01 · FrameworkThe 17-duty framework, four groups, one operating stack
The 17 statutory duties of a London landlord are not a single statute and do not sit in a single schedule. They are a composite of roughly a dozen different pieces of primary and secondary legislation, enforced by half a dozen different authorities, with cadences that run from weekly to ten-yearly. The operating problem is not knowing they exist, most landlords can name the big ones. The problem is running them as a coordinated compliance file rather than as a loose collection of certificates.
HSE groups the 17 into four colour-coded groups on the For Landlords audience page, matching the way building-safety professionals, insurance underwriters and council licensing teams think about the stack:
- Group A · Fire Safety (5 duties): FRA, fire doors, fire alarm system, emergency lighting, smoke and CO alarms.
- Group B · Electrical & Energy (4 duties): EICR, PAT, Gas Safety CP12, EPC and MEES.
- Group C · Structural & Hazard (4 duties): Legionella Risk Assessment, Asbestos Management Survey, HHSRS Hazard Assessment, Awaab's Law (damp and mould response).
- Group D · Licensing & Legal (4 duties): HMO Licence, Selective Licensing, Right to Rent, Tenancy Deposit Protection.
Not every duty engages on every property. The exact subset depends on six inputs: property type (single-let, HMO, block), occupancy (number of persons and households), building height (under or over 11 m / 18 m), pre-2000 or post-2000 build (asbestos), and whether the borough has designated Additional HMO or Selective licensing for the ward. The interactive Compliance Obligation Diagnoser scopes the specific stack in sixty seconds; the rest of this article runs through each duty so you can see what a given trigger actually means.
Read this alongside the four pillar articles
Each of the four groups has its own deeper dives elsewhere in this blog. Fire doors and BS 5839 alarm grades cover Group A detail; the HMO Borough Guide, Article 4 and licensing comparison cover Group D; Awaab's Law SOP and the Renters' Rights Act 2025 cover Group C interactions.
02 · Group A · Fire SafetyThe five fire-safety duties (duties 1-5)
The fire-safety group is the highest-risk in penalty terms (unlimited fines, imprisonment on indictment) and the most commonly enforced. All five duties apply to HMOs and block common parts; most apply to single-let properties within blocks but not to free-standing single-family houses.
1 · Fire Risk Assessment
Unlimited fineStatute: Regulatory Reform (Fire Safety) Order 2005, as amended by Fire Safety Act 2021 and s.156 Building Safety Act 2022. Written FRA mandatory for every premises with a Responsible Person (blocks, HMOs, commercial). Cadence: Review within 12 months; full re-assessment every 2-5 years or on material change. Enforcer: London Fire Brigade. Methodology: PAS 79-1 or BS 8674:2025.
2 · Fire Door Inspection
Reg 10Statute: Fire Safety (England) Regulations 2022 Regulation 10. Cadence: Quarterly checks of flat entrance doors, annual checks of common-parts fire doors, for buildings over 11 m. Standards: BS 8214:2026 (install/maintain), BS 476-22 or BS EN 1634-1 (test). Enforcer: LFB and HMO licensor. See the full Fire Doors FD30/FD60 guide. The enforcement side, what landlords actually get wrong and what councils are finding, is written up in the sister-team piece on landlord fire-door obligations in 2025.
3 · Fire Alarm System
BS 5839Standard: BS 5839-6:2019+A1:2020 (domestic), BS 5839-1 (non-domestic/Grade A), LACORS 2008 HMO benchmark. Cadence: Weekly user test, 6-monthly specialist service, annual third-party verification. Four-certificate pack: design, installation, commissioning, verification. Full grade/category detail in BS 5839 guide. Penalty: HMO licence refusal, insurance void, prosecution.
4 · Emergency Lighting
£30k civilStandards: BS 5266-1:2025 (design) and BS EN 1838 (photometric performance) under the Fire Safety Order 2005. Required on escape routes in blocks, HMOs and commercial buildings. Cadence: Monthly function test (flick test), annual full-duration discharge test (typically 3 hours). Log book held on site. Enforcer: LFB and HMO licensor.
5 · Smoke & CO Alarms
Up to £5kStatute: Smoke and Carbon Monoxide Alarm (England) Regulations 2015, as amended 2022. Scope: Smoke alarm on every storey with a room used as living accommodation; CO alarm in every room with a fixed combustion appliance (solid-fuel or gas, including gas boilers per the 2022 amendment). Cadence: Test at start of each new tenancy; unit lifespan typically 10 years. Penalty: Up to £5,000 per property per breach; council enforcement.
