A house in multiple occupation (HMO) in England must have its fixed electrical installation inspected and tested at least every five years under the Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020, and the landlord faces a penalty of up to £40,000 for a breach. The EICR is the same BS 7671 report used anywhere else. What changes for the electrician is the job around it: working out how many installations the building holds, getting into every let room, judging circuits that are worked far harder than in a family home, and reporting on the supplies to fire alarms and escape lighting. This guide covers the rules, the scope, the recurring findings and how to code them.
- Every privately rented HMO in England needs an EICR at intervals of no more than five years. If your report recommends a shorter interval, that shorter interval becomes the landlord's legal deadline.
- One EICR covers one installation. A shared house on one supply gets one report with a schedule for each board; converted flats with their own meters get a report each, plus one for the landlord's supply.
- The 2020 Regulations removed the old five-year test duty from the 2006 HMO Management Regulations, but the equivalent duty for section 257 HMOs (converted blocks of flats) is still on the statute book.
- Under BS 7671:2018+A4:2026 only C1 and C2 make a report unsatisfactory. GOV.UK guidance still tells landlords that FI items must be investigated within 28 days.
- No AFDDs on socket circuits in an existing HMO is a C3, not a C2.
- The EICR covers the circuits feeding fire alarms and emergency lighting. It does not certify the systems themselves.
Which rules apply to the electrics in an HMO?
An HMO is, broadly, a property occupied by three or more people from more than one household who share a kitchen, bathroom or toilet (Housing Act 2004, section 254). Some buildings converted into self-contained flats are also HMOs under section 257, where the conversion did not meet the 1991 Building Regulations and fewer than two-thirds of the flats are owner-occupied. Since 1 October 2018 an HMO occupied by five or more people in two or more households has needed a mandatory licence whatever the number of storeys, and many councils run additional licensing schemes that catch smaller ones.
Four sets of rules touch the electrics. It helps to know which one a licensing officer is quoting.
| Rule | What it requires | What it means for your report |
|---|---|---|
| Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020 | Inspection and testing by a qualified person at intervals of no more than five years, or sooner if the last report says so. Copy to tenants within 28 days and to the council within 7 days of a written request. Remedial or further investigative work within 28 days. Penalty up to £40,000 | The operative duty for almost every HMO. The outcome and the next-inspection date you write carry legal weight |
| Management of Houses in Multiple Occupation (England) Regulations 2006 | Manager must keep fire alarms in good working order (regulation 4), must not unreasonably interrupt the electricity supply (regulation 6) and must keep fixtures, fittings and common-parts lighting in repair (regulations 7 and 8) | Regulation 6(3), the old five-year electrical test duty, was omitted by the 2020 Regulations. The other duties remain |
| Licensing and Management of Houses in Multiple Occupation (Additional Provisions) (England) Regulations 2007 | For section 257 HMOs, regulation 7(3) still requires every fixed electrical installation to be inspected and tested at intervals not exceeding five years, with the certificate supplied to the council within 7 days of a written request | In a converted block this bites on the landlord's installation serving the common parts |
| Housing Act 2004, Schedule 4 licence conditions | Licence holder must ensure every electrical installation in the house is in proper working order and safe for continued use, declare that to the council on demand, and keep any appliances supplied in a safe condition | Councils ask for a satisfactory EICR at licence application and renewal |
The penalty figures moved recently. The 2025 amending regulations (SI 2025/1043), which extended the electrical safety regime to social housing, raised the maximum penalty under the 2020 Regulations from £30,000 to £40,000 from 1 November 2025. The civil penalty ceiling for Housing Act 2004 offences, including breaches of the HMO management regulations, rose to £40,000 on 1 May 2026. GOV.UK's civil penalties guidance gives councils a starting level of £20,000 for a manager's failure to take safety measures and £12,000 for failure to supply and maintain gas and electricity.
The landlord-side detail is in Landlord EICR Regulations in England: The Electrician's Guide and the intervals for other property types are in How Often Is an EICR Required? Intervals by Property Type. Scotland and Wales run their own HMO licensing and repairing-standard rules, covered in EICR Landlord Requirements in Scotland and Wales (vs England).
