Since October 2022, Your Acquisition Target Owes £5,000 Per Property if Smoke and CO Alarms Aren't Installed

Since October 2022, the Smoke and Carbon Monoxide Alarm (Amendment) Regulations have expanded what landlords must do to keep tenants safe. If you manage residential buildings in England, the rules now cover more rooms and more appliances. Non-compliance can cost you up to £5,000 per property.

Here is what changed, what it means for your portfolio, and how to stay ahead of enforcement.

The 2022 amendment closed a gap in the old rules

The original 2015 regulations required smoke alarms on every storey and carbon monoxide (CO) alarms in rooms with solid fuel appliances. That left gas boilers, gas fires, and biomass systems outside the CO alarm requirement.

The 2022 amendment fixed that. Now, a CO alarm must be installed in any room containing a fixed combustion appliance. That includes gas boilers, gas hobs, oil-fired systems, and biomass burners. The only exception is rooms with gas cookers alone — but if a gas boiler sits in the same room as a cooker, the alarm is required.

Smoke alarms remain mandatory on every storey used as living accommodation. That means a hallway on each floor, not just the landing. If a tenant rents a flat spread over two levels, both floors need a smoke alarm.

Fines for non-compliance rose to £5,000 per property. Local authorities can issue penalty notices without going to court. They can also require remedial action within 28 days.

What this means for your day-to-day operations

If you manage a portfolio of rented homes — from single flats to multi-storey blocks — the practical impact depends on your existing setup.

Check every room with a gas boiler. Many properties built before 2022 have a CO alarm in the living room or hallway but not in the utility cupboard or kitchen where the boiler sits. That is now a compliance gap. A CO alarm must be within audible range of the sleeping area, but the regulation specifically requires it in the room with the appliance.

Test and log. The regulations do not require a specific brand or model, but the alarms must comply with British Standards (BS EN 50291 for CO, BS EN 14604 for smoke). Battery-powered units are acceptable, but hardwired alarms with sealed lithium batteries reduce the risk of tampering. Log the installation date, test date, and battery replacement schedule. A tenant complaint or a routine inspection can trigger a local authority check.

Renewal is the trigger. The regulations apply at the start of each new tenancy. If a tenancy began before October 2022 and has not been renewed, the old rules still apply. But every new tenancy or renewal after that date must meet the expanded requirements. That means your compliance window opens every time a lease turns over.

Shared houses and HMOs. Houses in multiple occupation (HMOs) already had stricter fire safety rules under the Housing Act 2004. The 2022 amendment adds CO alarm requirements to those properties. If your HMO has a gas boiler in a communal kitchen, that room now needs a CO alarm. If each bedroom has a gas fire, each bedroom needs one.

Enforcement is real and rising

Local authorities have been issuing penalty notices since the amendment took effect. In 2023, several councils in London and the South East issued fines of £2,500 to £5,000 per property for missing CO alarms. One landlord in Manchester received a £4,000 penalty for a flat with a gas boiler and no CO alarm in the boiler cupboard.

The Health and Safety Executive (HSE) also takes a dim view of CO exposure. A tenant hospitalised by carbon monoxide poisoning can lead to a prosecution under the Health and Safety at Work Act. The fine for that can run into six figures, plus legal costs and reputational damage.

Insurance companies are paying attention too. Some policies now require proof of compliant alarms before they will pay out on a fire or CO claim. If a tenant dies or is injured and your alarms were missing, your insurer may deny coverage.

How this connects to your wider building safety obligations

The 2022 amendment is one piece of a larger shift in UK building safety regulation. The Building Safety Act 2022 introduced new duties for building owners of higher-risk residential buildings. The Fire Safety Act 2021 clarified that fire doors and external wall systems fall under the Regulatory Reform (Fire Safety) Order 2005.

For landlords managing older stock, the overlap matters. A property that needs a CO alarm under the 2022 amendment may also need a fire risk assessment under the 2005 Order. A block of flats with a gas boiler in each flat needs both a fire risk assessment for the common parts and individual CO alarms in each flat.

We covered the fire compartmentation requirements in an earlier post: Building Regulations 2024 Fire Compartmentation Update: What Your Insurance Renewal Will Demand. The same principle applies here — compliance is not optional, and insurance will check.

For landlords with commercial or mixed-use buildings, the MEES EPC Band E deadline adds another layer. A property that fails on energy efficiency may also fail on safety if alarms are missing. The two are separate regulations, but a single inspection can catch both.

What this looks like in practice

Start with a simple audit. Walk every property in your portfolio. Note the location of every fixed combustion appliance — gas boiler, gas fire, oil boiler, biomass stove. Check whether a CO alarm is installed in that room. Check whether a smoke alarm is installed on every storey. Test each alarm. Replace any unit older than 10 years or with a missing test date.

Document everything. A spreadsheet with property address, appliance type, alarm model, installation date, and last test date is enough. Keep it accessible for local authority inspections.

If you manage a large portfolio, consider a digital log. A building management platform can track alarm status, send reminders for battery changes, and flag properties that need attention before a tenancy renewal. That is where HermanWa comes in — we help building operators monitor compliance across multiple properties without chasing paper records.

The 2022 amendment is not new, but enforcement is accelerating. If you have not audited your portfolio since October 2022, now is the time. A £5,000 fine per property adds up fast. A tenant injury adds up faster.

— The HermanWa Team