01 · DefinitionWhat counts as an HMO in London
Three or more unrelated persons. Two or more households. Shared kitchen, bathroom or toilet. That is the test. Everything else, tenancy paperwork, rent structure, room layout, is secondary.
The legal definition of a House in Multiple Occupation sits in section 254 of the Housing Act 2004. A property is an HMO if it is occupied by three or more persons who form two or more households, and they share one or more basic amenities (kitchen, bathroom or toilet). A "household" in this context means a single person, a cohabiting couple, or members of the same family.
Crucially, the s.254 test is about occupation, not contracts. Whether the residents sign one joint Assured Shorthold Tenancy or individual room-only contracts is irrelevant to HMO status. What matters is who actually lives there and how they share the facilities. A 3-person houseshare with one AST is as much an HMO as a 3-bedsit house with three separate contracts.
Is your property an HMO?
HMO vs "large HMO"
The s.254 test catches any property meeting the three-part definition. A "large HMO" under Mandatory licensing is a sub-set: any HMO occupied by 5+ persons. Every large HMO is an HMO, but not every HMO is a large HMO. The Additional licensing regime was created to capture smaller HMOs (3-4 persons) that fall outside the Mandatory threshold.
02 · Three regimesMandatory, Additional, Selective, the three licensing regimes
Most landlord confusion about HMO licensing in London traces back to the same root: there are three separate licensing regimes, any London borough can run all three at once, and they do different things. Here is how to tell them apart.
| Mandatory HMO | Additional HMO | Selective | |
|---|---|---|---|
| Statute | Housing Act 2004 Part 2 (national) | Housing Act 2004 Part 2 (borough-designated) | Housing Act 2004 Part 3 (borough-designated) |
| Catches | HMOs with 5+ persons, 2+ households, sharing amenity | HMOs with fewer persons (typically 3-4) where borough has designated | Every private rented property in the designated area, HMO or not |
| Where it applies | All London boroughs, nationwide | Only in boroughs running a designated scheme | Only in areas designated by the borough (often specific wards) |
| Licence duration | Typically 5 years | Typically 5 years | Typically 5 years |
| Civil penalty cap | £30,000 per offence + RRO + criminal | £30,000 per offence + RRO + criminal | £30,000 per offence + RRO + criminal |
| Can overlap? | Yes | Yes, with Selective in some boroughs | Yes, applies regardless of HMO status |
The three regimes can stack. A 5-person HMO in Newham's designated selective area needs a Mandatory HMO licence (for being a 5-person HMO) and a Selective licence (for being a private rented property in a selective area). Two fees, two sets of conditions, two audit trails. This is not a drafting error, it is how the Housing Act 2004 chose to split HMO-specific versus general-PRS regulation.
When you need which licence
- 5-person HMO anywhere in England: Mandatory licence required.
- 3-4 person HMO in a borough with Additional licensing: Additional licence required.
- Any private rented property in a borough's Selective area (even a single let): Selective licence required.
- 5-person HMO in a Selective area: Both Mandatory AND Selective licences required, and potentially Additional if the borough runs one that captures the property.
- Single let in a non-selective area: No HMO or selective licence. Standard PRS compliance still applies.
03 · Article 4Article 4 directions, the planning overlay
Article 4 is not a licensing regime. It is a planning mechanism that sits alongside licensing, and landlords often confuse them. Here is the clean distinction.
Under the Town and Country Planning (General Permitted Development) (England) Order 2015, there is a "permitted development" right to convert a single dwelling (Use Class C3) into a small HMO (Use Class C4), that is, a house in multiple occupation of between 3 and 6 persons. Permitted development means no planning application is required.
An Article 4 direction withdraws that permitted development right. In boroughs with an Article 4 direction covering their area, converting a C3 dwelling to a C4 small HMO requires a full planning application, on top of any licensing regime that applies.
As of April 2026, Article 4 directions covering HMO conversion are in force within these London boroughs (either borough-wide or across significant designated areas):
- Tower Hamlets, borough-wide
- Newham, borough-wide
- Southwark, borough-wide
- Hackney, borough-wide
- Waltham Forest, borough-wide
- Barking & Dagenham, borough-wide
- Camden, designated wards
- Ealing, Redbridge, Haringey, Islington, designated wards
Article 4 directions change. The above list is accurate at publication but should be verified against the borough's current Local Development Framework before any purchase or conversion decision. Some boroughs have consulted on extending their Article 4 to cover larger HMOs (C3-to-sui-generis conversion for 7+ person HMOs), which would further tighten the planning layer.
Article 4 is separate from licensing
Article 4 is about whether you need planning permission to convert a property to an HMO. The licensing regimes (Mandatory / Additional / Selective) are about whether you need a licence to operate the property once it is already an HMO. Both may apply to the same property, both may require fees, and compliance with one does not excuse the other.
