A guest checking into a hotel surrenders something most people never think about: the ability to make an informed judgement about whether the building they are sleeping in is safe. They do not know whether the fire doors work, whether the alarm system is connected, or whether anyone has checked the escape routes recently. They are, in the words of the sentencing judge at the Old Bailey in 2015, placing their trust in the premise that the person responsible for the building is paying it "absolute attention."

That phrase — absolute attention — came from the prosecution of a Bayswater hotelier who was not. It is a useful starting point for understanding what the law expects of hotel and hospitality operators, and why enforcement authorities treat this sector as a priority.

Why Sleeping Accommodation Is Treated Differently

The Fire Safety Order applies to virtually all non-domestic premises. But the government's statutory guidance specifically identifies sleeping accommodation — hotels, guesthouses, bed and breakfasts, hostels and similar premises — as a distinct and higher-risk category, warranting its own dedicated guidance document.

The reason is straightforward. When people are asleep, their capacity to detect and respond to a fire is severely diminished. They are in an unfamiliar building, often on upper floors, without the instinctive knowledge of escape routes they would have in their own home. They may not hear an alarm. They may not know which way to run. In that context, the fire safety measures in place — the detection system, the fire doors, the emergency lighting, the escape routes — are not a back-up to personal vigilance. They are the only defence.

The government's statutory guidance for sleeping accommodation is unambiguous on this point: virtually all premises providing overnight accommodation will need an electrical fire detection and warning system incorporating automatic fire detection, sounders and manually operated call points. In larger or multi-storey premises — which covers most hotels and guesthouses of any scale — a comprehensive automatic detection system with a control panel is likely to be required. This is not guidance that admits much flexibility.

Hotels are considered high fire risks. They are exposed to the carelessness of guests, to accidental and deliberate disabling of fire precautions, and to the particular vulnerability of people sleeping in unfamiliar buildings. The responsible person's duty reflects that risk directly.

The Specific Duties for Hotel Operators

The Fire Safety Order's requirements apply in full to hotels and hospitality venues. The responsible person — typically the owner, operator or manager with day-to-day control of the premises — must carry out and maintain a suitable and sufficient fire risk assessment, implement the preventive and protective measures it identifies, and keep both the assessment and those measures under review.

For hotels specifically, that assessment must address a number of factors that do not arise in the same way in a standard commercial premises.

Fire detection and warning

An automatic system is not optional in premises where guests sleep The statutory guidance is clear: sleeping accommodation of any meaningful scale requires an automatic fire detection and warning system. The system must be capable of waking sleeping guests and alerting staff. It must be properly installed, regularly tested and maintained, and its maintenance must be documented. A system that exists but does not work — or that has been disabled — provides no protection and will be treated by enforcement authorities accordingly.

Means of escape

Escape routes must be adequate, clear and usable at all times Every guest room must have a clear, protected route to a final exit. In multi-storey premises, protected stairways are the primary means of escape — and their integrity depends entirely on the fire doors that protect them. Doors tied or wedged open, damaged door closers, absent intumescent strips — these are the failures that turn a survivable fire into a fatal one. Escape routes must not be used for storage. They must be illuminated by emergency lighting. They must be signed.

Guest information

Guests must know what to do before a fire starts Fire action notices in guest rooms, information on the back of bedroom doors, and staff briefings for guests are all part of meeting the responsible person's duty. Guests who are unfamiliar with the building cannot be expected to respond correctly in an emergency unless they have been given the information to do so. This is especially relevant where the guest mix includes elderly visitors, families with children, or guests with mobility impairments.

Staff training

Trained staff are the most important life-safety resource in a hotel fire In a hotel fire, guests depend heavily on staff. Staff must know how to raise the alarm, how to assist guests to evacuate, how to account for all occupants, and when not to re-enter the building. Fire safety training must be provided on induction and refreshed regularly — and training records must be kept. High staff turnover, common in hospitality, makes regular training more important, not less.

The fire risk assessment

The FRA must reflect the actual risk profile of the premises A generic or outdated fire risk assessment is of limited value and limited legal protection. The assessment must be specific to the premises, must be reviewed whenever anything changes — a refurbishment, a change of use, a new extension — and must be reviewed at regular intervals regardless. Our post on how often a fire risk assessment should be reviewed covers this in detail.

What the Courts Have Said

The prosecution record in the hotel sector is clear, consistent, and worth understanding in detail. The following cases all involve premises where the basic requirements were not met, and where enforcement authorities took the view that prosecution was the appropriate response.

Bayswater, London, 2015 — The Radnor Hotel

London Fire Brigade officers visited The Radnor Hotel on Inverness Terrace in 2011 during a routine inspection and found numerous fire safety breaches. An enforcement notice was issued requiring the deficiencies to be resolved. Follow-up visits found nothing had been done. The hotel continued to operate without a working fire detection system.

