Complete HMO Safety Compliance Checklist for Scottish Landlords
Holding an HMO licence in Scotland means operating at a higher compliance bar than a standard private rented property. Councils in Edinburgh, Glasgow, Fife, Falkirk, Perth & Kinross, and every other Scottish local authority inspect HMO premises at grant and renewal, and most also conduct random annual spot checks. This is the practical checklist we'd give any Scottish HMO licence holder — the paperwork and physical items inspectors expect to see, and the order in which to tackle them.
Why This Checklist Matters
HMO licensing in Scotland operates under the Housing (Scotland) Act 2006. Your licence is valid for 3 years, and renewal is not automatic — it's a full re-inspection. Losing your licence, or having it granted subject to onerous conditions, damages your business materially. The good news: if you run tight compliance, renewal is routine.
The Statutory Documents
These are the documents every Scottish council expects to see at licence renewal. Get them all in a folder (physical or digital), dated, and clearly labelled.
Landlord Registration Certificate — You must be a registered landlord with your local authority. Check your registration is current and covers the property.
HMO Licence — The current licence, showing the property address and the maximum occupancy permitted.
Electrical Installation Condition Report (EICR) — Dated within the last 5 years, or dated to the most recent change of tenancy (whichever is more recent). Covers the fixed wiring, consumer unit, sockets, switches, and lighting circuits. Must be "satisfactory" or any C1/C2 remedial work completed and signed off.
PAT Testing Certificate — Dated within the last 12 months. Covers every appliance you supply with the property: kettle, toaster, microwave, fridge, freezer, oven, hob, washing machine, tumble dryer, hoover, lamps, TVs, fire alarms (if plug-in), and communal-area appliances. Each appliance labelled with pass date and next test date.
Gas Safety Certificate (CP12) — If gas is supplied. Dated within the last 12 months. Covers every gas appliance and the gas installation.
Fire Extinguisher Service Certificate — Dated within the last 12 months. Covers each extinguisher on the common stair and any kitchen unit. Issued to BS 5306-1 by a competent servicer.
Fire Risk Assessment — Current and reviewed annually. For HMOs with 4 or fewer occupants the assessment can be self-completed using the Scottish Government's template; for larger HMOs, a professional assessor is recommended.
Asbestos Management Plan — For the common parts of the HMO building. Based on a Management Survey by a BOHS P402-qualified surveyor. Required under the Control of Asbestos Regulations 2012 for buildings constructed before 2000.
Buildings Insurance — Current, with specific cover for HMO use (check your policy).
Energy Performance Certificate (EPC) — Current (valid for 10 years, but some councils want it dated within the last 5 for HMOs).
The Physical Items
Now walk the property with this list.
Fire doors — Every bedroom door and the kitchen door in an HMO must be a fire door, self-closing, with intumescent strips and smoke seals. No gaps exceeding 3mm around the frame. Number of doors varies by property layout — expect inspectors to check every single one.
Fire alarm system — Interlinked smoke and heat alarms are mandatory in Scotland since 1 February 2022. One smoke alarm per circulation space, a heat alarm in each kitchen, all interlinked (wirelessly or hardwired). Annual testing logged. HMO systems are typically upgraded to grade D1 or higher with battery backup.
Fire extinguishers — One appropriate extinguisher on each level of the common stair (typically 6-litre water-additive or 6kg dry powder). Kitchen extinguishers where shared cooking is provided (typically 2-litre wet chemical for class F fires). All serviced annually.
Fire blanket — One per communal kitchen, mounted in a visible position.
Emergency lighting — Required in HMOs where the escape route isn't naturally lit. Tested monthly (30-second flick test), annually (3-hour discharge test). Records kept.
Escape route signage — Clear signage at any change of level, junction, or doorway on the escape route. Photoluminescent to remain visible in a fire when power fails.
Electrical sockets and switches — No damaged or loose sockets. No overloaded extension leads permanently in use. RCD protection on sockets (your EICR confirms this).
Kitchen appliances — Working and supplied by the landlord (or clearly documented as tenant-owned). All included in the annual PAT test.
Bathroom extraction — Working mechanical extract or openable window in every bathroom.
Heating — Adequate fixed heating to every habitable room. Boiler serviced annually.
Locks on bedroom doors — Tenants must be able to lock their bedrooms. Escape from inside without a key is mandatory.
Council-Specific Requirements
Individual Scottish councils layer additional expectations on top of the national baseline. Edinburgh's HMO standards are among the strictest, with detailed requirements on kitchen size, bedroom floor area, and natural light. Glasgow, Dundee, Aberdeen, and the major towns each publish HMO licence guidance documents — download your council's before licence renewal.
The 60-Day Pre-Renewal Routine
60 days before your licence renewal date, follow this routine. You'll pass the inspection without drama.
Day 60: Email your council to confirm your renewal date and any new standards that apply since your last renewal.
Day 55: Book your PAT testing, fire extinguisher service, and any asbestos re-inspection needed. Book your fire risk assessment review.
Day 45: Walk the property with this checklist in hand. Note anything needing repair.
Day 40: Arrange repairs. Fire doors, self-closers, alarms, emergency lighting issues — all take longer than you think to sort.
Day 30: Retest everything. PAT and fire work completed. Certificates filed.
Day 25: Complete your landlord checklist. EICR valid? Gas valid? PAT done? Fire done? Asbestos plan reviewed?
Day 20: Photograph all fire equipment, escape routes, and signage for your file.
Day 15: Submit your renewal application with all documents attached.
Day 0: Licence renewed, property inspected, tenants safe, you sleep well.
Get Coordinated HMO Compliance Support
Arnold Pat Testing coordinates PAT testing, fire extinguisher servicing, and P402 asbestos surveys for Scottish HMO licence holders across Edinburgh, Glasgow, Fife, Falkirk, the Lothians, and every Scottish council area. One contractor, one schedule, one invoice, licence-ready documentation. Email us with your property details for a compliance package quote.