Additional HMO Licence: Which London Boroughs Require One?

The question of which London boroughs require an additional HMO licence is one we are asked almost daily. The answer changes regularly as councils introduce, extend, and sometimes discontinue their schemes, and it depends as much on your property's exact address as it does on which borough it sits in. Here is an updated overview, including the details landlords most often get wrong.

What is an additional HMO licence?

Under Part 2 of the Housing Act 2004, local authorities can introduce additional licensing schemes for HMOs that fall below the mandatory threshold. These cover smaller properties — typically those let to three or more tenants forming two or more households and sharing amenities such as a kitchen or bathroom — in areas the council has specifically designated. A designation is a formal decision by the council, published and time-limited, rather than an automatic borough-wide rule.

The trigger for a council introducing a scheme is usually evidence of a problem specific to that area — poor property conditions, high concentrations of shared housing, or antisocial behaviour linked to badly managed HMOs. Because the justification is local, the geography of a scheme is local too, which is the single biggest source of confusion for landlords who assume a borough either does or doesn't require licensing across the board.

How this differs from mandatory and selective licensing

Additional licensing is one of three separate licensing regimes under the Housing Act 2004, and landlords frequently conflate them. Mandatory licensing applies nationally to any HMO let to five or more people from two or more households sharing amenities, regardless of which council area the property sits in — no local designation is needed. Additional licensing, by contrast, only applies where a council has designated an area and only to smaller HMOs that fall below that five-person mandatory threshold. Selective licensing is different again: it can apply to any privately rented property in a designated area, HMO or not, including an ordinary single-tenancy let.

A single property can, in principle, be caught by more than one regime if its borough runs overlapping schemes, or by none of them if it sits just outside a designated boundary. This is why we always check a property against all three regimes rather than assuming the answer based on tenant numbers alone.

Which London boroughs require additional licences

As of 2025, a significant number of London boroughs operate additional HMO licensing schemes. These include: Barking and Dagenham, Barnet, Brent, Camden, Croydon, Ealing, Enfield, Hackney, Hammersmith and Fulham, Haringey, Harrow, Havering, Hounslow, Islington, Kensington and Chelsea, Lambeth, Lewisham, Merton, Newham, Redbridge, Southwark, Tower Hamlets, Waltham Forest, Wandsworth, and Westminster.

That is a majority of London's 33 boroughs, which reflects how widely additional licensing has been adopted across the capital over the past decade. It does not mean every smaller HMO in every one of these boroughs needs a licence — only those within the specific designated boundary the council has drawn.

Why the borough name alone doesn't answer the question

Even within boroughs that operate additional licensing schemes, the scheme boundaries are not always borough-wide. Many boroughs designate specific postcode areas, wards, or even individual streets rather than their entire administrative area. Your property's exact address — not just the borough it falls in — determines whether it sits within a scheme boundary.

We regularly see landlords assume they're exempt because they've heard their borough "doesn't do" additional licensing, when in fact the scheme covers only a pocket of the borough that happens to include their street. The reverse also happens: landlords assume they need a licence because the borough is on the list, when their specific address falls just outside the designated area. The only reliable way to know is to check the address against the current scheme map, not the borough name against a general list.

Schemes expire, renew, and change shape

Additional licensing designations are time-limited, typically for around five years, and must be formally renewed or replaced by the council if it wants to continue. A borough that had an additional licensing scheme last year may have let it lapse; another may have introduced a brand new scheme with different boundaries and different conditions. Some councils use the renewal process to expand the designated area or tighten the conditions attached to licences; others narrow it.

This means a property that didn't need a licence eighteen months ago might need one today, and a property that was previously covered might have fallen outside a redrawn boundary. Because of this, checking status once and assuming it holds indefinitely is a genuine compliance risk — always verify current status for your specific address rather than relying on what applied at your last check.

Overlap with selective licensing

Several of the boroughs on the list above also run selective licensing schemes covering ordinary rented properties that aren't HMOs at all. Because selective licensing under Part 3 of the Housing Act 2004 can apply to any privately rented property in a designated area — a single-tenancy flat included — it's entirely possible for a small HMO to sit inside both an additional licensing designation and a selective licensing designation at the same time, depending on how the council has drawn each boundary.

Where both apply, the licences are usually separate applications with separate fees, even though they cover the same physical property. Landlords who only check for additional licensing because their property is an HMO sometimes miss the selective licensing requirement layered on top, particularly since selective schemes don't require a property to have multiple households at all — a landlord letting a single flat on the same designated street could need a licence for that reason alone.

What happens if you need one and don't have it

Operating a licensable HMO without an additional licence carries the same consequences as any other unlicensed HMO offence. Councils can impose a civil penalty, and tenants or the local authority can apply to the First-tier Tribunal for a Rent Repayment Order covering rent paid during the unlicensed period. These are not theoretical risks — councils actively enforce additional licensing schemes, often through targeted inspection campaigns once a scheme is introduced, precisely because the scheme exists to address a known local problem.

Enforcement typically starts with a complaint from a neighbour or tenant, a referral from another council department such as environmental health or planning, or a proactive inspection sweep once a new scheme is introduced. Once a council identifies a property operating without a required licence, it does not need to wait for the landlord to apply — it can proceed directly to considering a civil penalty, and a tenant can independently apply for a Rent Repayment Order regardless of what the council decides to do.

How to check your property

Contact us with your property address. We will check the current status for your borough — including any selective licensing schemes that may also apply — and advise on your exact requirements. This initial consultation is free.

If your property does need an additional licence, our Additional HMO Licence service costs £300+VAT and covers the full application, from documentation through to liaison with the council until the licence is granted. Given how often scheme boundaries shift, it's worth getting a definitive answer rather than working from what you were told last time.