The fire-safety group is the one most commonly under-resourced by new landlords. A single free-standing family home does not need a written FRA or emergency lighting; a flat in a block benefits from the common-parts FRA that the freeholder procures. An HMO triggers everything in this group plus licence-specific conditions.
03 · Group B · Electrical & EnergyThe four electrical and energy duties (duties 6-9)
Where fire safety is the most criminally exposed group, electrical and energy is the most civilly exposed. EICR, gas safety and MEES each carry civil penalty regimes with £30,000 ceilings, and the enforcers (HSE, local authority housing teams, Trading Standards) are materially more active than many landlords assume.
6 · EICR · Electrical Installation Condition Report
£30k civilStatute: Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020. Every private tenancy in England requires a satisfactory EICR. Cadence: Every 5 years (some HMO schemes condition 1 year). C1, C2 or FI observations must be remedied within 28 days and evidenced by a further report. Enforcer: Local authority housing team. Penalty: up to £30,000 per property per breach.
7 · Portable Appliance Testing (PAT)
HSE enforcementStatute: Electricity at Work Regulations 1989. Applies to all landlord-supplied appliances (fridge, washing machine, microwave, kettle, toaster, lamps, vacuum). Cadence: Annual is the conservative default; the Regulations themselves require appliances to be maintained in a safe condition, which for PAT-testable equipment in a PRS context is achieved by annual test and visible pass stickers. Penalty: HSWA prosecution, insurance void.
8 · Gas Safety Certificate (CP12)
Unlimited fineStatute: Gas Safety (Installation and Use) Regulations 1998, especially Reg 36. Every gas installation and appliance must be checked annually by a Gas Safe-registered engineer. The CP12 certificate must be provided to the tenant within 28 days of the check and to new tenants before they move in. Enforcer: HSE, Gas Safe Register. Penalty: Unlimited fine on indictment, up to 6 months' imprisonment in serious cases, plus civil disrepair exposure.
9 · EPC & MEES
£30k MEESStatute: Energy Performance of Buildings (England and Wales) Regulations 2012 and the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015 (MEES). Current minimum: Band E for all new and continuing tenancies. Proposed: Band C from 2030 (consultation as of April 2026). Cadence: EPC valid 10 years. Enforcer: Trading Standards. Penalty: up to £30,000 for MEES breach.
Most landlord portfolios do not fail because they miss the statute. They fail because they miss the cadence. Every one of the 17 duties has a renewal interval baked into it, and a paper file without a live compliance calendar will drift. Tidy the cadence and the paper takes care of itself.
04 · Group C · Structural & HazardThe four structural and hazard duties (duties 10-13)
The structural and hazard group includes the duties that are most often overlooked because no one certifies them with an annual sticker, but the enforcement exposure is substantial, particularly under the strengthened HHSRS regime and the Awaab's Law PRS extension.
10 · Legionella Risk Assessment
HSE + insurerStatute: Health and Safety at Work etc. Act 1974 s.3(2); COSHH 2002; HSE Approved Code of Practice L8. Scope: Every PRS property with stored-water systems (tanks, cylinders). Most London PRS stock is in scope. Cadence: Written Legionella Risk Assessment at tenancy start and review every two years (or on material change). Enforcer: HSE; insurer exposure for untreated cases.
11 · Asbestos Management Survey
Unlimited fineStatute: Control of Asbestos Regulations 2012. Scope: Common parts of any block built before 2000, and any building where works are planned that may disturb fabric. Single-household PRS houses are not in duty-to-manage scope, but any pre-2000 property with planned works needs an asbestos Refurbishment/Demolition survey before works commence. Enforcer: HSE and local authority. Penalty: Unlimited fine and up to 2 years' imprisonment on indictment.
12 · HHSRS Hazard Assessment
£30k civilStatute: Housing Act 2004 Part 1. 29 recognised hazards, each rated Category 1 (compels council action) or Category 2 (discretionary). Covers the whole PRS. Cadence: On complaint, on HMO licence renewal, and on intelligence-led inspection. Enforcer: Local authority housing team. Penalty: Improvement notice, prohibition order, emergency remedial action, civil penalty up to £30,000 per offence under HPA 2016 s.126, Works in Default chargeable back to the landlord.
13 · Awaab's Law · Damp and Mould Response
Consultation-stage PRSStatute: Social Housing (Regulation) Act 2023 (live for RPs); Renters' Rights Act 2025 PRS extension (consultation stage; final SI not yet laid as at April 2026). Proposed PRS framework: 14 days to investigate, 7 days for emergency action, modelled on social-housing regulations. Enforcer: Local authority, First-tier Tribunal. Best practice now: run the SOP on the social-housing framework; tighten to final PRS regs when they commence. Full detail in the Awaab's Law 14-day SOP.