If you are buying a 3-bed house in Tower Hamlets to convert to a 4-person HMO, you need three separate approvals: Article 4 planning permission, an Additional HMO licence, and because Tower Hamlets also runs selective licensing in some wards, potentially a Selective licence too. Miss any one and the property cannot lawfully operate.
04 · A–Z referenceEvery London borough, regime summary
The reference table. Every London borough, with the regime types in force as of April 2026. Mandatory HMO applies everywhere so is implied on every row. Where a regime applies only in designated wards, we have flagged "parts", verify the specific address against the borough's Local Development Framework or public-register map before acting.
| Borough | Mandatory HMO | Additional HMO | Selective | Article 4 |
|---|---|---|---|---|
| Barking & Dagenham | Yes | Yes | Yes | Yes · borough-wide |
| Barnet | Yes | Parts | None | None |
| Bexley | Yes | None | None | None |
| Brent | Yes | Parts | Parts | None |
| Bromley | Yes | None | None | None |
| Camden | Yes | Parts | None | Parts |
| City of London | Yes | None | None | None |
| Croydon | Yes | None | Yes | None |
| Ealing | Yes | Yes | None | Parts |
| Enfield | Yes | None | Yes | None |
| Greenwich | Yes | Parts | None | None |
| Hackney | Yes | Yes | None | Yes · borough-wide |
| Hammersmith & Fulham | Yes | None | None | None |
| Haringey | Yes | Yes | Parts | Parts |
| Harrow | Yes | Yes | None | None |
| Havering | Yes | None | None | None |
| Hillingdon | Yes | None | None | None |
| Hounslow | Yes | Yes | None | None |
| Islington | Yes | Yes | None | Parts |
| Kensington & Chelsea | Yes | None | None | None |
| Kingston upon Thames | Yes | None | None | None |
| Lambeth | Yes | Yes | None | None |
| Lewisham | Yes | Parts | None | None |
| Merton | Yes | None | None | None |
| Newham | Yes | Yes | Yes | Yes · borough-wide |
| Redbridge | Yes | None | Parts | Parts |
| Richmond upon Thames | Yes | None | None | None |
| Southwark | Yes | Yes | None | Yes · borough-wide |
| Sutton | Yes | None | None | None |
| Tower Hamlets | Yes | Yes | Parts | Yes · borough-wide |
| Waltham Forest | Yes | None | Yes | Yes · borough-wide |
| Wandsworth | Yes | None | None | None |
| Westminster | Yes | Parts | None | None |
Schemes change. Always verify the specific address against the borough's licensing register and Local Development Framework before committing. The regime-tag summary above is correct as of April 2026; several consultations on scheme extensions are in progress.
05 · Fees & processWhat you pay, and how you apply
Licence fees are set by each borough and are usually split into two parts: an application fee (due on submission, non-refundable) and a licence fee (due on grant, covering the 5-year duration). Some boroughs combine them into one payment at application.
As of April 2026, indicative London ranges are:
- Mandatory HMO (5+ persons): £900–£1,500 for a 5-year licence, with per-room or per-storey multipliers on top of a base fee.
- Additional HMO (3-4 persons in designated boroughs): £1,000–£2,000, inner-London boroughs typically at the higher end.
- Selective licensing: £500–£900 per property for 5 years.
- Planning application under Article 4: £462 for householder application (as of April 2026); higher for more complex schemes.
Several London boroughs raised their licensing fees 15–40% in the 2025/26 cycle. The Renters' Rights Act 2025 includes provisions that may change fee-capping from 2027 onwards. For a current-year budget, always pull the specific borough's fee schedule from their licensing page within 30 days of application.
The application process in six steps
- Pre-audit. Before submission, audit the property against the borough's fire-safety, amenity and HHSRS standards. Most rejections happen here; fix them before applying. See Section 06 below for the six items that fail first-time inspections.
- Fit & Proper Person documents. Compile the landlord's (or manager's) Fit & Proper declaration, DBS disclosure, evidence of previous landlord experience, a declaration of any unspent convictions or housing-related penalties.
- Submit online. Every London borough now accepts applications via their online licensing portal. Upload supporting documents (gas certificate, EICR, FRA, EPC, building plans, tenancy agreements).
- Pay the application fee. Non-refundable, due on submission. Keep the receipt.
- Inspection. A borough licensing officer will visit the property, typically within 6–12 weeks of application. They score against the published inspection sheet; remedial items are flagged as "must-fix before grant" or "conditions on the licence".
- Licence grant or refusal. If the inspection is passed, a 5-year licence is issued on payment of the licence fee. If refused, the applicant has a statutory right of appeal to the First-tier Tribunal within 28 days.
