absolutely yes — and the law couldn’t be clearer about it.
What the Law Actually Says
The key piece of legislation is the Regulatory Reform (Fire Safety) Order 2005 — usually just called the Fire Safety Order.
It applies to all non-domestic areas and the communal parts of residential buildings.
That means if you own or manage:
• A block of flats
• A converted house with multiple tenants (HMO)
• Any building with shared corridors, stairwells, plant rooms, bin stores, or entrances
…you are legally required to have a Fire Risk Assessment (FRA) in place for those shared areas.
It doesn’t matter if you only have a couple of tenants.
It doesn’t matter if the building was converted years ago.
And it doesn’t matter if your council hasn’t been round yet.
If people live there and share access routes, the law applies to you.
You can read the local guidance on Surrey Fire & Rescue’s Business Safety page.
Why HMOs and Flats Are Different
Houses in Multiple Occupation (HMOs) and flats bring their own challenges. You’ve got different people living under one roof — often strangers — with different routines, habits, and fire risks.
Someone’s cooking late, someone’s smoking on the balcony, someone else has an e-scooter charging in the hallway.
It’s a cocktail of risk.
That’s why the law expects landlords and managing agents to take extra care. A good Fire Risk Assessment looks at:
• Escape routes — are they protected, signed, and clear?
• Fire doors — do they close and seal properly?
• Alarms and detectors — are they the right grade and type?
• Emergency lighting — is it tested and maintained?
• Compartmentation — are walls and floors properly fire-stopped?
• Tenant information — do residents know what to do if there’s a fire?
The Fire Safety Act 2021 — What Changed
Before 2021, many landlords assumed their Fire Risk Assessment only needed to cover communal areas.
That changed with the Fire Safety Act 2021.
Now, the FRA must also include:
• The structure and external walls of the building, including balconies and cladding.
• Flat entrance doors that open onto communal areas.
In short: you can’t ignore what’s behind the front door anymore.
If you manage or own flats in Surrey, you’re legally responsible for making sure those elements are inspected and included in your assessment.
This is especially important if your property has external wall systems or older fire doors — both are common in conversions and older blocks.
The Fire Safety (England) Regulations 2022 — Even More to Know
From January 2023, the Fire Safety (England) Regulations 2022 added new duties for landlords and managing agents.
If your building is:
- Over 11 metres high, you must check flat entrance doors at least once a year.
- Over 18 metres (high-rise), you must:
• Provide residents with fire safety instructions and evacuation information.
• Install and maintain wayfinding signage for firefighters.
• Share digital floor plans and building information with your local fire service.
These rules are now being actively enforced — and Surrey Fire & Rescue is already inspecting buildings to make sure they’re being followed.
What Happens If You Don’t Have a Fire Risk Assessment
Failing to comply isn’t just risky — it’s criminal.
If you don’t have a current FRA, or it’s incomplete, you could face:
• Enforcement notices requiring immediate action
• Hefty fines — often running into thousands
• Prosecution if negligence puts people at risk
And if there’s a fire?
You’ll be held responsible for any injury, death, or damage if you can’t show that you’ve taken proper precautions.
Your insurance company could also refuse to pay out — leaving you with the full cost of repairs.
How to Stay Compliant in Surrey
To stay on the right side of the law, make sure:
✅ Your Fire Risk Assessment is carried out by a competent, qualified assessor
✅ It includes communal areas, doors, and external walls
✅ You review it every 12 months or after any significant changes
✅ You keep written records and maintenance logs
✅ You provide clear fire safety information to your tenants
Getting It Right
At Fire Risk Assessment Surrey, we help landlords and managing agents across Guildford, Woking, Camberley, Farnham, and Epsom stay compliant and confident.
We carry out detailed, BS 9991-compliant assessments that meet the latest legislation — covering everything from fire doors and alarms to external walls and evacuation plans.
If you manage flats or HMOs in Surrey and aren’t sure your Fire Risk Assessment covers what it should, now’s the time to check.
Book your Fire Risk Assessment in Surrey today — and protect your tenants, your property, and yourself.
