Smoke and CO Alarm Regulations (Post-2022): Landlord Guide
← Part of Landlord Laws & LegislationThe Smoke and Carbon Monoxide Alarm (England) Regulations 2015, as substantially amended in 2022, require landlords to install working smoke alarms on every storey of a let property and carbon monoxide alarms in every room with a fixed combustion appliance (excluding gas cookers). Alarms must be tested at the start of every new tenancy. Civil penalties of up to £5,000 per property per breach apply, rising to £30,000 in line with other compliance regimes. The 2022 amendments substantially expanded the CO alarm requirement — many landlords still have not caught up. This page covers the Regulations in full, the alarm types and standards, the testing obligation, the penalty regime, and the practical compliance approach.
What the Regulations do
The Smoke and Carbon Monoxide Alarm (England) Regulations 2015 require landlords to install and test working smoke and carbon monoxide alarms in residential property let on tenancies. Originally limited in scope, the Regulations were substantially amended in 2022 to extend their carbon monoxide alarm requirements and apply equivalent standards to social housing. The amended regime took effect on 1 October 2022 and represents the current regulatory framework.
The Regulations are conceptually simple but operationally important. They turn on physical installations (alarms) that cost very little to comply with — typically £50-£200 per property for a complete set of alarms — but failure to install attracts civil penalties of up to £5,000 (rising to £30,000 in line with the broader housing enforcement framework). Beyond the financial cost of non-compliance is the substantially higher human cost where a fire or carbon monoxide incident produces an injury or death that working alarms would have prevented.
Compliance among professional landlords is now near-universal but pockets of non-compliance remain — particularly around the 2022 extension of CO alarm requirements, which many landlords still have not caught up with. The 2022 amendments brought every room with a fixed combustion appliance (other than gas cookers) within scope, where previously only solid-fuel appliances triggered the requirement. Landlords with gas boilers in kitchens, gas fires in living rooms, or wood burners need to verify their CO alarm provision against the post-2022 standards.
Smoke alarm requirements
Regulation 4 requires a working smoke alarm to be installed on every storey of a property where there is at least one room used wholly or partly as living accommodation. The "every storey" rule means:
- Single-storey flats: at least one smoke alarm.
- Two-storey houses: at least two smoke alarms (one upstairs, one downstairs).
- Three-storey houses: at least three smoke alarms.
- Properties with habitable basements or attics: an additional alarm in those spaces.
The location on each storey must be appropriate — typically in the hallway or landing where the alarm will detect smoke from any room. A smoke alarm in a single bedroom or kitchen alone does not satisfy the requirement.
The Regulations do not specify whether the alarm must be battery-powered or mains-wired — both satisfy the requirement. In practice:
- Sealed 10-year battery alarms are the simplest compliance route for non-HMO single-household lets. Cost £15-£25 per alarm; battery lasts the alarm's lifetime; replace the entire alarm at the end. No electrical installation required.
- Mains-wired alarms with battery back-up are required by HMO licence conditions in many cases and are the higher standard for larger properties. Cost £40-£80 per alarm plus installation. Last 10+ years and operate during power cuts.
- Interlinked alarms — where activation of one sounds all of them — are not required by the 2015/2022 Regulations but are required by HMO licence conditions in many cases.
Smoke alarms must comply with BS EN 14604, the European standard for smoke alarms. Most alarms sold in the UK retail market satisfy this standard; check the packaging or product listing before purchasing.
Carbon monoxide alarm requirements (post-2022)
The 2022 amendments substantially expanded the CO alarm requirements. Under the original 2015 Regulations, a CO alarm was required only in a room with a solid fuel appliance. The amended Regulations require a CO alarm in every room used wholly or partly as living accommodation that contains a fixed combustion appliance (excluding gas cookers).
In practice this means:
- Any room with a gas boiler — typically the kitchen, utility room, or airing cupboard.
- Any room with a gas fire — typically the living room.
- Any room with a solid fuel appliance (wood burner, multi-fuel stove, open fire).
- Any room with an oil-fired appliance (less common in residential).
- Any room with an LPG appliance.
Gas cookers are excluded from the CO alarm requirement. The reasoning: gas cookers are intermittent appliances under direct user control with adequate ventilation, whereas boilers and fires run unattended and are the most common sources of CO incidents. The exclusion is narrow — a kitchen with a gas boiler still needs a CO alarm even if the cooker is also gas.
CO alarms must comply with BS EN 50291, the European standard for carbon monoxide alarms.
Testing at the start of every new tenancy
Regulation 4(5) imposes a specific testing obligation: alarms must be tested at the start of every new tenancy. The "test" means physically pressing the test button and confirming the alarm sounds.
Best practice for documenting the test:
- Test all alarms in the presence of the tenant at occupation.
- Document the test — a brief written note ("Smoke alarms tested in tenant's presence on [date]; all functioning") signed by tenant and landlord. Photographs of the alarms in situ on the inventory date are valuable corroboration.
- Provide written guidance to the tenant on how to test alarms during the tenancy and what to do if one stops working.
Once the start-of-tenancy test has been documented, the on-going responsibility for testing and battery replacement (where applicable) falls on the tenant. The landlord's obligation is to ensure the alarms are operational at the start; the tenant's obligation is to maintain that operation during their occupation. The landlord's duty re-engages if the tenant reports an alarm failure — the landlord must then repair or replace as soon as reasonably practicable.
Penalties and enforcement
Regulation 13 establishes the enforcement framework. Local authorities serve a "remedial notice" requiring the landlord to install or repair alarms within 28 days. Failure to comply triggers civil penalty exposure:
- Penalty for breach: currently up to £5,000 per property per breach. Being raised to £30,000 in line with other compliance regimes (date subject to consultation).
- Local authority remedial action: where the landlord does not act on the notice, the local authority can carry out the works themselves and recover the cost from the landlord — typically with a substantial markup for administrative costs.
The penalty is per property, not per missing alarm. A landlord with five missing alarms across a single property faces one penalty (up to £5,000). A landlord with five missing alarms across five properties faces five penalties.
Insurance consequences: standard buy-to-let policies often require working smoke and CO alarms as a condition of cover. A fire-related claim where the alarms were missing or non-functional may be refused.
Practical compliance approach
A landlord operating professionally:
Audits the alarm position at every property. Walk through each property and confirm: smoke alarm on every storey, CO alarm in every room with a fixed combustion appliance.
Uses sealed 10-year battery alarms as standard. Buy a brand-name product (Aico, FireAngel, Kidde) rather than the cheapest available. Total cost for a typical 3-bedroom house: £80-£150.
Documents the start-of-tenancy test with a short note in the inventory or a separate signed record.
Replaces alarms preemptively at 8-9 years rather than waiting for end-of-life beep at year 10.
Tests alarms during periodic inspections. A 30-second test during the routine 6-month inspection confirms the alarm continues to function.
See our smoke and CO alarms guide for the operational detail.