· Property Assessments for Landlords Services Ltd (PALS)
If you let property in England, your legal duties don't come from one place. They come from two separate regimes, written years apart, enforced by two different bodies — and most of the people offering to assess your property work in only one of them.
This article explains how the two systems fit together, where they overlap, and why we think the overlap is the strongest argument for choosing an assessor who is qualified in both.
Two laws, two enforcers
Fire safety in non-domestic premises — and that includes holiday lets, HMOs' shared areas and the structure and common parts of blocks of flats — sits under the Regulatory Reform (Fire Safety) Order 2005. It requires a suitable and sufficient fire risk assessment, and in Cornwall it is enforced by Cornwall Fire, Rescue and Community Safety Service.
Housing conditions sit under Part 1 of the Housing Act 2004, which covers residential premises — dwellings, HMOs and the common parts of buildings containing flats. Its assessment method is the Housing Health and Safety Rating System (HHSRS), revised in June 2026, and it is enforced by the local housing authority — in our case, Cornwall Council.
Different laws, different inspectors, different paperwork. And crucially: for a landlord with an HMO or a building containing flats, both regimes apply to the same building at the same time. The fire service can act on the common parts under the Fire Safety Order while the council acts on conditions inside the lettings under the Housing Act.
Fire doesn't respect the boundary
Here is the part that makes the split genuinely awkward: fire is itself one of the HHSRS hazards. A council inspector scoring your property under the HHSRS is required to consider fire risk — and since the June 2026 revision, the fire hazard has been widened to include associated risks such as smoke and fumes and structural collapse resulting from fire. The updated framework also anticipates housing authorities working more closely with Fire and Rescue Services on higher-risk properties.
So the boundary between the two regimes is not a wall; it is a seam. A means-of-escape problem in an HMO can surface as a Fire Safety Order matter, an HHSRS fire hazard, or both — and which document it lands in decides who comes knocking and which powers they use.
An assessor who only knows fire safety law will do their fire risk assessment, hand you the report, and walk past a Category 1 damp problem, a dangerous staircase or an excess cold hazard without recognising what any of them would mean the day a council inspector visits. Not through carelessness — it simply isn't their framework.
What a dual-qualified assessor does differently
Our background is over 20 years of combined Local Authority housing enforcement — the people who used to carry out these inspections for the council — alongside NFRAR third-party accreditation as fire risk assessors and HHSRS 2026 transition training. That combination changes what an assessment visit produces in three practical ways:
- One visit can cover both. A fire risk assessment and an HHSRS assessment can be carried out on the same day, in the same visit — one appointment, less disruption for tenants or guests, and reports that agree with each other rather than being written in ignorance of one another.
- Eyes in the property, whatever we're there for. Even when we are booked only for a fire risk assessment, we notice what a housing enforcement officer would notice. If there is a hazard the council would score, we'll tell you we saw it — before an inspector or a tenant complaint makes it formal.
- Recommendations that work under both regimes. The measures that satisfy a fire officer and the measures that satisfy a council inspector are not always the same. Knowing both sides means recommending fixes once, not twice.
That second point matters more than it sounds. Under the Renters' Rights Act 2025, councils have stronger powers and tenants are more confident about reporting poor conditions. The cheapest time to learn about a hazard in your property is while a friendly assessor is already standing in it.
An honest note on what the law requires
To be clear about the legal position: the Fire Safety Order requires a fire risk assessment for the premises it covers. The Housing Act does not require a landlord to commission a private HHSRS assessment — the HHSRS is the council's inspection tool, and a private assessment is a way of seeing your property the way an inspector would before the council does. One is a legal duty; the other is due diligence. We think landlords are better served by knowing the difference than by being told everything is mandatory.
If you want the detail on either regime, we've written about the June 2026 HHSRS changes and about when you can carry out your own fire risk assessment.
About Property Assessments for Landlords Services Ltd (PALS)
We provide accredited fire risk assessments and independent HHSRS assessments across Cornwall, including Truro, Newquay, St Austell, Bodmin and Liskeard. Both our assessors are Third-Party Accredited Intermediate Fire Risk Assessors on the National Fire Risk Assessors Register (NFRAR) and trained on the revised 2026 HHSRS framework. If a combined visit would suit your property, get in touch.