06 · Why licences get rejectedSix items that fail most first-time London HMO inspections
Across the applications HSE Property Checks handles, these six items account for roughly 80% of first-time inspection failures. The pattern is consistent across boroughs; if you close these six before the officer visits, the inspection becomes a formality.
01 · Fire-door specification
#1 rejection causeFlat-entrance doors, room doors and cellar/loft doors in an HMO must be FD30 (30-minute fire resistance) with intumescent strips, cold-smoke seals, compliant self-closing devices, and a 3-mm ± gap tolerance to the frame. Most rejections cite one of: wrong door (non-FD30), missing or damaged strips and seals, self-closer failing to fully close, or gap tolerance exceeded. An FDIS-compliant fire-door inspection report resolves all of this before the licence officer visits. Our sister team at Fire Doors Pro has written the on-site view of the same work, a landlord's complete guide to HMO fire-door checks in practice.
02 · Fire-alarm grade
LACORS specificThe LACORS Housing – Fire Safety guidance recommends grades and categories by HMO type. Typical mismatches: a Grade D1 LD3 system where the LACORS matrix calls for Grade A LD2; missing interlinked detection in escape routes; or a purely battery-powered system where mains-wired is required. Borough licensing teams use LACORS as their scoring template; a mismatch is a near-automatic fail.
03 · Emergency lighting
Escape routesBS 5266-1 emergency lighting is required on escape routes and stairwells in HMOs, with photometric compliance to BS EN 1838 and a 3-hour duration specification. Common failures: absent emergency lighting entirely; presence on the landing but not the internal stairs; or installed but never commissioned / tested. The licensing officer looks for a current test-log entry.
04 · EICR findings open
ElectricalUnder the Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020, any C1, C2 or FI code on the EICR must be remediated within 28 days (or the shorter period specified in the report). Borough officers routinely pull the EICR certificate and check that the remedial certificate has closed every coded finding. An EICR with open C2s at the point of licence inspection is a certain rejection.
05 · Amenity standards
HHSRS / amenityTypical borough amenity standards: one kitchen per 5 persons (or part thereof), one bathroom per 5 persons, minimum bedroom sizes (usually 6.51 m² for a single, 10.22 m² for a double). Fail modes: too many residents per kitchen or bathroom, bedrooms below minimum square-metre threshold, kitchen too far from any living accommodation. Room sizes are hard constraints and frequently impossible to fix without reducing occupancy.
06 · FRA missing or non-LACORS
Fire Risk AssessmentEvery HMO must have a written Fire Risk Assessment under the Regulatory Reform (Fire Safety) Order 2005, and for HMO licensing the FRA must align to LACORS fire-safety guidance. Two patterns fail most often: no FRA at all (the landlord assumed the alarm certificate was enough), or an FRA signed by a non-Tier-3 NFRAR assessor with no LACORS alignment in its methodology. Use a Tier 3 NFRAR assessor and verify the report references LACORS explicitly.
80%
of first-time London HMO licence rejections trace to one of these six items. A pre-licence audit that closes all six before the officer visits typically moves pass-first-time to above 95%.
07 · Worked example6-bed HMO in Southwark SE15, licence application process
Victorian conversion, 6 persons, 3 storeys, Peckham SE15
A private landlord acquires a 3-storey Victorian conversion in SE15 in early December 2025, intending to operate it as a 6-person HMO (3 households across 6 bedrooms). Southwark runs Additional HMO licensing borough-wide and is an Article 4 borough. Here is the timeline from purchase to operating licence.
- Week 1 (Dec). Confirm Article 4 status. The property was already operating as a C4 HMO before purchase, so existing use rights transfer; no fresh planning application is required. If it had been a C3 dwelling, a planning application would be the first step, typically 8–13 weeks for determination.
- Week 2–3. Pre-licence audit commissioned. HSE runs a full 6-item inspection against Southwark's published scoring sheet and the LACORS matrix. Findings: three fire doors non-FD30, missing intumescent strips on two more, Grade D alarm where LACORS calls for Grade A LD2, EICR expired, no emergency lighting on internal stairs.
- Week 4–5. Remedial works carried out in parallel: FD30 door installs, alarm upgrade to Grade A LD2 with interlinked detection, BS 5266 emergency-lighting retrofit on escape routes, fresh EICR with all C2s closed. Tier 3 NFRAR FRA commissioned with LACORS-aligned methodology.
- Week 6. Fit & Proper Person documents compiled: landlord DBS, previous rental history, no unspent convictions. Supporting documents assembled: CP12, EICR, EPC, FRA, plans, tenancy agreements, inventory.
- Week 7. Additional HMO licence application submitted to Southwark licensing team via their online portal. Application fee paid (£1,200 indicative; confirm current schedule). Receipt retained.
