For mandatory licensable HMOs (broadly, properties with five or more occupants forming two or more households), the local authority licensing regime imposes specific fire safety conditions on top of the FSO duty. Conditions vary by local authority but typically include smoke alarms in every habitable room, heat alarms in kitchens, fire blankets or extinguishers in shared kitchens, and fire doors on bedrooms in some configurations.
Local authorities can also operate additional or selective licensing schemes that bring smaller HMOs into the regime. The FRA workflow does not depend on licensing status; it depends on the building meeting the statutory definition of an HMO. If the building is an HMO, the FRA covers it whether or not licensing applies.