01 · ScopeWhat a council HMO inspection actually covers
A council HMO inspection is three statutory checks rolled into a single visit. The licensing officer is looking at licence conditions (Housing Act 2004 Part 2 for HMO licensing, Part 3 for Selective), the HMO management duties (the Management of Houses in Multiple Occupation (England) Regulations 2006), and the hazard rating of the property under the Housing Health and Safety Rating System (HHSRS) under Housing Act 2004 Part 1. A breach of any of the three can result in enforcement, even if the other two are clean.
Structurally, the visit has two halves. The first is a documentary audit: the officer asks for the HMO licence paperwork, fire risk assessment, certificates for gas, electrical and fire-alarm systems, tenancy agreements, deposit-protection records, and any other evidence the licence conditions require. Many officers ask for the pack by email in advance and arrive with it already marked up. The second is a physical walkthrough: room-by-room measurement, sight-check of fire doors and alarms, electrical sockets and panels, kitchen and bathroom adequacy, general condition. A 5-bed HMO runs 90 minutes to two hours on site; a 10+ bed runs three.
After the visit, the officer writes up the report (typically 5-15 working days) and issues one of three outcomes: grant with standard conditions (pass), grant with a schedule of works and re-inspection date (conditional pass, landlord must complete specified works), or refuse with reasons (fail, appealable to the First-tier Tribunal within 28 days). First-time passes are the cheapest outcome by a wide margin.
Licensing and HHSRS are not the same test
The licensing inspection asks "does this property meet the conditions of the HMO licence?". The HHSRS assessment asks "does this property contain any hazard that would materially endanger the health or safety of a reasonable occupant?". A Category 1 hazard under HHSRS obliges the council to act regardless of licensing status. A passed licensing inspection does not protect against HHSRS enforcement, and vice versa. Run both lenses in your pre-inspection walkthrough.
02 · PaperworkThe paperwork file, 11 documents that carry half the outcome
Officers open the visit by asking for the documents. A clean file presented on arrival, indexed and cross-referenced, materially shifts the officer's default disposition from "find the gaps" to "confirm the standard". The table below is the indexed pack HSE puts together before every first-visit HMO inspection.
| Document | Validity | What the officer checks |
|---|---|---|
| HMO licence or application reference | Application receipt or granted licence | Correct property, correct licence holder, accurate occupancy cap. |
| Fire risk assessment | Written to PAS 79-1 or BS 8674:2025 methodology; reviewed within 12 months | Competent assessor, significant findings recorded, action plan with dates. |
| Gas safety certificate (CP12) | Current (<12 months, renewed annually) | Every gas appliance recorded, each room listed, Gas Safe engineer registration number. |
| Electrical Installation Condition Report (EICR) | Valid (within 5 years; many HMO schemes require 1-year cadence for licensing) | Satisfactory rating, C1/C2 observations resolved, competent electrician signed. |
| PAT test records | Landlord-provided appliances; annual is the conservative default | Pass record per appliance, test-date stickers visible on items. |
| BS 5839-6 fire-alarm certificates (design / install / commission / verify) | Original certificates held for the life of the system | Grade and category match the FRA spec, four-certificate sequence complete. |
| Emergency-lighting test records (where applicable) | Monthly flick-test + annual full-duration test per BS 5266 | Log book present; most-recent test dated within 12 months. |
| Tenancy agreements | One per occupant or joint agreement; current term | Match declared occupancy, no over-occupation beyond licence cap. |
| Deposit protection certificates | Within 30 days of receipt of deposit | Scheme confirmation (TDS, DPS or mydeposits), prescribed information served. |
| Right-to-Rent checks | Pre-tenancy; re-check if time-limited leave expires | Documentary evidence retained (Home Office guidance, 2023 penalty regime). |
| Building insurance certificate + proof of ownership | Current | Property address matches; licensee named as insured. |
Present this file on arrival, indexed, with tabs or digital bookmarks. For a landlord running the file from a mobile or tablet on the day, a single PDF with a linked table of contents works well. The documentary audit that would otherwise take 30-45 minutes collapses to 10 minutes when the pack is tidy, and the officer starts the physical walkthrough already predisposed to pass.
03 · PhysicalThe room-by-room physical walkthrough
Once the documents are cleared, the officer walks the building. The sequence is broadly the same across London boroughs. Below is the order of spaces and what is being measured or verified in each.