- Week 13. Southwark licensing officer visits the property. The six pre-audited items all score clean. One minor finding on internal door handles (non-compliant lever handle) resolved on the day. Licence approved subject to payment of the licence fee.
- Week 14. Licence fee paid; 5-year Additional HMO licence issued. Property operating lawfully from the date of grant. The licensing team will typically conduct a mid-cycle compliance inspection around month 24–30.
Total elapsed time from purchase to operating licence: approximately 14 weeks, of which 6 weeks was pre-application remediation and 6 weeks was application-to-inspection lag. Had the landlord skipped the pre-audit and submitted at Week 2, the inspection at Week 8 would have failed on fire-door and alarm grounds, triggering a resubmission cycle that typically adds 12–16 weeks.
Close the six fail-points before the officer visits
Our pre-licence HMO audit mirrors the borough's inspection scoring sheet line-by-line and delivers a remedial list in 5 working days. Tier 3 NFRAR, LACORS-aligned, fixed price.
08 · FAQsSix questions we get asked most
Is my property an HMO?
A property is an HMO under Housing Act 2004 s.254 if three or more unrelated persons forming two or more households share a kitchen, bathroom or toilet. Whether they sign one joint AST or individual room-only contracts is irrelevant. It is the occupation pattern that defines HMO status, not the tenancy paperwork. A property meeting the s.254 test is an HMO for fire-safety, HHSRS, LACORS and amenity-standard purposes regardless of whether it also requires a Mandatory, Additional or Selective licence.
What are the three HMO licensing regimes in London?
Mandatory HMO licensing (Housing Act 2004 Part 2) applies to every property occupied by 5+ persons in 2+ households sharing amenities; Additional HMO licensing (also Part 2) is a borough-designated extension typically catching 3-4-person HMOs; Selective licensing (Part 3) is a separate regime covering every private rented property in a designated area regardless of HMO status. A London borough can run all three simultaneously.
What is Article 4 direction and which London boroughs have it?
An Article 4 direction removes permitted-development rights, specifically the right to convert a single dwelling (C3) to a small HMO (C4) without planning permission. In Article 4 boroughs, converting any property into a 3-6-person HMO triggers a full planning application on top of the licensing regime. As of April 2026, Article 4 directions cover areas within Tower Hamlets, Newham, Southwark, Hackney, Waltham Forest, Barking & Dagenham, Camden, and parts of Ealing, Redbridge, Haringey and Islington. Always check the current Local Development Framework for your exact address.
How much does a London HMO licence cost?
As of April 2026, London Mandatory HMO licence fees typically run £900-£1,500 for a 5-year licence, Additional HMO £1,000-£2,000, and Selective £500-£900 per property. Fee structures are set by each borough; several London boroughs raised fees 15-40% in the 2025/26 cycle. The Renters' Rights Act 2025 includes provisions that may change fee-capping from 2027. Always check the specific borough's current fee schedule before budgeting.
What makes a London HMO licence application get rejected?
Six items account for roughly 80% of first-time rejections: fire-door specification, fire-alarm grade mismatched to LACORS, missing emergency lighting, open EICR codes, amenity-standard failures, and an FRA that is either missing or not LACORS-aligned. See Section 06 above for the full breakdown. A pre-licence audit that closes all six before the officer visits typically moves pass-first-time rates to above 95%.
Do I need an HMO licence in an Article 4 borough if my property is not an HMO?
Article 4 only affects you when you convert a single dwelling into a C4 small HMO; if your property is a single let, Article 4 is not triggered and no HMO licence is required. But if your borough also runs Selective licensing and your address falls within the Selective designation, the property still needs a Selective licence regardless of HMO status. Article 4 and Selective licensing operate independently.
09 · Where to go nextThree next steps for London HMO landlords
If you are scoping an HMO acquisition or renewing an existing licence, these are the three immediate steps that will save you time, rejection and re-application cycles.
First, run the duty diagnoser on our For Landlords page. It folds Article 4 status, selective licensing, HMO grade and the six rejection items into a single output, with an enforcement-risk score so you can see exposure at a glance.
Second, commission a pre-licence audit before submission. The HSE HMO Compliance service mirrors the borough's inspection scoring sheet line-by-line and delivers a remedial list inside 5 working days, the same service we run on the worked example in Section 07.
Third, subscribe to The HSE compliance briefing. One email a month, pricing updates, regulatory shifts, one actionable thing to do before the next deadline. Unsubscribe in one click.
HSE service for this topic
HMO Compliance · pre-licence audit & application support
Full LACORS audit, line-by-line against your borough's scoring sheet. Remedial list in 5 working days. Application support through to grant. Tier 3 NFRAR throughout.