How many EICRs does an HMO need?
An EICR reports on one installation, from its origin to its final circuits. So the first job on site is to count supplies, not bedrooms.
| Building type | Supply arrangement | Reports needed |
|---|---|---|
| Shared house, single supply | One meter, one consumer unit | One EICR, one schedule of test results |
| Shared house, several boards | One meter, main board plus sub-boards (kitchen, loft conversion, outbuilding) | One EICR with a schedule for each distribution board |
| Bedsit HMO, landlord's supply | One incoming supply, a small board or private sub-meter for each room | One EICR covering the whole installation, boards listed per room |
| Converted flats, separate supplier meters | Each flat has its own supply; landlord's supply for stairs, alarm and lighting | One EICR per flat plus one for the landlord's supply |
| Mixed building (shop below, HMO above) | Usually separate supplies | Separate reports; note any circuits that cross between them |
With several boards on one supply, record the supply characteristics once at the origin. Give each board its own schedule with a reference, a location, how it is fed (for example "sub-main from DB1 way 8, 16 mm² SWA"), its protective device and its own Zdb and prospective fault current. How to Fill In a Schedule of Test Results, Column by Column goes through the columns, and EICR for Flats and Communal Areas: Who Is Responsible? deals with landlord's supplies in blocks.
A private sub-meter does not create a separate installation. Ownership and the point of supply do. If the landlord pays one bill and recharges the tenants, it is one installation and one report.
How should you plan access, extent and limitations?
Access is where HMO reports go wrong. Six tenants keep six sets of hours, and bedrooms are locked. Getting into the rooms is the landlord's job, so make it a condition of the quote that every tenant has written notice (24 hours is the usual minimum in tenancy agreements) and that someone with keys is on site.
Before the day, ask the landlord or agent for:
- the previous EICR and any Electrical Installation Certificates or Minor Works certificates for alterations since;
- the fire alarm and emergency lighting certificates and logbook;
- the licence, or at least the number of occupants and how the rooms are numbered on the tenancies;
- which meters serve what, and whether any are prepayment meters.
Agree the extent and limitations in writing before you start and repeat them on the report. An agreed limitation is one the client accepted in advance, such as not lifting floors. An operational limitation is one you hit on the day, such as a locked room. Record both, room by room, with the reason. A report that quietly omits three bedrooms may not satisfy the council and leaves the inspector exposed if one of those rooms later has a fire. EICR Sampling and Limitations Explained: Extent, LIM and N/V covers the wording.
Plan the dead testing. Switching off a shared house affects several households at once, with fridges, home workers and sometimes medical equipment in the rooms. Agree a window, isolate board by board where the arrangement allows, and expect a mains-fail fault on any fire alarm panel until the supply is back. Allow more time than the floor area suggests: an HMO has more accessories per room and often two or three boards. See How Long Does an EICR Take? Typical Times by Property Type and How to Price an EICR: A Method for Electricians.
Councils and agents read HMO reports room by room, so write the observations that way. Number each one, use the room name on the tenancy (Room 3, first-floor rear) and name the board and circuit. "No RCD protection to sockets" is no use in a six-bedroom house. "DB2 (first-floor landing), circuit 4, ring final serving Rooms 3 and 4: no additional protection by 30 mA RCD, Regulation 411.3.3. C3" tells the landlord exactly what to price. How to Write EICR Observations That Stand Up has more examples.
What should you check at the intake and the boards?
Adequacy of the supply. A house wired for one family may now hold six adults, each with a heater, a kettle and a fridge. Six rooms each drawing 13 A is 78 A before the shared kitchen, a shower or an immersion heater is counted, and many older intakes have a 60 A or 80 A cut-out fuse. You are not designing the installation, but you should look for the evidence: discoloured tails, a hot cut-out, a main switch showing heat damage. Thermal damage is a C2. A supply that looks marginal with no damage is a written note to the landlord. Defects in the distributor's equipment are reported to the network operator. Smart Meters and Isolators on EICRs: What to Record covers who owns what at the intake.