- Front door and approach. Locks and final-exit release (thumb-turn, no removable key). External lighting. Approach condition (steps, trip hazards). HMO licence notice displayed if the licence conditions require it.
- Entrance hallway and staircase. Fire-alarm sensors (optical, typically ceiling-centre). Escape-route width. Storage obstructions (bikes, boxes). Handrails on every stairway. Flooring condition. Any riser-cupboard doors on the escape route should be FD30s.
- Kitchen. Heat detector (not smoke). Room size against occupancy: LACORS guidance and London-specific borough conditions vary, but a 6-bed HMO typically needs 10+ m² of communal kitchen/dining. Adequate cooking rings, fridge-freezer capacity per occupant, sinks, worktop and storage. Ventilation (window or extractor). Rubbish disposal.
- Living room / lounge. Optical smoke alarm. Furniture fire-labels (compliant with Furniture and Furnishings (Fire Safety) Regulations 1988 as amended). Soft-furnishing condition. Electric sockets (enough for the occupancy, RCD-protected per EICR).
- Bathroom / WC. Ratio check: most licences require one bathroom per five occupants or a second WC. Extractor fan or opening window. Tiling and seal condition. No damp or mould. Shower-head pressure.
- Each bedroom. Measured floor area, the single most common fail. Mandatory minima under the HMOs (Prescribed Descriptions) Order 2018: 6.51 m² for one person over 10 years old, 4.64 m² for one person under 10, 10.22 m² for two persons over 10. London boroughs often condition higher minima on individual licences. Optical smoke alarm in each room (if LD2/LD1). Each bedroom door should be FD30s with a self-closer unless the FRA specifically documents a different spec.
- Electrical consumer unit. RCD protection confirmed, cover in place, labelling legible, EICR recent. Often inspected with a torch, often the thing that triggers follow-up questions.
- Gas boiler cupboard. CO alarm present (Smoke and CO Alarm (Amendment) Regulations 2022). Gas safety certificate matches the boiler installed. Ventilation per manufacturer instructions. Isolation valve accessible.
- Refuse and cycle storage. Designated bin area with adequate capacity, covered, accessible. Cycle storage if the licence conditions require. Refuse collection schedule clear to tenants.
- Garden and external areas. Boundary fencing, trip hazards, any structures (sheds) checked for asbestos concerns if pre-2000. Condition of any outdoor electrical fittings.
Officers often photograph findings as they walk, either good (confirming a spec) or bad (evidence for the notice). A landlord on site should be prepared to point out anything that has recently been replaced or repaired, if a fire door was refurbished two weeks ago and the certificate is in the paperwork pack, say so while the officer is in front of it. Silent-standing gets read as "nothing to declare"; tactical disclosure gets read as "landlord is across their file".
Officers grade on signal, not just substance. Two HMOs with identical fixes can score differently, the one where the landlord met them with an indexed file, knew the layout by heart, and answered every question with a document reference, scored higher. The same fabric, differently presented, changes the outcome.
04 · HHSRSThe HHSRS hazard lens running in parallel
While the licensing officer is checking licence conditions, they are also applying the Housing Health and Safety Rating System. HHSRS sits under Housing Act 2004 Part 1 and assesses the property against 29 recognised hazards, each rated for likelihood of a harmful occurrence and for severity of the outcome. Hazards are categorised Category 1 (serious, the council is compelled to act) or Category 2 (less serious, the council may act).
The hazards that show up most often on London HMO inspections:
- Damp and mould growth, disproportionately high in older conversions. See our Awaab's Law SOP for the standard response.
- Excess cold, inadequate heating or insulation, typically in single-glazed Victorian stock.
- Falls on stairs, handrail, tread condition, lighting.
- Electrical hazards, EICR C1/C2 observations, exposed cabling, inadequate RCD protection.
- Fire, inadequate escape route, fire-door failings, missing detection coverage.
- Food safety, kitchen hygiene and storage conditions in shared HMOs.
- Carbon monoxide, missing CO alarms where a gas or solid-fuel appliance is present.
HHSRS enforcement routes (improvement notice, prohibition order, emergency remedial action, demolition order, hazard-awareness notice) are triggered independently of licensing. A landlord who passes the licensing test but ignores HHSRS can still face an improvement notice the following month. Passing both lenses in one visit is the goal; failing one but passing the other is not "mostly fine".