The owner, Salim Patel, pleaded guilty at the Old Bailey to seven offences under the Fire Safety Order. He was fined £200,000 — at the time the largest fine ever secured by London Fire Brigade against an individual — ordered to pay nearly £30,000 in costs, and given a four-month prison sentence, suspended for 18 months.

Sentencing Judge Kennedy said the public expected "absolute attention" to fire safety when occupying sleeping accommodation in a hotel, and that as the business owner, Patel was where the "buck stopped." London Fire Brigade's head of fire safety regulation said the size of the fine should serve as a reminder of the seriousness with which the courts treated fire safety obligations.

Stratford, London, 2020 — The Baytree Hotel

London Fire Brigade officers visited The Baytree Hotel in Vicarage Lane during a routine audit in January 2019. They found no smoke detection, numerous fire doors tied open and missing or malfunctioning door closers, and a first-floor external emergency exit route blocked along almost its entire length by stored rubbish.

The company, Act Grange Ltd, and its sole director Falgun Patel were ordered to pay a combined £45,000 at Southwark Crown Court after pleading guilty to five Fire Safety Order breaches. London Fire Brigade's assistant commissioner described the failings as "serious and systemic" and noted that if guests had tried to escape in a fire, they would have found their escape route "compromised and unusable, trapping them in the building." He added: "It was simply a matter of luck that there hadn't been a fire at the hotel."

Barking, London, 2022 — The Bank Hotel

London Fire Brigade inspectors visited The Bank Hotel on Ripple Road in May 2018, finding deficiencies significant enough to warrant an immediate prohibition notice. The hotel had no fire doors, no smoke detectors and no fire alarm system. When further inspections were carried out in the following months, the prohibition notice, originally affixed in the owner's presence, had been removed from the door. The hotel had continued to take guests.

Owner Naveed Mir was found guilty after a trial at Southwark Crown Court and fined £40,000 with £10,000 costs. He received custodial sentences, suspended for two years. London Fire Brigade noted that the combination of no fire alarm, insufficient means of escape, ongoing refurbishment work and cigarette butts found throughout the property "could have been a recipe for disaster."

The Pattern These Cases Reveal

Reading these cases together, a consistent pattern emerges. In each instance, the deficiencies were not obscure or technical — they were fundamental: no working alarm, fire doors propped open, escape routes blocked. In each instance, the responsible person had been informed by the fire service that something was wrong. And in each instance, nothing was done.

The courts' response has been equally consistent. Hotel operators who fail to provide basic fire safety measures for sleeping guests, and who continue to operate after being told their premises are non-compliant, face significant fines, custodial sentences and the reputational consequences of a public prosecution. The enforcement authorities have been explicit: they will not hesitate to prosecute where responsible persons are not taking their obligations seriously.

For a sector with high staff turnover, significant pressure on margins and a culture that tends to treat maintenance as a cost rather than a duty, that message is worth taking seriously.

The Audit Picture for Hotels

Hotels and hospitality premises feature prominently in Fire and Rescue Service audit data. The most recent MHCLG statistics, covering 2024–25, recorded hospitality settings — hotels, boarding houses and hostels — as the fourth highest category for fire incidents in non-residential premises, with 505 fires recorded. As we noted in our post on fire safety audit failures, 42% of all audits in England returned an unsatisfactory result in 2024–25 — the worst rate since records began. Hotels are not exempt from that trend.

An FRS audit of a hotel that finds non-compliance does not automatically lead to prosecution. The fire service's preferred approach is to work with operators to achieve compliance. But where deficiencies are identified, an enforcement notice is served, and nothing is done — as in every case described above — prosecution follows. The Radnor Hotel case illustrates the timescale: a routine inspection in 2011, an enforcement notice, follow-up visits, and a prosecution that concluded at the Old Bailey in 2015. Four years. A £200,000 fine. A suspended prison sentence. And a business that no longer exists.

We carry out fire risk assessments and fire door inspections for hotels and hospitality premises across Chester, the North West and North Wales. If you are not confident that your current fire safety provision meets the standard the law requires for sleeping accommodation, get in touch.

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Sleeping accommodation carries a distinct legal duty of care. We carry out thorough, professionally qualified fire risk assessments and fire door inspections for hotels and hospitality premises across Chester, the North West and North Wales.

Disclaimer: This article is intended as general guidance only and does not constitute legal advice. The legal position described reflects the law as it applies in England and Wales. Case details are drawn from publicly available court records, London Fire Brigade press releases and fire service reports. Responsible persons facing enforcement action or investigation should seek independent legal advice. Fletcher Risk Management is not a law firm and accepts no liability for actions taken or not taken on the basis of this article. Fletcher Risk Management is based in Chester and provides fire risk assessments, fire door inspections and fire safety training across the North West and North Wales. © Fletcher Risk Management Ltd, March 2026.