London apartment interior set up for short-term letting

We're asked a version of this question regularly, and the honest answer is that HMO licensing and short-let rules are two separate regimes that landlords often conflate. Understanding the difference matters, because getting it wrong can mean falling foul of one set of rules while thinking you've covered the other.

HMO licensing is about who lives there, not how long

HMO licensing is triggered by the number of unrelated households sharing a property on a long-term residential basis — broadly, three or more people from two or more households sharing amenities, with mandatory licensing kicking in at five or more people from two or more households. A short Airbnb-style booking to a single group (a family, or a group of friends travelling together counted as one household for the stay) does not, on its own, create an HMO, because it isn't multiple separate households under one roof.

The 90-day rule is the actual short-let control

The regulation that specifically governs short-lets in London is the 90-day rule under the Deregulation Act 2015: a residential property in Greater London cannot be let out on a short-term basis for more than 90 nights in a calendar year without planning permission for a change of use. This is entirely separate from HMO licensing and is enforced through planning law, not housing licensing law.

Where the two can overlap

The situations that genuinely need care are mixed-use ones: a property operating as a licensed HMO with individual rooms let to separate long-term sharers, where one or more rooms are also advertised short-term to different guests. That can create HMO licensing questions (are the short-term occupants a separate "household" changing the licensing calculation?) and short-let planning questions (is this now effectively short-term letting activity subject to the 90-day cap?) simultaneously.

Get clarity before you list

If you're planning to let a property on Airbnb or a similar platform in London, or you're already doing so alongside a longer-term HMO arrangement, it's worth getting clarity on both regimes before, not after, a council inspection raises the question. Contact us and we'll help you understand exactly where your property sits.

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