London Boroughs Tighten HMO Licensing Rules Ahead of 2025

Several London boroughs have introduced or widened additional HMO licensing schemes in recent years, part of a wider trend of councils using Housing Act 2004 powers to raise standards in the private rented sector as demand for shared housing keeps climbing. For landlords with a single property or a growing portfolio, keeping track of which streets fall inside a designated scheme has become one of the more tedious but consequential parts of letting a home in multiple occupation.

Why additional licensing keeps expanding

Additional licensing is created locally, under Part 2 of the Housing Act 2004, and is aimed at smaller HMOs — typically three or more occupants forming two or more households — that sit below the mandatory licensing threshold. Councils introduce these schemes where they can show a particular area has a concentration of poorly managed shared housing, antisocial behaviour linked to HMOs, or declining property conditions. Because the legal test is local evidence rather than a national trigger, each London borough designs its own scheme independently, with its own boundaries, fees and conditions.

For a landlord who owns properties in several boroughs, this creates a genuinely uneven picture. A five-bedroom house let to two households might need no licence at all in one borough, a licence under an additional scheme in a neighbouring borough, and fall under mandatory licensing in a third purely because of how many people live there. There is no single London-wide answer to whether a given HMO needs a licence — the question can only be answered borough by borough, and often street by street.

What counts as a designated area

A designated area can be as small as a few streets or as large as an entire borough, and the boundary lines are drawn precisely — a property on one side of a road can fall inside a scheme while a near-identical property opposite does not. Schemes are also time-limited, usually running for five years before a council must review the evidence and either renew, amend or let the designation lapse. This matters because a property that was outside a scheme when you bought it can end up inside a renewed or newly drawn scheme a few years later, without any change to the property itself.

Before a scheme is renewed or expanded, councils typically run a consultation and publish the evidence behind the proposed boundaries, but landlords who do not follow local authority housing bulletins closely can easily miss this process entirely. By the time a scheme change is picked up through a routine search, it may already be in force, and a property let without a licence during that period remains exposed to enforcement regardless of when the landlord found out.

Additional licensing is not the same as mandatory licensing

It is easy to assume that if a property does not meet the mandatory licensing threshold — five or more occupants from two or more households — it needs no licence at all. That assumption is exactly what catches landlords out in a borough running an additional scheme. Mandatory licensing applies nationally and automatically once the occupancy threshold is met; additional licensing only applies where a council has actively designated the area, but where it has, a much smaller HMO can still need a licence.

Consider a house with three postgraduate students sharing — that is three households under most interpretations, well below the five-person mandatory threshold, and would need no licence at all in a borough without an additional scheme. Move the same house into a borough running an additional scheme covering that postcode, and a licence becomes compulsory despite nothing about the property or the tenants changing.

Higher fees and closer scrutiny

Several councils have raised licence application fees as schemes have been renewed, reflecting the cost of processing applications and running the compliance checks that go with them. Alongside higher fees, more boroughs have shifted resources toward proactive inspection of licensed HMOs rather than relying solely on complaints, which means a licence granted several years ago is more likely to be checked against current conditions than it once was.

Some boroughs have also introduced discounted fees for landlords accredited under a recognised landlord accreditation scheme, or for early renewal applications submitted before an existing licence expires, so the headline fee increase is not always the full picture. It pays to check what discounts a specific council offers rather than assuming the standard fee applies.

Room sizes and fire safety are being enforced more rigorously

The minimum room sizes set out in the mandatory conditions regulations — 6.51 square metres for one adult, 10.22 square metres for two adults, and 4.64 square metres for a child under ten, with anything below 4.64 square metres barred from use as sleeping accommodation entirely — apply to licensed HMOs generally, and councils are increasingly checking these figures against floor plans rather than taking an application at face value. The same is true of fire detection equipment, which inspectors now routinely test in person rather than accepting a certificate alone.

This has practical consequences for landlords converting larger rooms into two smaller lettings to increase rental income. A room that falls even marginally under 6.51 square metres cannot be let to a single adult over ten, and anything below 4.64 square metres cannot be used as sleeping accommodation at all, regardless of how the room is marketed. Councils checking floor plans against these figures during licence renewal have started catching room divisions made without regard to the mandatory minimums.

What this means if you already hold a licence

An existing licence does not freeze a property's obligations in time. The Management of Houses in Multiple Occupation (England) Regulations 2006 impose ongoing duties — keeping the structure in repair, maintaining water and drainage, keeping fire detection equipment in working order, arranging gas and electrical safety checks, providing for waste disposal, and making sure occupiers know who the property manager is — regardless of what the licence certificate says or when it was issued. A licensed landlord who lets these slip can still face enforcement even though the licence itself remains technically valid.

In practice this means a licensed HMO can still receive a visit from an environmental health officer investigating a specific complaint, entirely independent of when the licence is due for renewal. A landlord found in breach of the management regulations can face enforcement even while the licence certificate remains valid on paper.

What landlords should actually do

The only reliable way to know a property's current position is to check the specific address against the current version of the relevant borough's scheme, rather than relying on what applied when the property was bought or a tenancy started. This is worth doing before completing a purchase, before advertising a room to a new household, and periodically for any property already let as an HMO, since scheme boundaries and fees change without much fanfare.

We track licensing schemes across all 33 London boroughs and can tell you within a day whether your property needs an additional or mandatory HMO licence. Our fixed fees are £300+VAT for an additional licence application and £500+VAT for a mandatory licence application — contact us for a free eligibility check on your specific address.