05 · Group D · Licensing & LegalThe four licensing and legal duties (duties 14-17)
The licensing and legal group is where most landlords either already know the regime applies or can check in minutes. The penalty exposure on getting it wrong is significant, up to £30,000 per offence and 12-month Rent Repayment Orders, but the duty is binary (either you need a licence or you don't) and the council publishes the designation map.
14 · HMO Licence
£30k civilStatute: Housing Act 2004 Part 2 (Mandatory s.55, Additional s.56-57). Trigger: Mandatory applies nationally to HMOs with 5+ persons / 2+ households. Additional applies in designated wards. Cadence: 5-year licence, with annual condition compliance. Enforcer: Local authority licensing team. Penalty: up to £30,000 civil, 12-month Rent Repayment Order, criminal prosecution. Full comparison in the licensing comparison article.
15 · Selective Licensing
£30k civilStatute: Housing Act 2004 Part 3 s.80. Scope: All private tenancies in designated wards (not HMO-specific). Borough consultation required; SoS confirmation for schemes >20% of area. Cadence: 5-year scheme, 5-yearly review. Enforcer: Local authority. Penalty: up to £30,000 civil, 12-month Rent Repayment Order. HMO-licensable properties exempt under s.79(2)(b).
16 · Right to Rent
£5k-10kStatute: Immigration Act 2014, Right to Rent scheme, enforced under Immigration (Residential Accommodation) (Maximum Penalty) Order 2023. Cadence: Pre-tenancy check on every occupant; follow-up where time-limited leave expires during the tenancy. Enforcer: Home Office and CPS. Penalty: Civil penalty up to £5,000 for a first breach per occupant, up to £10,000 per occupant for repeat breaches. Criminal prosecution for knowing breaches, up to 5 years' imprisonment.
17 · Tenancy Deposit Protection
1-3× depositStatute: Housing Act 2004 ss.212-215 and Sch.10. Trigger: Any Assured Shorthold Tenancy deposit. Cadence: Deposit must be protected with an authorised scheme (TDS, DPS, MyDeposits) within 30 days of receipt; prescribed information served on the tenant. Enforcer: County court or First-tier Tribunal. Penalty: 1 to 3× the deposit, awarded to the tenant, plus bar on s.21 eviction (for pre-RRA 2025 tenancies) and loss of Ground 1A / 1B possession routes if compliance is materially breached.
06 · Worked example12-month compliance cycle, 5-bed Brixton HMO
5-bed shared-house HMO, Brixton SW9, Additional Licensing borough
A landlord holds a 5-bed shared-house HMO in Brixton SW9. Borough operates Additional Licensing in the ward; property is over 11 m (3 storeys); gas-heated; pre-2000 build. All 17 duties engage. Here is the 12-month cycle HSE runs to keep the stack live.
- January · Annual Gas Safety CP12. Engineer visit, all gas appliances checked, CP12 issued to landlord and tenants within 28 days.
- January · Annual PAT. Every landlord-supplied appliance tested and stickered.
- January · Annual FRA review. Responsible Person reviews against change-log; full re-assessment if material change.
- January · Annual fire-alarm service. BS 5839-6 6-monthly service merges with annual verification; log book updated.
- Each week · Fire-alarm user test. Rotating test-button check on one detector; logged.
- Each month · Emergency-lighting function test. Flick test of each fitting; logged.
- February / May / August / November · Quarterly flat-entrance-door inspection (FS(E)R Reg 10). Every flat entrance door on the escape route, seals and gap tolerances checked.
- March · Common-parts fire-door inspection (annual). FDIS inspector walks the communal fire doors.
- April · Legionella review. Every 2 years; water temperatures logged, tank inspected if present.
- June · Emergency-lighting annual full-duration test. 3-hour discharge test; failing luminaires replaced.
- July · MEES & EPC sanity-check. Confirm EPC rating still Band E or better; plan for proposed Band C by 2030.
- September · HHSRS self-survey. Landlord walks property against the 29 HHSRS hazards; actions any finding.
- At turnover · Right to Rent + Deposit Protection + Smoke/CO test. Every new tenancy triggers these three duties afresh.
- As reported · Awaab's Law response. Any tenant damp or mould report triggers the 14-day investigation SOP. File archived.
- Year 5 · EICR renewal. Full re-test of the electrical installation; any C1/C2/FI remedied within 28 days.
