HMO Additional Licensing London — Borough-by-Borough Status 2026

Three layers of HMO and rental licensing apply in England under the Housing Act 2004. Mandatory licensing is the national scheme — any HMO occupied by five or more persons forming two or more households requires a mandatory HMO licence regardless of which council the property sits in.

Additional licensing is a borough-defined scheme that extends licensing to HMOs below the mandatory threshold. A common additional scheme covers 3-or-4-person HMOs across the whole borough. The council must designate the scheme, consult and publish a designation order. The scheme then runs for five years before requiring renewal.

Selective licensing is also borough-defined but applies to all private rented properties — not just HMOs — within a defined geographic area. Selective is typically used on a street-by-street basis where the council has identified concentrated poor-quality private rented stock. The scheme covers single-family lets as well as small HMOs.

A property can be subject to more than one scheme. A 3-person HMO in a selective licensing street within a borough with active additional licensing requires an additional HMO licence and a selective licence as separate parallel obligations. Each licence has its own fee and conditions.

Newham — the longest-running additional licensing scheme in London, in continuous operation since 2013. The current designation covers all HMOs not within mandatory scope across the whole borough. Renewal cycle is five years. Newham's scheme is the model that many other boroughs reference.

Hackney — additional licensing covers all HMOs of three persons or more across the whole borough. The current scheme runs through 2027 with consultation under way for the next designation period. Hackney pairs additional licensing with selective licensing in defined wards.

Waltham Forest — additional licensing covers all HMOs of three persons or more. Combined with one of London's broader selective licensing schemes — landlords in Waltham Forest often face both licences on the same property.

Brent — additional licensing covers small HMOs across the borough. Brent's scheme has historically had longer decision timelines than other boroughs due to inspection backlogs; applications routinely take 12-16 weeks to determine.

Croydon — additional licensing in defined parts of the borough alongside selective licensing in others. Croydon's scheme has been notably aggressive in enforcement and Rent Repayment Orders are common where unlicensed letting is identified.

Havering — additional licensing introduced March 2026 covering small HMOs across designated wards. New scheme; the council is still calibrating its inspection regime and application volumes are high.

Hillingdon — additional licensing introduced August 2026, the most recent London designation. Hillingdon's scheme launched with a backlog of applications from landlords who anticipated the designation. Decision timelines in the first six months are running long.

The application form and evidence requirements for additional licensing are broadly the same as mandatory licensing — most boroughs use a single combined HMO application portal. The differences sit in the threshold (additional catches smaller HMOs) and the fee structure (often lower for additional than mandatory).

Property suitability assessment under additional licensing applies the same Schedule 4 criteria as mandatory — minimum room sizes, kitchen and bathroom amenity standards, fire safety, electrical safety, gas safety. The smaller HMO size does not relax any of these standards.

Some boroughs operate a fast-track or self-certification route for additional licensing where the landlord has a strong compliance record across multiple properties. Newham's portfolio landlord scheme is the established example.

Fee bands typically £400-£800 for additional licensing versus £700-£1,200 for mandatory. Some boroughs charge per-bedroom rather than per-property and the difference between a 3-bed and 5-bed HMO can be substantial.

Electrical safety — valid EICR (within 5 years and satisfactory) for the full installation. HMO EICRs are often required to be Domestic 1 type-tested rather than visual-only. Some boroughs require Periodic Inspection Reports on a 5-year cycle and an interim visual inspection at every change of tenancy.

Fire safety — a Fire Risk Assessment (FRA) under the Regulatory Reform (Fire Safety) Order 2005 for the communal areas, plus BS 5839-6 Grade D LD2 alarm coverage certified by a competent person. Emergency lighting where the escape route lacks borrowed natural light. The FRA is usually a separate document from the electrical certification.

Gas safety — CP12 Landlord Gas Safety Record within 12 months of application date and renewed annually thereafter. Gas Safe registered engineer signature required.

Energy performance — EPC at band E or higher (MEES current threshold) trending towards band C by October 2030. Some boroughs request a forward MEES plan as part of the licence application.

Management — written management plan covering tenancy management, complaint handling, repair response times and out-of-hours contact. DBS check on the named manager. Where the licence holder is a company, evidence of company registration and director details.

