Updated: 27 September 2026. Emergency lighting is not automatically required in every HMO in exactly the same form. The need depends on the building layout, escape route, natural and borrowed light, occupancy, risk level, local licensing conditions and the fire risk assessment.
Where emergency escape lighting is required, it must be capable of helping occupants find and use the escape route if the normal lighting supply fails. For London landlords and managing agents, the practical task is to confirm whether the system is needed, whether it is adequate for the building, and whether testing and servicing are being recorded properly.
Emergency lighting in HMOs: the position at a glance
| Question | Practical answer |
|---|---|
| Does every HMO need emergency lighting? | No. Need depends on risk, layout, escape route, natural light and local standards. |
| When is it commonly required? | Long, complex or dark escape routes, larger or higher-risk HMOs, and where the fire risk assessment or licence conditions require it. |
| What happens if normal lighting fails? | The emergency system should automatically illuminate the escape route. |
| How often is it checked? | Routine visual/function checks plus periodic full-duration testing, commonly monthly and annually in recognised guidance. |
| Who should carry out annual servicing? | A competent person familiar with emergency-lighting systems and the relevant standard. |
| Should records be kept? | Yes. A fire logbook or equivalent record is good practice and may be required by licence conditions. |
What is emergency escape lighting?
Emergency escape lighting is a secondary lighting system designed to operate when the normal electrical supply to the escape-route lighting fails. Its purpose is to provide enough illumination for people to leave the building safely and to make hazards such as stairs, changes in level, direction changes and final exits visible.
Government fire-safety guidance for residential buildings identifies emergency lighting as one of the fire-safety measures that a responsible person may need to provide and maintain where the risk assessment shows it is necessary.
Does every HMO need emergency lighting?
No. Small, straightforward HMOs with good natural or borrowed light and simple escape routes may not need the same emergency-lighting provision as larger, darker or more complex properties.
Local-authority HMO guidance commonly says emergency lighting is more likely to be required where escape routes are long or complex, where there is little effective borrowed light, where the property has more storeys, or where occupants may be more vulnerable.
For example, London Borough of Hammersmith & Fulham guidance identifies emergency lighting requirements for larger HMOs with dark or complex escape routes, three-storey HMOs and bedsit-style HMOs. Other councils may use different detailed standards, so the relevant borough and licence conditions must always be checked.
What does the fire risk assessment have to do with emergency lighting?
The fire risk assessment is central because it should consider whether people can escape safely if normal lighting fails. The assessment should look at the route length, complexity, changes in level, staircases, internal rooms, borrowed light, occupancy and any vulnerable residents.
If the assessment identifies inadequate escape-route lighting, emergency lighting may be one of the control measures required. The responsible person then needs to make sure the system remains suitable and properly maintained.
For the wider fire-safety process, see our Fire Risk Assessments for Blocks of Flats guide.
How often should emergency lighting be tested?
Recognised emergency-lighting maintenance guidance uses a combination of routine checks and periodic testing. Local-authority HMO guidance commonly refers to:
- visual checks during routine visits to confirm indicators and obvious condition
- short function tests at regular intervals, commonly monthly
- full-duration tests at least annually to confirm the system can operate for its designed duration
Oxford City Council’s HMO guidance, for example, describes visual checks, monthly short tests and a full annual test. The exact regime should follow the system design, manufacturer instructions, the applicable standard and any local licence condition.
What happens during a monthly function test?
A short function test is intended to confirm that the emergency fittings change over to battery or emergency operation when the normal supply is interrupted.
The person carrying out the check should confirm that the relevant fittings illuminate and that no obvious defect is present. After the test, the normal supply should be restored and any indicators checked to confirm the units are charging correctly.
What happens during the annual full-duration test?
The annual test is longer and is designed to show that the emergency lighting can remain illuminated for the required duration. Many HMO systems are designed around a multi-hour duration, but the exact specification depends on the system and building.
Because batteries can be discharged during a full-duration test, it should be planned so the building is not left without adequate emergency protection while the units recharge. Higher-risk systems should be tested and serviced by a competent professional.
What should an emergency-lighting record include?
- property address and system location
- date of the inspection or test
- type of test performed
- fittings or areas checked
- defects identified
- repair or replacement action
- date the action was completed
- name or role of the person carrying out the test
For HMOs with formal fire logbooks, emergency-lighting records should sit alongside fire-alarm, fire-door and other fire-safety checks so the management history is clear.
What are common emergency-lighting defects?
- failed lamps or LED modules
- battery failure or reduced duration
- damaged fittings
- obscured or poorly positioned units
- incorrect charging indicators
- lights that do not switch to emergency mode
- coverage gaps following building alterations
- escape-route changes that are not reflected in the system layout
A building can also become under-protected even where the fittings themselves work—for example, if walls, partitions or escape routes change after refurbishment.
Do London boroughs have their own HMO emergency-lighting standards?
Yes. London boroughs can impose HMO standards and licence conditions that are more specific than general fire-safety guidance. Some boroughs specify the types of HMOs that require emergency escape lighting and may require test certificates or periodic evidence.
This is why a London landlord should check both the fire risk assessment and the relevant council’s HMO/licensing guidance instead of assuming one city-wide rule applies to every property.
Is emergency lighting required in blocks of flats?
It can be. Government guidance for blocks of flats states that responsible persons must assess and maintain fire-safety measures, which can include emergency lighting. Whether it is required, and the extent of the system, depends on the building and fire strategy.
A modern purpose-built block with well-designed common areas may have different requirements from an older converted building or an HMO. The fire risk assessment should identify what is needed.
Emergency lighting services in London
Primelinks Solutions helps landlords, HMO operators, freeholders and managing agents coordinate emergency-lighting and wider fire-safety requirements across London.
- See our fire risk assessment service.
- For the wider building review, see Fire Risk Assessment.
- Read our Fire Doors & Emergency Lighting Guide.
- For HMO duties, see the HMO Compliance Checklist for London Landlords.
- For London coverage, see our London coverage page.
Frequently asked questions
Does every HMO need emergency lighting?
No. The need depends on factors such as the escape route, natural light, building layout, occupancy, fire risk assessment and local HMO standards.
How often should emergency lighting be tested?
Recognised maintenance regimes commonly use regular visual checks, short monthly function tests and a full annual duration test, subject to the system design, manufacturer instructions and local requirements.
Does an HMO need an annual emergency-lighting certificate?
Some local authorities and HMO licence conditions require annual certification or evidence. The relevant borough’s requirements should be checked for the specific property.
Who should carry out the annual emergency-lighting test?
A competent person should carry out formal testing and servicing, particularly where a full-duration test, fault diagnosis or certification is required.
Need emergency-lighting testing in London?
Use Get a Quote and provide the property address, building type, number of storeys, whether it is an HMO or block of flats, and any existing fire risk assessment or emergency-lighting certificate.
This article provides general information and is not fire-engineering or legal advice. Requirements depend on the building, fire risk assessment, local licence conditions and applicable standards.