Fire Risk Assessments for Portfolio Landlords: Staying Compliant Across Multiple Manchester HMOs

Most fire risk assessment guidance is written for a landlord with one HMO. Check it, book it, file it, forget it for a year. That advice falls apart the moment you own four, seven or twelve properties, because the thing that actually goes wrong for portfolio landlords is rarely the assessment itself. It is the system, or lack of one, that is supposed to keep track of all of them at once.

I work with landlords across Greater Manchester who started with one HMO and now run a genuine portfolio. The question I get asked most often isn’t “what does a fire risk assessment involve” – they know that by property two. It’s “how do I stop one of these slipping through the net while I’m busy growing the rest of the business.”

This article is about that second question. It covers which of your properties actually need a fire risk assessment, why a managing agent doesn’t take your legal liability off your hands, what happens when a multi-property operation gets fire safety wrong, and a practical system for keeping every property compliant without it becoming a full-time job in itself.

Why a Portfolio Changes the Compliance Maths

A single HMO landlord has one review date to remember, one assessor relationship to manage, and one set of defects to close out. Miss it, and you have one problem. A portfolio landlord with seven HMOs doesn’t have seven times the risk of any individual property failing – they have seven separate, independent chances for something to slip, each with its own renewal date, its own assessor, its own paperwork trail, and its own set of tenants who could be affected if it goes wrong.

The average UK landlord now holds around 7.3 properties with a combined value of roughly £1.7 million, according to NRLA member data analysed by Rushbrook. Average management costs for a portfolio that size run to around £12,207 a year, and that’s before you’ve factored in the admin time of keeping every property’s fire safety paperwork current. That’s the scale a lot of our Manchester clients are operating at, or growing towards, and it’s precisely the scale where ad hoc compliance tracking starts to break down.

It’s also worth being honest about what’s at stake beyond the fine itself. A lapsed fire risk assessment that surfaces during a claim can affect your landlord insurance too – insurers increasingly ask to see current documentation before they’ll pay out on a fire-related claim, and that risk multiplies across every property you hold, not just the one where something went wrong.

I’ve never seen a portfolio landlord get caught out because they didn’t know a fire risk assessment was needed. I’ve seen plenty get caught out because they knew, meant to sort it, and it got lost between two other properties that needed attention that same month.

Not Every Property in Your Portfolio Needs a Fire Risk Assessment

This is the first thing I clarify with any multi-property landlord, because getting it wrong in either direction costs you. Treat every property the same and you’ll waste money commissioning assessments you don’t legally need. Assume none of them need one beyond your licensed HMOs and you risk leaving a genuine commercial unit or converted block uncovered.

Houses in multiple occupation

Every HMO in your portfolio needs its own fire risk assessment, covering the whole building: communal areas, escape routes, fire doors, detection, and every let room. This applies whether the HMO is licensed or not – licensing and the fire safety duty under the Regulatory Reform (Fire Safety) Order 2005 are separate obligations that both apply. Our article on HMO licensing and fire safety in Manchester covers how the two interact.

Single lets and smaller shared houses

A standard single-family tenancy, or a house shared by fewer than the threshold that makes it a licensable HMO, generally sits outside the Fire Safety Order’s general fire precautions duty, because it isn’t a workplace or a building with shared means of escape serving multiple households in the way the Order targets. You still carry other statutory duties here – smoke alarms, gas safety, electrical safety – just not a formal fire risk assessment in the HMO sense.

Mixed-use and commercial units

If your portfolio includes a shop with a flat above, an office conversion, or any unit with a genuine commercial element, that property needs its own fire risk assessment regardless of what else you own, because the Fire Safety Order applies to workplaces directly. Don’t assume your residential-focused compliance calendar automatically covers these.

The practical upshot: before you build any kind of system, you need an honest, property-by-property audit of which ones actually trigger the duty. Get that wrong first and everything downstream is wrong too.

The Law Does Not Recognise “Portfolio Compliance”

I still occasionally hear landlords ask whether one assessment, or one assessor’s sign-off, can cover a group of similar properties on the same street. It can’t, and the legislation is clear on why.

Article 5 of the Regulatory Reform (Fire Safety) Order 2005 places the duty on “the responsible person” for each set of premises, and extends it to “every person, other than the responsible person… [who] has, to any extent, control of those premises.” There is no provision anywhere in the Order for treating a group of properties as a single unit of compliance, however similar their layout or however consistent your management of them.

Two identical terraced HMOs on the same road, bought in the same year from the same vendor, still need two separate fire risk assessments, two separate review dates, and two separate sets of records. Your portfolio might feel like one business. To the law, it’s a collection of individual premises, each with its own responsible person duties.

Appointing a Managing Agent Does Not Transfer Your Liability

This is the single most common misunderstanding I encounter among landlords who’ve scaled up enough to bring in a letting or managing agent. Handing day-to-day management to someone else feels like handing over the risk too. It doesn’t work that way.