- Year 5 · HMO Licence renewal. Pre-inspection audit runs per the HMO inspection playbook; licence application filed in the last 90 days of the current licence.
- Year 10 · EPC renewal. Fresh EPC; gap-close any MEES exposure.
- On any works · Asbestos R/D survey. Pre-2000 build means any intrusive work triggers a Refurbishment/Demolition survey first.
17 duties, 1 calendar
The distinguishing feature of a compliant London HMO is not that the landlord knows all 17 duties, most do, but that the calendar, the renewal intervals and the evidence file are running as a single system. Miss one cadence and the paper trail goes stale; the statute has not changed, but the file no longer proves compliance.
07 · FAQsQuestions London landlords keep asking
How many statutory duties does a London landlord have?
The complete PRS stack runs to 17 distinct statutory duties when every category is in scope. A single-let 2-bed flat typically triggers around 9; a licensed 6-bed HMO in an Additional Licensing borough triggers all 17. The duties fall into four groups: Fire Safety (5), Structural and Hazard (4), Electrical and Energy (4), and Licensing and Legal (4). The For Landlords page interactive diagnoser scopes the specific stack against six property inputs.
What happens if a landlord misses a statutory duty?
Consequences vary by duty but are cumulative. Criminal prosecution and unlimited fines for serious Fire Safety Order, Gas Safety and asbestos breaches. Civil penalties up to £30,000 per offence for EICR, HMO/Selective licensing, MEES and HHSRS Category 1 under Housing and Planning Act 2016 s.126. Rent Repayment Orders up to 12 months' rent at the First-tier Tribunal. Insurance void for most fire-safety, gas and PAT failings. Reputational damage on the landlord portal once the Renters' Rights Act 2025 commences that provision.
Which duty has the highest penalty?
The Fire Safety Order 2005 and the Gas Safety (Installation and Use) Regulations 1998 carry unlimited fines and imprisonment on indictment. In civil-penalty terms, HMO licensing, EICR, MEES and HHSRS Category 1 all carry up to £30,000 per offence under Housing and Planning Act 2016 s.126. Right-to-Rent 2023 penalties can run to £10,000 per occupant for repeat breaches.
Which duties apply to a single-let family home?
A standard single-let typically engages around nine duties: fire risk assessment for common parts (block only), smoke and CO alarms, EICR on a five-year cycle, annual Gas Safety CP12, EPC and MEES Band E minimum, Legionella Risk Assessment, HHSRS hazard assessment, Right to Rent checks, and Tenancy Deposit Protection. Asbestos engages for pre-2000 buildings; HMO licensing does not. Selective Licensing may engage depending on borough designation.
Which duties apply to an HMO?
An HMO (3+ persons, 2+ households) engages all five Fire Safety duties, all four Electrical and Energy duties, all four Structural and Hazard duties, and typically all four Licensing and Legal duties. That is all 17 in most real-world cases. Specific HMO licence conditions (bedroom minima, bathroom ratios, refuse and cycle storage) are layered on top as contractual obligations under the licence itself.
How do I keep on top of all 17 duties?
Run a 12-month compliance calendar organised by cadence. Weekly fire-alarm tests, monthly emergency-lighting function tests, annual Gas Safety, annual PAT, quarterly fire-door inspections for 11 m+ blocks, 2-yearly Legionella review, 5-yearly EICR and HMO licence, 10-yearly EPC. Most landlords under-perform not because they miss the statute but because they run the calendar loosely. HSE's 17-duty compliance calendar and audit service is designed to tighten this for portfolios.
Every duty audited, every certificate refreshed, a live 12-month calendar for the portfolio
HSE audits every property against its specific duty stack, refreshes any stale certificate, and issues a live 12-month compliance calendar with named renewal dates. One partner, one evidence file per property per year.
08 · Where to go nextTwo practical follow-ups
If the 17-duty stack is how you want to think about compliance for your portfolio, these are the two reads that close the loop.
First, the For Landlords audience page, the interactive duty-stack explorer, the Compliance Obligation Diagnoser, the annual calendar, and the enforcement-risk tooling. Use it alongside this article as the operating console.
Second, subscribe to The HSE compliance briefing. One email a month covering regulatory and licensing updates across all 17 duties. When any of the four groups changes, new Fire Safety Regulations, a Band-C MEES update, a London borough designation, you will hear it from Kevin within the week.
HSE service for this topic
17-duty landlord compliance audit
Every duty audited against the property-specific stack, every certificate refreshed, a live 12-month calendar with named renewal dates. One file per property per year.