RRO 2005 compliance — London
Regulatory Reform (Fire Safety) Order 2005 compliance checks for London properties
Full RRO 2005 compliance audits covering fire risk assessment, fire doors, compartmentation, emergency lighting, and alarm systems. Written reports with photographic evidence for HMOs, blocks of flats, and commercial premises across all 33 London boroughs.
The legislation
What is the Regulatory Reform (Fire Safety) Order 2005?
The Regulatory Reform (Fire Safety) Order 2005 — commonly called the RRO or the Fire Safety Order — is the primary fire safety legislation for non-domestic premises and the common parts of residential buildings in England and Wales. It came into force on 1 October 2006 and replaced more than 70 separate pieces of fire safety legislation, consolidating them into a single, risk-based framework.
The central concept of the RRO is the "responsible person" — the person on whom all fire safety duties rest. The responsible person must carry out a fire risk assessment, implement the preventive and protective measures identified by that assessment, and keep the assessment under review. The RRO is explicitly non-prescriptive: it does not mandate a specific type of detector or a specific number of extinguishers. It requires the responsible person to take measures proportionate to the risk.
For London property owners and managers, the RRO is the legal framework that underpins every HMO licence fire safety condition, every block of flats communal area fire safety obligation, and every commercial tenancy fire safety requirement. Compliance is enforced primarily by the London Fire Brigade, with additional oversight from local authority housing teams for licensed HMOs.
Who it applies to
Which London premises does the RRO cover?
The RRO applies to virtually all non-domestic premises and to the common parts of multi-occupied residential buildings. In the London context, this includes:
- Common parts of HMOs — staircase, hallways, shared kitchen and bathroom
- Communal areas of purpose-built or converted blocks of flats
- Commercial premises: offices, retail units, workshops, warehouses
- Licensed premises: pubs, restaurants, hotels, takeaways
- Schools, places of worship, community halls, and sports facilities
- Care homes and supported living premises
- Any premises with employees, even if the building is also residential
The interior of a self-contained dwelling let to a single household is not covered by the RRO. However, the moment a property has shared facilities or shared access — the definition of an HMO — the RRO applies to those shared elements, and the landlord becomes the responsible person.
Key duties
The six Articles that drive every RRO compliance audit
The RRO contains 52 articles and five schedules. For most London HMO landlords and property managers, the following six articles are where compliance is won or lost.
Fire risk assessment
Mandatory written assessment for premises with 5+ employees or that are licensed or an HMO. Must identify hazards, evaluate risks, record significant findings, and specify protective measures. Review required after any significant change.
Fire-fighting equipment and detection
Premises must be equipped with appropriate fire-fighting equipment (extinguishers, hose reels) and fire detection or warning systems. Equipment must be maintained and employees trained in its use.
Emergency routes and exits
Escape routes must be kept clear, signed with illuminated or photoluminescent signage, and lead as directly as possible to a place of safety. Doors on escape routes must open in the direction of escape and must not be secured in a way that prevents immediate use.
Emergency procedures
A written evacuation plan must be in place. Where appropriate to the risk, fire drills must be conducted and recorded. Procedures must cover the action to be taken in the event of fire, including who calls the fire brigade and how occupants assemble.
Maintenance
All fire safety measures — fire doors, emergency lighting, alarm systems, extinguishers, sprinkler systems — must be maintained in efficient working order and in good repair. Servicing records must be kept and available for inspection.
Safety assistance
The responsible person must appoint one or more competent persons to assist with fire safety measures. A competent person is one with sufficient training, experience, knowledge, and other qualities to implement the measures required.
Our service
What a full RRO compliance check covers
A single audit visit covering every fire safety element required by the RRO and by London borough HMO licensing conditions. Every finding is documented with photographs, and the final report includes a prioritised remediation schedule referenced against the relevant RRO article.
Fire risk assessment
Review or carry out a full Article 9 fire risk assessment if none exists or the existing assessment is out of date. Full written report with photographic evidence and prioritised remediation schedule.
Fire door inspection
All bedroom, kitchen, and common area doors inspected against FD30S specification: self-closer fitted and adjusted, intumescent strip and cold smoke seal present and continuous, correct gap tolerance (3mm maximum), door closes fully against the frame under its own closer.