05 · FailsTop ten reasons HMOs fail first time
Across HSE's London HMO inspection data, the ranked list below accounts for the vast majority of first-visit fails. Most of them are fixable in the 10 working days before the inspection, which is why the pre-inspection walkthrough matters so much.
- Fire-door installation or maintenance failings. Ironmongery, gap tolerance, missing or damaged intumescent or cold-smoke seals. Every point the fire-doors FD30/FD60 article covers.
- Missing or inadequate fire-alarm coverage. Coverage not matching the FRA-specified LD category, out-of-date commissioning certificates, CO alarm missing where a gas boiler is present. See the BS 5839 guide.
- Undersized bedrooms. Below the Prescribed Descriptions Order 2018 minima, or below a stricter London borough licence condition. A room let to two people that measures 9.5 m² is a licence-condition breach even if it looks fine.
- Inadequate kitchen facilities for the occupancy. Too few cooking rings, fridge-freezer capacity, worktop or storage for the number of occupants.
- Inadequate bathroom or WC ratio. London borough conditions typically require one bathroom per five occupants; some require a second WC in 6+ person HMOs.
- Missing or out-of-date compliance certificates. Gas CP12 expired, EICR stale beyond the licensing scheme's required cadence, no PAT test record, no fire-alarm commissioning certificate on file.
- Damp and mould. Category 1 HHSRS hazard compelling council action. See Awaab's Law SOP.
- Electrical hazards. Exposed cabling, inadequate RCD protection, consumer unit condition.
- Blocked or compromised escape routes. Tenant storage, uncleared waste, obstructions on stairwells, locked final exits requiring keys.
- Inadequate refuse storage or cycle parking. Overflowing bin area, no designated cycle storage where borough conditions require.
06 · 10-day walkthroughThe 10-day pre-inspection walkthrough
6-bed Camberwell SE5 shared-house HMO, Additional Licensing renewal
A landlord has an Additional Licensing renewal inspection scheduled in 10 working days. The HMO is a 6-bed Victorian terrace in Camberwell SE5. Five years have passed since the last licence cycle. Here is the walkthrough HSE runs to close every likely finding before the officer arrives.
- Day -10 (Monday) · Paperwork audit. Pull every document from the 11-item list. Check validity dates. Re-order any expired or near-expired certificates: gas CP12 if within 60 days of expiry, EICR if stale, PAT tests if undocumented. Book a fresh FRA if the current one is older than 12 months or if any material change has occurred.
- Day -9 (Tuesday) · Fire-door audit. FDIS-certificated inspector walks every fire door with a gap gauge and a seal check. Photographs every finding. Flags pass / remedial / replace per door. Remedial schedule priced for completion by Day -2.
- Day -8 (Wednesday) · Fire-alarm and CO test. Full test of the alarm system. Replace any sounder or detector that fails. CO alarms in every room with a gas appliance. Emergency-lighting test where applicable. Record the tests in the log book.
- Day -7 (Thursday) · Bedroom measurements. Measure every bedroom to confirm it meets Prescribed Descriptions Order 2018 minima AND the specific borough's licence-condition minima. Flag any over-occupancy risk; if a 9.5 m² room is currently let to two people, the fix is an immediate occupancy-change conversation with the tenant.
- Day -6 (Friday) · Kitchen and bathroom review. Check adequacy ratios: cooking rings, fridge/freezer capacity, worktop length, sinks, bathroom count per occupant. Deep-clean the communal areas.
- Day -5 (Monday) · Electrical and gas sweep. Competent electrician walks every socket, switch and consumer-unit breaker. Sort any exposed cabling, cover plate or labelling gap. Gas engineer confirms boiler servicing record matches the CP12.
- Day -4 (Tuesday) · HHSRS hazard sweep. Damp-and-mould inspection, excess cold rating, stairway handrail check, food-safety hygiene, any other HHSRS hazard that could catch the officer. Fix what can be fixed in 48 hours; schedule the rest with a written action plan.
- Day -3 (Wednesday) · Remedial works executed. Fire-door remedials, fire-alarm component swaps, any electrical small works. All photographed before/after.
- Day -2 (Thursday) · Final walkthrough. Internal walkthrough by the landlord or agent running the inspection pattern the officer will run. Deep-clean pass on common areas. Tenant engagement: confirm inspection date, ask that rooms are reasonably tidy, emphasise that it is a scheduled visit.
- Day -1 (Friday) · Pack ready and file shared. Final paperwork file emailed to the licensing officer the afternoon before the inspection. Master copy printed and bound on site for the physical walkthrough. Landlord available on site to answer questions.
