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What Is an HMO?
A House in Multiple Occupation (HMO) is a property occupied by three or more people who form two or more separate households and share facilities such as a kitchen or bathroom. The definition matters because HMOs are subject to additional regulation compared to standard single-household tenancies — including licensing requirements that carry significant penalties if ignored.
For London landlords, HMO regulation is particularly important because much of the capital's rental market involves multi-occupancy arrangements, and London boroughs tend to be among the most active in applying and enforcing HMO licensing schemes.
The Three Tiers of HMO Licensing
1. Mandatory HMO Licensing
Mandatory licensing applies nationally to any HMO that is:
- Five or more people forming two or more households
- Who share facilities (kitchen, bathroom)
- Regardless of the number of storeys
This is a national requirement that applies across all London boroughs and the rest of England. There is no exemption based on building age, property type, or location within a borough.
If your property meets this definition and you do not hold a licence, you are committing a criminal offence. The penalties include:
- An unlimited fine
- A rent repayment order requiring you to repay up to 12 months' rent to tenants or the local authority
- A banning order preventing you from letting property
- An entry on the Rogue Landlord database
2. Additional HMO Licensing
London boroughs have the power to extend licensing requirements beyond the national mandatory threshold using Additional Licensing schemes. These typically cover smaller HMOs — properties with three or four occupants — that do not fall within the mandatory category.
Additional licensing schemes must be approved by the Secretary of State (or, in London, the Mayor of London) and are time-limited, typically running for five years before renewal.
A large majority of London boroughs now operate additional licensing schemes covering most or all HMOs in the borough. Examples include Camden, Islington, Hackney, Southwark, Lewisham, Haringey, Tower Hamlets, and many others. You should check with your specific borough as to whether an additional licensing scheme is in operation and whether your property falls within its scope.
3. Selective Licensing
Selective licensing is a different scheme that requires ALL privately rented properties in a designated area to be licensed — not just HMOs. It is not limited to multi-occupancy properties. It is used by councils in areas with low housing demand, anti-social behaviour problems, or poor property management standards.
Several London boroughs or parts of boroughs operate selective licensing schemes. If your property is in a selective licensing area, you need a licence even if it is let to a single family.
How to Check If Your Property Needs an HMO Licence
Check the size of the occupation: If five or more people from two or more households — mandatory licensing applies nationwide. If three or four people — check for an additional licensing scheme in your borough.
Check your borough: Every London borough publishes its current licensing schemes on its website. Search for "[borough name] HMO licensing" or "[borough name] private rented sector licensing". The council will list which schemes are active, the boundaries, and how to apply.
Check for selective licensing: Even if your property is not an HMO, check whether the postcode falls within a selective licensing designation.
Councils actively check: London boroughs cross-reference council tax records, tenancy deposit data, planning records, and utility data to identify unlicensed properties. Do not assume that because you have not been contacted, your property does not require a licence.
What Does an HMO Licence Require?
To obtain an HMO licence, the property must meet standards in several areas:
Room sizes
Under regulations introduced in 2018, minimum room sizes apply to HMOs:
- Single adult sleeping room: minimum 6.51 m²
- Double adult sleeping room: minimum 10.22 m²
- Room for a child under 10: minimum 4.64 m²
Rooms below these sizes cannot be used as bedrooms in an HMO. If existing rooms are undersized, you will need to either reconfigure the space or reduce the number of occupants.
Fire safety
HMOs must have adequate fire safety provisions including:
- Mains-wired, interlinked smoke detectors (typically Grade D, LD2 system at minimum)
- Heat detectors in kitchens
- Fire doors with appropriate closers where required
- Emergency lighting in some cases
- Clear means of escape
The exact requirements depend on the size, height, and layout of the property. Your local authority will typically refer to the LACORS Fire Safety Guidance or Approved Document B. An FRA (Fire Risk Assessment) is often required.
Electrical safety
- A current Electrical Installation Condition Report (EICR) — required every five years for HMOs (and now for all private rented properties under the 2020 Electrical Safety Standards regulations)
- Adequate electrical circuits and sockets for the number of occupants
Gas safety
- Annual Gas Safety Certificate from a Gas Safe registered engineer
- All gas appliances serviced and in safe working order
Facilities standards
HMO licensing standards typically specify minimum provision based on the number of occupants:
- Kitchen facilities: worktop space, sinks, cooker connections, storage
- Bathroom and WC provision: one bathroom/WC per 4–5 occupants is commonly specified, but standards vary by borough
- Heating: adequate fixed heating in all habitable rooms
Management standards
The HMO licence also requires compliance with the Management of Houses in Multiple Occupation (England) Regulations 2006, which impose duties on landlords and managers around maintenance, safety, cleanliness, and the handling of complaints.
Applying for an HMO Licence
Applications are made to your local authority, typically online. You will need to provide:
- Property address and floor plans
- Details of all occupants and tenancies
- A current gas safety certificate
- A current EICR
- Details of smoke detection and fire safety provision
- Details of the landlord or managing agent
- Payment of the application fee
Licence fees vary substantially between boroughs. As a guide, London boroughs typically charge between £500 and £1,500 per HMO for a five-year licence (mandatory HMO), with some charging more for larger properties or per-room fees. Check your specific borough.
The council will inspect the property as part of the licensing process, either before granting the licence or shortly after.
How HMO Licensing Affects Property Work
For landlords carrying out work on HMO properties — conversion, extension, refurbishment — HMO licensing requirements directly affect the design and specification:
Room sizes: If you are converting a house to HMO use, room layouts must achieve the minimum sizes. Rooms that are marginally too small may require wall repositioning to comply.
Fire safety: HMO fire safety standards often require fire doors throughout. This affects joinery specification, door hardware, and can affect the feel of the property.
Kitchen and bathroom provision: You may need to add bathrooms or enlarge kitchens to meet the ratio requirements for the number of occupants intended.
Electrical installation: An existing installation may need upgrading to provide adequate circuits for the occupant load.
At rcbGroup, we have extensive experience in HMO conversion and refurbishment work across London. We understand the licensing standards and can design and build to meet them — helping landlords avoid the cost of rework after a failed inspection.
Common Mistakes London Landlords Make
Not knowing whether a licence is required: The mandatory threshold changed in 2018, when the storey restriction was removed. Landlords who previously fell below the three-storey threshold may now require a licence and not know it.
Assuming small HMOs are exempt: Additional licensing schemes in London commonly extend to properties with three or four occupants. Check your borough.
Not maintaining the licence: Licences are not permanent. They must be renewed when they expire (typically every five years). Continuing to let without a valid licence is an offence even if you previously held one.
Not updating the licence: If the property changes in a material way — number of permitted occupants, new managing agent, substantial works — you may need to notify the council or apply for a variation.
Ignoring room sizes: Rooms below the minimum size cannot be counted as bedrooms. Putting a bed in a 5m² room in a licensed HMO is a breach of licence conditions.
Summary
HMO licensing in London is a detailed and evolving area of regulation. Mandatory licensing applies to all five-person-plus HMOs across England. Additional licensing schemes extend requirements to smaller HMOs across most London boroughs. Selective licensing can catch all private lets in designated areas regardless of size. The consequences of non-compliance are severe — unlimited fines, rent repayment orders, and banning orders. For landlords carrying out HMO conversions or refurbishments, understanding the licensing standards before the work starts is essential to avoid costly changes post-completion.
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Important Note
This guide is for general information only. Building regulations, planning rules, and legal requirements change regularly and vary by local authority. Always seek professional advice specific to your project and location. To talk through your own project, book a project review.
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