Emergency lighting (BS 5266)
Test and document all emergency luminaires to BS 5266-1. Functional discharge test for minimum 3-hour duration. Check coverage of all escape routes, final exit doors, and staircase enclosures. Identify any circuits or zones with deficient coverage.
Fire alarm and detection (BS 5839)
Full site audit of the alarm and detection system: panel inspection, detector placement against BS 5839-1 or BS 5839-6 Grade D, battery condition on interlinked mains-and-battery units, fault log review, last service date.
Fire extinguisher positions
Check number, type, rating, and location of extinguishers against the fire risk assessment. Inspect service labels — annual service and 5-year discharge service dates. Identify missing, expired, or incorrectly located units.
Means of escape
Walk every escape route from every habitable room to final exit. Check for obstructions, locked doors, inadequate headroom, missing signage, and adequate artificial and emergency lighting throughout. Measure travel distances against Approved Document B limits.
Compartmentation survey
Inspect party walls, floor/ceiling assemblies, and staircase enclosures for unintumesced penetrations from services, converted voids, and historical building works. Identify every breach requiring intumescent mastic, pipe collar, or pillow.
Evacuation plan and procedures
Review or produce a written evacuation plan per Article 15. Check that fire action notices are posted at alarm call points. Confirm a log of fire drills is in place where required.
The most commonly failed element
Compartmentation failures in London period conversions
London's housing stock is dominated by Victorian and Edwardian terraces built between 1870 and 1914 — solid brick party walls, timber joist floors, and staircase enclosures originally designed as open features of a single-family home. Decades of piecemeal conversion to HMOs, the addition of en-suite bathrooms, re-routing of heating pipework, and installation of electrical wiring through floor voids have systematically compromised the fire-resisting integrity of these structures.
A 15mm gap around a waste pipe passing through a party wall is enough for hot gases and flame to bypass a fire door rated at 30 minutes and spread a fire into an adjacent tenancy or the staircase enclosure. A chase cut into a staircase wall for a new cable run, left unintumesced after the conduit was installed, does the same. These penetrations are invisible to a casual inspection — they are inside the wall or below the floor — but they render the fire-resisting construction worthless.
Remediation is straightforward when identified: intumescent mastic applied around small pipe penetrations, proprietary pipe collars on larger waste and soil pipes, intumescent pillows or boards in larger voids. The critical step is finding every penetration — which requires a methodical survey of every party wall, floor/ceiling assembly, and staircase enclosure in the building.
Fire door compliance
FD30S: what every HMO fire door must have
The standard fire door specified in London HMO licensing conditions and by the RRO fire risk assessment guidance for HMOs is an FD30S door — a door assembly providing 30 minutes of fire resistance (FD30) with a smoke seal (S). This applies to every bedroom door, kitchen door, and any door opening onto the protected staircase.
A fire door is only as effective as its installation and maintenance. In practice, the most common defects found during RRO audits in London HMOs are: missing or disconnected door closers (doors propped open or left to drift), intumescent strips that have been painted over and no longer expand, cold smoke seals absent from one or both faces of the door leaf, and gaps at the head, sides, or bottom of the door frame exceeding the 3mm tolerance required by BS 8214.
A fire door that does not close fully against its frame under the action of its own closer provides no meaningful fire resistance. The closer is therefore the most critical single component — and the most commonly failed one in residential conversions where tenants remove them for convenience.
Enforcement
London Fire Brigade inspection powers and penalties
The London Fire Brigade is the enforcing authority for the RRO across Greater London. LFB fire safety inspectors have the power to enter and inspect any premises covered by the RRO at any reasonable time, without prior notice. They can require the responsible person to produce the fire risk assessment and all maintenance records on demand.
Where an inspection reveals significant non-compliance, the LFB can serve one of two notices. An Improvement Notice specifies the contraventions found and the steps required to remedy them, with a time limit — typically 28 days for serious defects and up to six months for complex remediation. The responsible person can appeal to the First-tier Tribunal, but the notice remains in force during the appeal unless the tribunal suspends it.