- Inspection day. Officer arrives. Paperwork audit collapses to 10 minutes. Physical walkthrough runs 90 minutes without finding. Officer confirms intent to recommend grant with standard conditions. Licence issued within 10 working days.
10 working days
The minimum realistic pre-inspection window to run the HSE walkthrough and close the likely findings. A same-week scramble typically leaves the paperwork tidy but the physical findings unfixed. 10 days lets the remedial works sit, be photographed, and be reflected in the updated FRA file.
07 · FAQsQuestions landlords keep asking
What does a council HMO inspection actually cover?
A council HMO licensing inspection is a combined document audit and physical walkthrough. The officer verifies the paperwork file (FRA, gas, EICR, PAT, fire-alarm commissioning certificates, tenancy agreements, deposit protection, Right-to-Rent) and walks the property room-by-room checking fire doors, alarm coverage, kitchen and bathroom adequacy, bedroom sizes, electrical condition, escape routes, refuse storage, and general condition against the HHSRS hazard framework.
How long does a typical HMO inspection take?
Budget 90 minutes to three hours on site, depending on property size. A 5-bed HMO typically runs 90 minutes to 2 hours; a 10+ bed HMO or a more complex conversion can run 3 hours. The officer writes up the report over the following 5-15 working days and issues the decision: grant with conditions, grant with a schedule of works, or refuse with right of appeal.
What are the most common reasons an HMO fails inspection?
Fire-safety findings dominate. The top ten: fire-door installation or maintenance failings, missing or inadequate fire-alarm coverage, undersized bedrooms below licence minima, inadequate kitchen facilities for the occupancy, inadequate bathroom or toilet ratio, missing or out-of-date compliance certificates, damp and mould (HHSRS Category 1 or 2), electrical hazards, blocked or compromised escape routes, and inadequate refuse or cycle storage. Any one of these can push the case to a schedule of works with re-inspection.
What paperwork should I have ready for an HMO inspection?
An indexed 11-document file: HMO licence or application, fire risk assessment (PAS 79-1 or BS 8674:2025), gas safety CP12, EICR, PAT test records, BS 5839-6 four-certificate fire-alarm pack, emergency-lighting test records, tenancy agreements, deposit protection certificates, Right-to-Rent checks, and building insurance / proof of ownership. Present on arrival as a single indexed PDF or bound folder.
What is the difference between an HMO inspection and an HHSRS inspection?
An HMO inspection under Housing Act 2004 Part 2 or 3 is a licensing inspection, focused on licence conditions and HMO management standards. An HHSRS inspection under Housing Act 2004 Part 1 is a hazard-based inspection, focused on Category 1 and serious Category 2 hazards. The same officer often carries out both lenses on a single visit, but the statutory basis and enforcement routes differ. HHSRS can lead to improvement notices, prohibition orders, and mandatory remedial action even where no licence is in play.
Can I appeal an HMO inspection decision?
Yes, a refusal or unreasonable conditions can be appealed to the First-tier Tribunal (Property Chamber) under Schedule 5 Housing Act 2004 within 28 days of the decision. The Tribunal can confirm, vary or reverse the council's decision. HHSRS improvement notices and prohibition orders also carry appeal rights to the Tribunal. For enforcement notices, time limits are shorter and specialist housing-solicitor advice is strongly recommended.
10-day walkthrough, paperwork pack, physical remedials, ready for the officer
HSE runs the full 10-day pre-inspection walkthrough, assembles the indexed paperwork file, delivers the remedial works, and sits on site on inspection day. First-visit pass is the target; the pattern works.
08 · Where to go nextTwo practical follow-ups
If the next inspection is on the calendar and the HMO pillar is the part of the portfolio you are closest to, these are the two reads that close the loop.
First, the HMO Licensing London Borough-by-Borough Guide, the 22-minute mega-article with the A-Z of all 33 boroughs, their current licensing regime, and the specific licence-condition variations by council. Use it to pre-check the exact licence minima for the inspecting borough.
Second, subscribe to The HSE compliance briefing. One email a month covering regulatory and licensing updates. When a borough publishes a new licensing scheme condition set, you will hear it from Kevin within the week.
HSE service for this topic
Pre-inspection HMO audit · fixed scope
10-day walkthrough, indexed paperwork pack, physical remedials, on-site attendance. The first-visit-pass pattern, delivered by one team.