Sub-mains. Bedsit boards are fed by distribution circuits, and they need their own results. A distribution circuit on a TN system has a maximum disconnection time of 5 s (Regulation 411.3.2.3) and on a TT system 1 s (411.3.2.4). Measure Zdb and fault current at each board and check that the breaking capacity of the devices in it is adequate. Where a 30 mA RCD at the main board protects a sub-main, one fault in one room takes out everything downstream. That is a selectivity and Regulation 314.1 point, usually a C3 at most.
Whose supply feeds the safety systems. Stair lighting, the fire alarm and the emergency lighting should be on the landlord's supply. Where each room has its own prepayment meter, check that the alarm and escape lighting do not depend on a tenant keeping a meter in credit. LACORS guidance and most council HMO standards expect that. BS 7671 gives you no code for it, so put it in writing to the landlord.
Charts and labels. Regulation 514.9.1 requires a legible chart or schedule at each board. In an HMO a wrong chart is more than untidy, because the next person to isolate a circuit may be a tenant or a handyman. A missing or inaccurate chart is normally a C3.
What are the most common EICR observations in HMOs?
Shared houses are used hard and carry a history of cheap alterations. The codes below follow Electrical Safety First Best Practice Guide 4 (BPG4, Issue 7) and IET Guidance Note 3. The principles are in EICR Observation Codes Explained: C1, C2, C3 and FI.
| Finding | Where you find it | Usual code | Why it matters in an HMO |
|---|---|---|---|
| Ring final extended with spurs off spurs; r1, rn or r2 not continuous | Loft rooms, extensions, subdivided bedrooms | C2 if the ring is broken; C3 for poor practice that tests sound | Each room may run a heater, a fridge and cooking appliances from one 32 A circuit |
| No 30 mA RCD on socket-outlets | Older boards | C3 generally; C2 where a socket is likely to supply equipment outdoors | More occupants, more portable appliances, more extension leads |
| No RCD on circuits serving a bath or shower room | Older boards, en-suites added later | C3 where supplementary bonding is present and effective; C2 where it is not | Several bathrooms, and shower cubicles fitted into bedrooms |
| Plastic consumer unit under a wooden staircase or on the only escape route | Hallways, understairs cupboards | C3; C2 if there is thermal damage | A fire in the escape route is the classic HMO risk |
| Cables in the escape route held only by plastic clips or trunking | Halls, landings, stairs | C3 (Regulation 521.10.202); C2 if already sagging across the route | Fallen cables can trap occupants and firefighters |
| Main protective bonding absent or undersized | Intake | C2 where absent | Shared kitchens and bathrooms on unbonded services |
| Borrowed neutral or circuits crossing between units | Landings, two-way lighting, conversions | C2 once confirmed | A tenant's or contractor's isolation does not make the circuit dead |
| Accessories scorched, cracked or missing covers | Bedrooms, kitchen worktops | C2 for thermal damage; C1 where live parts can be touched | Overloaded adaptors and hard use between inspections |
| No AFDDs on socket-outlet circuits | Every HMO wired before 2022 | C3 | Regulation 421.1.7 requires them for new work in HMOs |
| Fire alarm supply sharing an RCD with socket circuits | Split-load boards | C3 or a note | BS 5839-6 wants the alarm supply independent of socket-circuit RCDs |
Two of these deserve more than a table row.
Rings. BS 7671 does not limit the number of sockets on a ring. The traditional guidance in Appendix 15 and the IET On-Site Guide is a floor area of up to 100 m², and Regulation 433.1.204 adds that the load in any part of the ring should be unlikely to exceed the cable's current-carrying capacity for long periods. A ring stretched across five letting rooms, each with its own heater, fails that test in spirit even when the end-to-end readings are sound. Test every ring fully as in Ring Final Circuit Testing: r1, rn, r2 and R1+R2 Explained. A broken ring is a C2. An intact ring with too much on it is a C3 and a clear written recommendation for more circuits. Council amenity standards usually set a minimum number of sockets per letting room, and too few shows up as adaptors and extension leads, which is worth noting too.
