The HMO Landlord Who'd Never Heard of a Legionella Risk Assessment

The improvement notice she didn't see coming

Picture a landlord we'll call Priya. She runs a small, well-kept HMO near a university campus — five tenants, shared kitchen and bathrooms, the kind of property that's been profitable precisely because she's taken compliance seriously. Gas Safety record renewed every year without fail. EICR done on schedule. Smoke and heat alarms tested and logged. Her HMO licence was up to date and framed, almost, she'd joke, like a certificate of honour.

Then the council's environmental health officer came round for a routine HMO inspection and asked a question that stopped her cold: "Can I see your legionella risk assessment?"

She didn't have one. She'd never heard of it.

What a legionella risk assessment actually is

Legionella bacteria live in water systems — most commonly in stagnant water, infrequently used outlets, water tanks, and shower heads — and can cause a serious lung infection called Legionnaires' disease if inhaled in contaminated droplets. Landlords have a legal duty under health and safety law to assess the risk of legionella in their rented properties, and that duty applies with particular weight to HMOs, where shared water systems, multiple outlets, and rooms that sit empty between tenancies create more opportunities for water to stagnate.

For a lot of single-let properties, a simple visual check and a basic written record can be enough to show the risk has been considered. For HMOs — especially larger or older ones with water tanks, infrequently used rooms, or complex plumbing — a more thorough assessment, sometimes carried out by a qualified contractor, is the safer route. This isn't a certificate you renew annually by rote the way you might with a Gas Safety record; it's a risk assessment that should be reviewed periodically and whenever something changes — a new tenant, an empty room, altered plumbing. If you're not sure which category your property falls into, that's worth checking against current HSE and local authority guidance, or getting professional input, rather than guessing.

This article is general information, not legal advice — if you're unsure of your specific obligations, check current government and HSE guidance or speak to a suitably qualified professional.

Why this one slips through so easily

Priya's story isn't about carelessness. It's about where attention naturally goes. Gas Safety checks, EICRs, and smoke alarms dominate landlord compliance conversations — they're the certificates letting agents ask for, the ones insurers reference, the ones most compliance tools are built around. Legionella risk assessments get far less airtime, despite being a real legal duty, because they don't come with the same renewal rhythm or the same enforcement visibility. Nobody sends you a text the week before it's "due" in the way a CP12 reminder does, because there usually isn't a fixed expiry date — just an ongoing duty to keep the assessment current and act on what it tells you.

That's exactly the kind of gap that turns a well-run portfolio into a one-off improvement notice: not because the landlord cut corners, but because the obligation was never on their radar to begin with.

How she sorted it

Priya's fix, once she knew what she was looking for, wasn't dramatic. She arranged a proper legionella risk assessment for the property, acted on its recommendations — flushing through an underused outlet, insulating a section of pipework, setting a simple testing routine for a room that sits empty between academic years — and kept the written assessment on file alongside her other certificates. The council officer, satisfied that she'd moved quickly and in good faith, didn't take the matter further.

What stuck with her was how close she'd come to assuming "compliant" meant "every certificate I've heard of, renewed on time." It doesn't. Compliance is the floor, not a checklist you can tick off from memory — and the obligations that don't come with an annual reminder letter are often the ones that catch good landlords out.

The takeaway for other landlords and agents

If you manage an HMO, it's worth asking yourself the same question the council asked Priya: do you have a current legionella risk assessment on file, and do you actually know what's in it? It sits alongside — not instead of — your Gas Safety record, EICR, and HMO licence, and it deserves the same level of attention, even without a flashing renewal date to prompt you.

This is also where it's worth being honest about the tools landlords and agents lean on. A system that only ever reminds you about the certificates it's set up to track, while quietly steering you toward particular contractors to renew them, can leave the less commercial obligations invisible. CertMinder UK doesn't take referral fees or kickbacks from the contractors on your work orders — our job is to help you see what's actually due and keep proof of it, not to profit from who you hire. Visibility into every obligation, not just the popular ones, is the baseline we think every landlord and agent deserves.