HMO Licensing in London — What Landlords and Developers Need to Know

Under the Housing Act 2004, a House in Multiple Occupation (HMO) is a property rented to three or more people who form two or more separate households and share facilities such as a kitchen or bathroom.

• **Examples of HMOs**:
• •A 5-bedroom house rented to 5 individual sharers who each have their own tenancy agreement
• •A 4-bedroom house rented by two couples who are not related to each other
• •A converted property with bedsit rooms sharing a common kitchen and bathroom

• **Not an HMO**:
• •A family renting a house (all one household)
• •Two people sharing (only two people, so below the three-person threshold)
• •Student accommodation directly managed by a university

Note: Some councils use a slightly broader definition in their additional licensing schemes — always check with the specific London borough.

• Mandatory HMO licensing applies nationally to properties that:
• •Are occupied by **5 or more people** forming **2 or more households**
• •Have at least some shared facilities (kitchen, bathroom, or WC)

This is sometimes called a 'large HMO' licence. The mandatory licensing scheme applies across all of England regardless of what the local council does.

**Smaller HMOs (3–4 occupants)** may still require a licence if the council has introduced an **Additional Licensing Scheme** covering their area. In London, the majority of boroughs have introduced additional licensing — covering 3+ person HMOs or even all privately rented properties in some areas.

**London boroughs with additional or selective licensing** (as of 2025) include: Newham (whole borough selective licensing), Tower Hamlets, Hackney, Lewisham, Southwark, Lambeth, Brent, Haringey, Waltham Forest, and many others. The coverage expands regularly.

**What this means in practice**: In most inner London boroughs, a 3-person HMO requires a licence — not just properties with 5+ occupants. Check your specific borough before assuming mandatory national licensing is the only obligation.

One of the most important changes to HMO regulations came in October 2018, when national minimum room sizes were introduced. These are now mandatory across all licensed HMOs in England:

• **Minimum sleeping room sizes**:
• •Adults (over 10): **6.51m² minimum**
• •Children (under 10): **4.64m² minimum**
• •Two adults sharing: **10.22m² minimum**

Rooms smaller than these minimums cannot be used as sleeping rooms in a licensed HMO. The measurement is of the usable floor area — alcoves, bay windows, and areas under sloping roofs below 1.5m do not count.

**Many London landlords discovered post-2018 that their HMO properties contained rooms smaller than 6.51m²** — particularly in converted Victorian terraces where original back bedrooms can be as small as 5m². These rooms had to be either taken out of use as sleeping accommodation, or the property's licensed room count was reduced.

Councils have the power to set local minimum sizes above the national minimum. Some London boroughs require larger minimums — check with the specific borough.

Fire safety is the single most prescriptive area of HMO regulation. Licensed HMOs must meet specific fire safety standards that go significantly beyond what an ordinary family home requires:

• **Fire detection and alarm system (FD&A)**:
• •A Grade D, LD2 or LD1 fire alarm system is typically required
• •Interlinked smoke detectors in all rooms and circulation areas
• •Heat detectors in the kitchen (not smoke detectors, which produce false alarms in cooking environments)
• •Fire alarm panel in larger HMOs
• •Annual servicing and testing log

• **Fire doors**:
• •All doors opening onto a means of escape (escape staircase, corridor) must be fire-rated doors (typically FD30 — 30 minutes fire resistance)
• •Fire doors must have self-closers fitted
• •Kitchen doors must be FD30S (fire and smoke rated) in many cases
• •This requirement catches many converting landlords — all bedroom doors, bathroom doors, and kitchen doors in a corridor-based HMO typically need upgrading

• **Means of escape**:
• •Clear, unobstructed route from all sleeping rooms to external exit
• •Emergency lighting on means of escape in larger HMOs
• •No combustible storage in escape routes

• **Compartmentation**:
• •Fire-stopping of all penetrations through walls and floors (pipes, cables) between units
• •Cavity barriers in roofspace where required

• **Furniture**:
• •All soft furnishings provided by the landlord must meet the Furniture and Furnishings (Fire) (Safety) Regulations 1988

**Gas safety**: Annual gas safety check (Gas Safe registered engineer) and a valid certificate, as with all privately rented properties.

Converting a family home to a licensed HMO — or bringing an unlicensed HMO up to standard — typically requires the following works:

• **Fire safety package** (almost always required):
• •New fire alarm and detection system (Grade D, LD2 or LD1)
• •Upgrading all bedroom, bathroom, and kitchen doors to FD30 fire doors with closers
• •Fire-stopping of all service penetrations through walls and floors
• •Fire-resistant ceiling to underside of escape staircase in many cases

• **Room reconfiguration** (common in larger conversions):
• •Adding en-suite shower rooms to some or all bedrooms (increases rental income significantly)
• •Dividing larger rooms to create more lettable units (subject to room size minimums)
• •Removing small rooms from sleeping use if below 6.51m²

• **Kitchen upgrade**:
• •Many HMO landlords upgrade shared kitchens to multiple cooking stations where five or more occupants share
• •Additional kitchen capacity (two hobs, two fridges, additional storage) is expected in 5+ bed HMOs

• **Bathroom provision**:
• •Councils set ratios — typically a maximum of 4–5 occupants per bathroom/shower room
• •Additional bathrooms or en-suites may be required to achieve the licensed room count

• **Electrical upgrade**:
• •EICR (Electrical Installation Condition Report) required before licensing
• •Smoke detector circuit added to consumer unit
• •Any remedial works identified in the EICR

• **Insulation and EPC**:
• •Minimum EPC rating of E is required for all privately rented properties; councils can enforce higher minimums
• •Loft insulation, cavity wall insulation, and boiler upgrade may be required

**Cost of a full 3-bedroom to 5-room HMO conversion**: £40,000–£75,000 **Cost of a 4-bedroom to 6-room HMO conversion with en-suites**: £70,000–£120,000+

Once the property meets the required standards, the HMO licence application is made to the local council. Each borough has its own process, but the typical requirements are:

• •Completed application form (online in most boroughs)
• •Application fee (varies by borough — typically £500–£1,500 per licence for a 5-year term)
• •Evidence of gas safety certificate
• •Evidence of electrical installation condition report (EICR)
• •Evidence of fire alarm system installation and servicing
• •Floor plans showing room sizes, door positions, means of escape
• •Landlord/manager details and fit-and-proper person declaration
• •Proof of buildings insurance

Council inspection: most boroughs inspect the property before issuing the licence. Inspectors assess compliance with the licence conditions and the Housing Health and Safety Rating System (HHSRS).

**Licence duration**: HMO licences are typically granted for 5 years. They are not transferable — if the property is sold, the new owner must apply for a new licence.

**Unlicensed HMOs**: Operating an HMO without a required licence is a criminal offence. The maximum fine is unlimited (magistrates court). Tenants can also apply for a Rent Repayment Order (RRO) — recovering up to 12 months' rent from the landlord — if the property was unlicensed during their tenancy.