Borrowed neutrals and crossed supplies. Pre-licensing conversions often have a landing light fed from one board and returned through another, or a bedsit socket spurred from the landlord's circuit. BPG4 lists a borrowed neutral as C2 because isolating one circuit leaves a live neutral on it. Borrowed Neutrals: How to Find, Test and Code Them shows how to prove it. Tell the landlord in writing that the isolation labelling cannot be trusted until it is put right.
Rooms with a shower cubicle fitted in the bedroom are locations containing a shower. Section 701 applies, every circuit serving the location needs 30 mA RCD protection (701.411.3.3), and socket-outlets must be outside the distance set by 701.512.3. Bathroom Zones, IP Ratings and Bonding: Section 701 Explained has the zones, and Kitchen Electrics Regulations UK: Sockets, Circuits, Part P covers bedsit kitchenettes. For the wider list of defects, see EICR Fails: The Ten Most Common C1 and C2 Observations.
How does Amendment 4 change an HMO report?
BS 7671:2018+A4:2026 was published on 15 April 2026 and the previous amendment is withdrawn on 15 October 2026. Two things matter on HMO reports.
| Point | Report to A2:2022 | Report to A4:2026 |
|---|---|---|
| FI (further investigation) | "Required without delay"; makes the report unsatisfactory | "Advised"; listed with C3 and does not make the report unsatisfactory |
| Observation layout | One list, any code | C1 and C2 separated from C3 and FI |
| AFDDs on HMO socket circuits up to 32 A | Required for new work (Regulation 421.1.7) | Still required for new work; scope unchanged |
| Landlord's 28-day duty | Applies to C1, C2 and FI | The 2020 Regulations still refer to "further investigative or remedial work" |
The IET's Wiring Matters (issue 110, July 2026) explains that FI and C3 were separated from C1 and C2 to make clear that they do not lead to an unsatisfactory outcome. It also says FI is for a potential safety issue you could not fully determine within the agreed extent, and is not a substitute for a code you ought to give.
The landlord's law has not moved with the form. GOV.UK's guidance on the 2020 Regulations, last updated on 1 November 2025, still tells landlords that C1, C2 and FI items need action within 28 days and that C3 does not. So when you write an FI on an HMO report, describe exactly what could not be verified and why, and tell the landlord that the council is likely to expect it investigated within 28 days whichever form you used.
On AFDDs, the requirement is not retrospective. An HMO wired before the 2022 amendment with no AFDDs gets a C3, and that alone never makes the report unsatisfactory. AFDD Requirements: Regulation 421.1.7 Explained (A4:2026) has the wording to use.
How do fire alarms and emergency lighting fit in?
Most HMOs have a fire detection system to BS 5839-6, and many have emergency lighting to BS 5266-1. The grade and category are set by the council, normally following the LACORS national fire safety guidance. Typical expectations look like this, but always check the council's own HMO standard.
| HMO type | Typical system | What it means electrically |
|---|---|---|
| Shared house, up to four storeys | Grade D, LD3 or LD2: interlinked mains smoke and heat alarms with standby batteries | A mains supply to every alarm and an interlink, wired or radio |
| Shared house, five or six storeys | Grade A, LD2: detectors and call points wired to a control panel | A dedicated circuit to the panel |
| Bedsits, one or two storeys | Grade D, LD2 in the common parts with a heat alarm in each bedsit, plus a separate smoke alarm in each bedsit | Common-parts alarms on the landlord's supply |
| Bedsits, three or more storeys | Grade A, LD2 in the common parts, plus a separate Grade D smoke alarm in each bedsit | A panel circuit and local alarm supplies |
BS 5839-6:2019 splits Grade D into D1 (sealed, tamper-proof standby battery) and D2 (user-replaceable battery), and some councils now specify Grade D1, LD2 for all rented HMOs.