What a good managing agent actually does

A competent agent will typically organise fire risk assessments on your behalf, chase contractors for remedial works, and keep your paperwork filed. That’s valuable, and it’s one of the main reasons portfolio landlords use agents in the first place. It reduces your administrative burden considerably.

What stays your responsibility whatever you pay them

The NRLA is direct about this: even once you’ve appointed a managing agent, “the legal responsibility remains with you,” and you can still face prosecution or fines if the agent fails to comply with fire safety law on your behalf. The owner “retain[s] ultimate legal responsibility for adhering to safety regulations and legislation.” Article 5(4) of the Order backs this up from the other direction too – anyone with a contractual obligation covering maintenance, repair or safety, including an agent acting under a management agreement, takes on control-based duties of their own. That adds a second responsible party. It does not remove you as the first one.

In practice, this means you need to know, for every property an agent manages on your behalf, whether the fire risk assessment has actually been done, when it’s due for renewal, and whether any actions from the last one are still open. “My agent handles that” is not a system. It’s a hope.

When Portfolio Compliance Fails: The Northampton Case

It’s worth looking at what happens when a multi-property operation gets this wrong, because the consequences scale with the portfolio, not just the individual property.

Faiz Hameed was described in court as the “controlling mind” behind eight unlicensed HMOs across six streets in Northampton. Alongside serious fire safety failings, officers found breaches of the Housing Act 2004 and the HMO Management Regulations 2006 across the properties. When sentencing finally came at Northampton Magistrates’ Court in October 2024, five years after the first inspection, Hameed was fined £312,000. Two associates involved in parts of the operation were fined £34,000 and £60,000 respectively. Combined with costs and victim surcharges, the total bill reached £452,796.

A case on that scale will also have triggered formal enforcement action long before it reached court. Our guide to fire safety enforcement notices covers what that process looks like and how much earlier, cheaper intervention usually is than letting it run this far.

That is not a single-property fine multiplied by eight. It’s what happens when a court decides an operation’s scale and the owner’s degree of control over it should be reflected directly in the penalty. The larger and more deliberate the pattern of non-compliance across a portfolio, the harder enforcement tends to land. A portfolio landlord who lets one property’s fire risk assessment lapse isn’t treated the same as a single-property landlord in the same position – the regulator and the courts increasingly look at the whole operation.

The Staggered Renewal Problem

Even landlords who take fire safety seriously tend to run into the same practical issue as they grow: review dates stop lining up. You bought property one in March, property two in July, property three the following February. Three different renewal windows, three different assessors possibly used at different points, and no single date in the calendar that triggers a full portfolio check.

I ask every new portfolio client the same question: if I asked you right now which of your HMOs has a fire risk assessment due in the next sixty days, could you answer without checking anything? Most can’t, and that’s the gap that causes problems.

There’s no single review interval that fits every HMO – it depends on the building’s risk profile, following a competent assessor’s own recommendation rather than a fixed statutory number. Our guide on how often fire risk assessments should be reviewed covers that in more detail. For a portfolio, the harder problem isn’t knowing the interval for one property. It’s tracking different intervals across several properties at once, without any of them quietly running over.

None of these systems need to be expensive or complicated. What they all have in common is that the tracking lives somewhere other than memory, and somewhere other than inside one agent’s inbox that you can’t see into.

Patterns We See Across Multi-HMO Portfolios in Manchester

Across the portfolios we see locally, the same handful of failure patterns turn up again and again. None of them are exotic. All of them are avoidable once you know to look for them.

• The same defect repeated across sister properties – a fire door closer that fails on one HMO is very often failing quietly on two or three others bought around the same time, because they were fitted by the same contractor.
• A newly acquired property inheriting the previous owner’s out-of-date or non-existent fire risk assessment, with the new landlord assuming it was already covered.
• Delegating fire safety entirely to a managing agent with no periodic check from the landlord’s side, as covered above.
• Commissioning cheaper, lower-quality assessments across the whole portfolio at once to save money – our guide to fire risk assessment costs explains why the cheapest quote per property rarely stays cheapest once you add up the generic, boilerplate reports it tends to produce.
• Review dates slipping during a period of rapid growth, when attention is on acquiring the next property rather than maintaining the ones already owned.
• No single person in the business who can state, from memory or from one document, the compliance status of every HMO at once.
• Remedial works agreed in a fire risk assessment report but never formally signed off as complete, so the same action reappears, unresolved, at the next review.

Most of these come down to the same root cause: treating fire safety compliance as a per-property task rather than a portfolio-level discipline. The properties are individual under the law. The system for managing them doesn’t have to be.

Selective Licensing Makes Cross-Borough Portfolios Harder

A growing portfolio often means growing across borough boundaries, and that’s where things get genuinely more complicated, because selective licensing schemes vary street by street and council by council across Greater Manchester.

Manchester City Council alone has fully licensed more than 3,500 private rented homes under selective licensing since 2017, with a further 1,863 properties across six wards – Cheetham, Crumpsall, Harpurhey, Longsight, Miles Platting & Newton Heath, and Moss Side – brought into scope from February 2025. A property in one of those wards sits under different obligations to an otherwise identical property a few streets away that falls outside the designated area, and a different set of rules again once you cross into Salford, Oldham, or another neighbouring borough. We cover the full picture in our guide to selective licensing across Greater Manchester.