A Prohibition Notice is reserved for situations where the LFB inspector concludes that there is a risk of death or serious injury if the premises continue to be used. A Prohibition Notice can prohibit or restrict the use of the premises immediately, without the 28-day improvement period. In the context of a residential HMO, this means tenants must vacate. The responsible person can apply to have the notice lifted once the identified deficiencies are remediated and re-inspected.
The RRO provides for unlimited fines on conviction in the Crown Court, and imprisonment for the most serious offences. The sentencing guidelines published by the Sentencing Council categorise contraventions by culpability and harm, with the highest culpability/harm combination attracting fines calculated as a percentage of organisational turnover for companies, and custodial sentences for individuals.
In the London context, HMO landlords face a compounding risk: a Prohibition Notice from the LFB is likely to trigger parallel action by the housing authority under the Housing Act 2004. A landlord who cannot produce a current fire risk assessment during an HMO licence renewal may have their licence refused or revoked.
HMO licensing in London
Fire risk assessment as a standard HMO licence condition in all 33 boroughs
Every London borough operates an HMO licensing scheme — either mandatory licensing under the Housing Act 2004 for HMOs of three or more storeys with five or more occupants, or additional licensing schemes that extend coverage to smaller HMOs. Several boroughs — including Newham, Waltham Forest, and Southwark — operate selective licensing schemes covering a majority of privately rented homes in defined areas.
A current fire risk assessment, carried out by a competent person and covering the common parts and any shared facilities, is a standard licence condition in all 33 London borough HMO licensing frameworks. The assessment must be produced on request to the licensing officer. Where a licence application is made without a current risk assessment — or where an existing licence is renewed and the assessment pre-dates the last material change to the property — the licensing authority may impose an additional licence condition requiring remediation, or refuse the application.
Beyond the risk assessment itself, licence conditions typically require specific physical fire safety measures: FD30S fire doors to all bedrooms and the kitchen, Grade D Category LD2 interlinked mains-and-battery smoke and heat alarms, emergency lighting on escape routes in larger HMOs, and fire extinguishers or fire blankets in the kitchen. Our RRO compliance audit checks all of these against the conditions typically applied by London borough councils.
Emergency lighting and alarm systems
BS 5266 and BS 5839 compliance for London HMOs
Emergency lighting to BS 5266 is required wherever there is a risk that the normal lighting supply could fail and leave occupants unable to navigate the escape route in darkness. In practice, for an HMO with a protected staircase and more than two storeys, emergency lighting is invariably required. BS 5266-1 specifies a minimum maintained illuminance of 1 lux along the centre line of the escape route and a 3-hour rated discharge duration.
Fire alarm and detection systems for residential premises are governed by BS 5839-6. The standard grades fire alarm systems from Grade A (a fully addressable professionally installed panel system) to Grade F (a single battery-only alarm). For London HMOs, the minimum typically required is Grade D Category LD2 — mains- powered interlinked alarms with battery backup, providing detection in all circulation areas (corridors, landings, staircase) and in rooms that open directly onto the escape route (kitchens).
Our RRO audit tests emergency luminaires under load, checks interlinked alarm operation and interconnection, and reviews the alarm layout against BS 5839-6 detector placement rules — identifying any zones with inadequate coverage before the LFB or licensing officer does.
2025 pricing — London
RRO compliance audit costs in London
All prices below are London market rates and include the audit visit, written report with photographic evidence, and prioritised remediation schedule. Remediation works are quoted separately before any work proceeds.
RRO compliance audit — small HMO (up to 6 beds)
£300 – £400
Full Article 9 fire risk assessment, fire door inspection, means of escape check, extinguisher audit, alarm and emergency lighting review. Written report with photographic evidence and prioritised remediation schedule.
RRO compliance audit — larger HMO or block of flats
£400 – £600
7–20 bed HMOs or blocks of up to 12 flats. Same scope as above with full compartmentation survey of all common areas. Pricing reflects increased floor area and complexity.
Fire door survey (standalone)
£150 – £300
Stand-alone fire door inspection report for all fire doors in the property. Useful as a standalone instruction from a managing agent or where only the door element is in dispute.
Compartmentation remediation (per penetration)
£80 – £200
Supply and application of intumescent mastic, pipe collar, or fire pillow to seal a single penetration in a fire-resisting element. Price reflects penetration size and access difficulty. London rates.