Floor plans — scaled floor plans showing room sizes against Schedule 4 minimum room sizes (4.64m² for single bedrooms, 10.22m² for double, plus dedicated kitchen and bathroom standards). Most boroughs require these prepared by a competent surveyor.

Standard decision timeline for an established additional licensing scheme is 8-12 weeks from complete application to licence issue. The clock starts when the application is complete — incomplete applications are returned for further information without counting against the timeline.

Newer schemes (Havering, Hillingdon in 2026) are running longer at 12-16 weeks due to inspection backlogs. Established schemes (Newham, Hackney) are at the shorter end of the range provided the application is clean and the property is compliant.

Where the application is straightforward — competent evidence pack, no remedial items pending, no enforcement history — some boroughs will issue a provisional licence within 4-6 weeks pending physical inspection. The provisional licence permits letting during the inspection window.

Where remedial works are required, the licence is typically issued with conditions specifying the works and a deadline (often 28 days for safety items, 6 months for amenity items). Failure to complete conditions can revoke the licence.

Letting an HMO that requires a licence without one is a criminal offence under the Housing Act 2004. The Civil Penalty in lieu of prosecution can be up to £30,000 per breach per property. Multiple unlicensed properties produce multiple penalties.

Rent Repayment Order — the tenant or council can apply to the First-tier Tribunal for repayment of up to 12 months' rent paid during the unlicensed period. Newham and Hackney both run active RRO programmes and tenant solicitors will assist on a no-win-no-fee basis.

Banning Order — for repeat or serious offenders, the council can apply for a banning order preventing the landlord from letting any property in England for up to 12 months. Banning orders are recorded on the national Rogue Landlord Database.

Section 21 (now abolished under the Renters' Rights Act 2026) was previously unavailable to landlords letting unlicensed. The replacement Section 8 possession routes under the new Act require the landlord to show ongoing licensing compliance — an unlicensed letting blocks the possession claim entirely.

A property can be subject to both additional and selective licensing at the same time where the borough has both schemes overlapping the property's location. The two licences cover different aspects — additional licensing covers the HMO management standards, selective licensing covers the broader private rented sector standards including anti-social behaviour and tenant management.

Application and fees are usually separate. Some boroughs offer combined applications where the property qualifies for both, but the two licences remain legally distinct and either can be revoked independently. We recommend treating them as parallel obligations rather than a single combined compliance.

Evidence pack overlap is significant — the EICR, CP12, EPC and FRA serve both licences. The differences sit in the management plan (additional licensing has stricter HMO-specific management standards) and the room-size schedule (additional licensing requires Schedule 4 compliance; selective does not).

Additional licensing designations run for up to five years before requiring renewal. The council must consult publicly before designating or renewing — typically a 10-12 week consultation with landlord, tenant and resident input considered.

Designations can be challenged via judicial review if the evidence base is inadequate. Several London additional licensing schemes have faced JR challenges from landlord associations, with mixed outcomes. The challenges have generally tightened the council's evidence requirements without overturning the schemes.

Renewal periods are an opportunity to lobby for scheme amendments — fee reductions, fast-track routes, scheme boundary changes. Landlord associations and individual portfolio landlords engage with the consultation to shape the next designation period.

Where a property crosses a designation boundary — common where the borough has selective licensing in some wards and additional in others — the property's licensing position can change at the designation renewal date. We monitor designation calendars and flag affected properties to clients well in advance of the renewal date.

First-time HMO licence applications have a high rejection rate in London — many sources cite 30%+ first-pass rejection, mostly due to incomplete evidence packs, expired certificates, or floor plans that do not show Schedule 4 compliance. Professional assistance dramatically lowers the rejection rate.

Look for a provider with a documented success rate, a published price (not a quote-on-enquiry model), familiarity with the specific borough's portal and a willingness to attend inspections. Generic 'compliance' providers without HMO experience often miss borough-specific quirks.

Our HMO licensing assistance service is £400 per property, covers evidence preparation, application submission, council liaison and inspection attendance, and includes free re-submission if the council requests additional information. We work across all London boroughs and maintain current contact relationships with the licensing teams.