For a single-property landlord, checking this once is a minor task. For a portfolio spread across three or four boroughs, it means your compliance system needs to track not just fire risk assessment renewal dates, but which licensing regime applies to which property, and when each of those licences themselves comes up for renewal. Treat it as one more thing to track centrally rather than one more thing to remember per property.

Building a Compliance System That Scales With You

None of this requires expensive software or a compliance manager on the payroll, certainly not at the 2-7 property stage most of our clients are at. It requires a system that exists outside anyone’s head, and a routine for checking it.

1. List every property you own and mark, honestly, which ones legally require a fire risk assessment under the criteria set out earlier in this article.
2. For each one that does, record the date of the last assessment, the assessor who carried it out, and the date the next one is due.
3. Record every action point from each report separately, with a close-out date and the name of whoever is responsible for getting it done.
4. Put one calendar reminder in place that reviews the whole list monthly, not one reminder per property scattered through the year.
5. If you use a managing agent for some or all properties, ask them directly, in writing, to confirm fire risk assessment status at that same monthly point – don’t assume silence means it’s handled.
6. Note which licensing regime, if any, applies to each property, and its own renewal date, alongside the fire safety information.
7. Review the whole system every time you acquire a new property, before the first tenant moves in, not after.

Most portfolio landlords we work with get as far as step two and stop, because step one alone usually surfaces at least one property they’d lost track of. That’s normal. It’s also exactly the gap this system is designed to close.

Why Portfolio Landlords Benefit from One Consistent Assessor

There’s a case for using the same fire risk assessor across your whole portfolio that goes beyond convenience. An assessor who already knows your properties, your typical tenant turnover, and the fixes you made last time round will spot a recurring defect pattern faster than someone starting cold on each visit – exactly the kind of repeated fire door or detection issue flagged earlier in this article.

It also gives you one relationship to manage rather than several, one point of contact who can proactively flag an approaching renewal across multiple properties at once, and consistent reporting that’s genuinely comparable property to property, rather than four different report formats from four different providers that are hard to compare at a glance. For a growing portfolio, that consistency is worth more than it looks on paper.

Frequently Asked Questions

Do I need a separate fire risk assessment for every HMO I own, even if they’re identical layouts?

Yes. The Regulatory Reform (Fire Safety) Order 2005 applies the responsible person duty to each set of premises individually. There is no provision for treating similar or identical properties as a single unit of compliance.

If my managing agent arranges fire risk assessments for me, am I still liable if something goes wrong?

Yes. Appointing an agent gives them their own duties for matters within their control, but it does not remove your underlying legal responsibility as the owner. You can still be prosecuted or fined if the duty isn’t met, even where an agent was supposed to handle it.

Do single-let properties in my portfolio need a fire risk assessment too?

Generally not in the same way as HMOs, because a standard single-family tenancy usually falls outside the Fire Safety Order’s general fire precautions duty. You still carry other statutory safety duties on those properties, such as smoke alarms, gas and electrical safety.

How often should I review fire risk assessments across a portfolio?

There’s no single fixed interval – it depends on each property’s risk profile and your assessor’s recommendation. The practical challenge for a portfolio is tracking different intervals across several properties at once, which is why a central compliance calendar matters more as you grow.

Can I use one fire risk assessment report as a template for similar properties in my portfolio?

No. Each property needs its own assessment reflecting its own specific layout, fixtures, occupants and defects. A generic or copied report is exactly the kind of lower-quality assessment that tends to miss property-specific risks.

What happens if one HMO in my portfolio is found non-compliant – does it affect my other properties?

Not automatically in legal terms, since each property is assessed individually. In practice, enforcement teams and courts do look at an owner’s overall pattern of compliance across their portfolio, and a documented history of non-compliance at one property can affect how seriously a later issue elsewhere is treated.

Does selective licensing replace the need for a fire risk assessment?

No. Selective licensing and HMO licensing are separate from the fire safety duty under the Regulatory Reform (Fire Safety) Order 2005. You can hold a valid licence and still be non-compliant on fire safety, or vice versa – both need managing in parallel.

What’s the most practical first step if I’ve never formally tracked fire safety compliance across my portfolio?

List every property you own and mark which ones legally require a fire risk assessment. Most landlords find this single step surfaces at least one property that’s fallen out of view, which is usually the most useful starting point.

Is it worth using the same fire risk assessor for every property in my portfolio?

Often, yes. An assessor who already knows your properties tends to spot recurring defect patterns faster, gives you one relationship to manage instead of several, and produces consistent, comparable reporting across properties.

Do I need to worry about fire risk assessments on commercial units mixed into my portfolio?

Yes. Any unit with a genuine commercial element, such as a shop or office, needs its own fire risk assessment under the Fire Safety Order because the Order applies directly to workplaces, regardless of what residential property you hold alongside it.