All prices include VAT. A firm price is confirmed when the scope is established — property size, number of floors, number of fire doors, and whether a full compartmentation survey is required. Same-day and next-day audit appointments are available across London.
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Book your RRO 2005 compliance audit across London
Experienced fire safety auditors covering all 33 London boroughs. Written report with photographic evidence delivered within five working days. Remediation works quoted from the same visit. Reports accepted by London borough HMO licensing teams and the London Fire Brigade.
Common questions
RRO 2005 compliance: frequently asked questions
Does the RRO 2005 apply to a residential landlord in London?
Yes — but only to the parts of the building that are not exclusively within a single domestic dwelling. If you let a house as a single tenancy, the RRO does not apply to the interior of that dwelling. However, if you let an HMO — where tenants share facilities such as a kitchen or bathroom — the common parts of that HMO fall under the RRO and you are the responsible person. Similarly, if you own a block of flats, the communal staircase, corridors, bin stores, and any shared plant rooms are covered by the RRO. Every London borough HMO licensing regime lists a current fire risk assessment as a standard licence condition, so practical enforcement exists at the licensing stage well before the London Fire Brigade inspects.
What is a "responsible person" under the RRO 2005?
The RRO defines the "responsible person" as: the employer, if the premises are a workplace; the person who has control of the premises in connection with carrying on a trade, business, or undertaking; or the owner, where no one else has control. In practice, for a London landlord-owned HMO this means the landlord. For a block of flats managed by a managing agent, it can be the managing agent and the freeholder jointly. Responsibility cannot be contractually transferred to a tenant. Where multiple persons share responsibility, they are required to co-operate and co-ordinate their fire safety arrangements under Article 22 of the RRO.
What happens if my London HMO fails an RRO inspection by the London Fire Brigade?
The London Fire Brigade (LFB) has significant enforcement powers under the RRO. If an inspector finds serious deficiencies — blocked escape routes, inadequate fire doors, a fire risk assessment that is absent, out of date, or not acted upon — they can issue an Improvement Notice specifying remediation required within a defined period, typically 28 days for serious matters. Where a risk of death or serious injury is identified as imminent, the LFB can issue a Prohibition Notice closing all or part of the premises immediately — effectively making the property unlettable until the notice is lifted. For HMOs, a Prohibition Notice can also trigger revocation of an HMO licence. Unlimited fines apply for non-compliance and, in serious cases, prosecution with the possibility of imprisonment. The LFB carried out over 3,000 audits of higher-risk premises in London in 2023 and has increased its focus on private rented sector properties following the Grenfell Tower inquiry recommendations.
How often must a fire risk assessment be reviewed under the RRO 2005?
Article 9 of the RRO requires the responsible person to review the fire risk assessment regularly to keep it up to date, and specifically after any significant change to the premises, occupancy, activities, or fire safety measures. "Regularly" is not defined by a specific interval in the legislation, but accepted practice and LFB guidance is that an HMO risk assessment should be reviewed at least annually and whenever there is a material change — a new tenant, a change in use of a room, refurbishment work, replacement of the fire alarm system, or following a fire or near-miss incident. Where the responsible person employs five or more people or the premises are licensed, the significant findings of the assessment and any group of persons identified as being especially at risk must be recorded in writing.
What is compartmentation and why does it matter in a London conversion?
Compartmentation is the principle of dividing a building into fire-resisting compartments — separated by walls, floors, and protected shafts — so that a fire in one compartment cannot spread to adjacent compartments for a defined period (typically 30 or 60 minutes). This gives occupants time to escape and limits fire damage. In London's large stock of Victorian and Edwardian terraced houses converted to HMOs, compartmentation is the element most commonly failed in fire risk assessments. The original structure often had solid party walls, but conversion works — running pipework and electrical cables through floor voids, cutting chases, fitting en-suite bathrooms, and inserting new partitions — routinely leave unintumesced holes in what should be fire-resisting elements. Even a small gap around a pipe or cable can allow hot gases and flame to bypass a fire door or fire-rated wall. Remediation requires identifying every penetration in party walls, staircase enclosures, and floor/ceiling assemblies, then sealing them with intumescent mastic, pipe collars, or pillows appropriate to the size and construction.
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