The EICR inspects and tests the fixed wiring that supplies these systems: the circuit, its protective device, cable condition and labelling at the board. It does not test detector coverage, sounder levels or battery standby. That is the fire alarm certificate and the routine testing regime. What the EICR should comment on is the supply arrangement:
- Grade D alarms should be fed either from an independent circuit at the board or from a separately protected, regularly used local lighting circuit, so that a lost supply gets noticed.
- Grade A panels need a dedicated circuit with nothing else on it, labelled so that nobody switches it off.
- RCDs. BS 5839-6 recommends that any RCD protecting the alarm supply serves that circuit alone or operates independently of the RCDs for socket circuits. An alarm circuit on its own RCBO meets that. One on the same 30 mA RCD as the kitchen sockets does not.
- Emergency lighting. Self-contained luminaires are normally fed from the local lighting circuit so they come on when that circuit fails. Do not code it for sharing a circuit; that is the design intent of BS 5266-1.
Fire Alarm Certificate BS 5839-6: Grades and Categories and Emergency Lighting Certificate: BS 5266-1 Testing and Records cover the certificates for the systems themselves.
Licence conditions also require appliances supplied by the landlord to be kept safe, and GOV.UK's guidance points landlords to the IET Code of Practice for In-service Inspection and Testing. Many landlords ask for this at the same visit. See PAT Testing Guide UK: Intervals, Tests and Records.
What does remedial work in an HMO have to meet?
The EICR judges the existing installation against the current standard and codes by risk. Remedial work is new work and must comply in full. The usual HMO remedial is a board change, and a new consumer unit in an HMO needs:
- AFDD protection on every socket-outlet final circuit up to 32 A (Regulation 421.1.7);
- a non-combustible enclosure (421.1.201);
- 30 mA RCD protection for socket-outlets (411.3.3) and for circuits supplying luminaires in domestic premises (411.3.4);
- surge protection assessed under Regulation 443.4.1. Where the building has a fire alarm panel, the "failure of a safety service" limb makes it hard to argue against fitting one.
AFDD and RCBO combinations take space, so count ways before quoting. RCBO vs RCD Split-Load Boards: Which to Fit and Why and Surge Protection (SPD) Requirements: Section 443 Explained go into the choices, and Consumer Unit Replacement: Which Certificate and What to Check covers the pre-work survey.
A consumer unit replacement or a new circuit is notifiable under Part P and needs an Electrical Installation Certificate. An addition or alteration to an existing circuit needs a Minor Works certificate. See Part P notification: what to notify, how, and by when and Minor Works Certificate: When to Use It (and When Not To).
What must the landlord receive, and by when?
The 2020 Regulations run on fixed periods, and several of them start from your paperwork.
| Document or action | Deadline | Who it goes to |
|---|---|---|
| EICR | Within 28 days of the inspection | Every existing tenant |
| EICR | Before they occupy | Each new tenant |
| EICR | Within 28 days of a request | A prospective tenant |
| EICR | Within 7 days of a written request | Local housing authority |
| Remedial or further investigative work | Within 28 days of the inspection, or sooner if the report says so | Carried out by a qualified person |
| Written confirmation that the work is done and the standard is met | Within 28 days of completing the work | Every tenant and the local housing authority |
| EICR | Kept until the next inspection | The next inspector |
After remedials, the landlord needs your written confirmation. In practice that is the EIC or Minor Works certificate for the work, with a short statement tying each item back to the observation number on the EICR. A receipt will not do. Unsatisfactory EICR: What Happens Next (Landlords & Electricians) covers the process from the landlord's side.
For a newly converted or fully rewired HMO, GOV.UK guidance accepts the Electrical Installation Certificate in place of a report for the first five years.
How Certio helps
Certio produces the EICR, EIC, Minor Works certificate and PAT records on the BS 7671 model forms and turns them into branded PDFs. Photograph the consumer unit and the circuit schedule drafts itself; point the phone camera at a Megger MFT-X1 and the reading goes straight into the schedule of test results, or dictate it while your hands stay on the probes. Suggested observation wording with the regulation reference is there for you to check and confirm. The judgement stays yours; the typing goes. Starter is free for 7 days, then £4.99 a month.