How to Apply for HMO Mandatory Licensing London (2026 Step-by-Step)

Mandatory HMO licensing applies in England to any HMO occupied by five or more persons forming two or more separate households. The threshold is set by the Licensing of Houses in Multiple Occupation (Prescribed Description) (England) Order 2018, which removed the previous three-storey rule and made the test purely occupancy-based.

Two households means two or more groups not related as a single family. Five unrelated adults sharing a flat are five households for licensing purposes. A couple plus three lodgers is four households. A single family of seven is one household and is not an HMO under the mandatory definition.

The threshold is national and applies regardless of borough. Every London council operates mandatory licensing on the same statutory basis, although each council sets its own fees and application portal. Additional and selective schemes sit on top of this and can pull smaller properties into licensing in specific boroughs.

The licence runs for up to five years and is non-transferable between landlords. Selling the property requires the new owner to apply for a fresh licence; the licence does not transfer with the property.

Count the occupants and households at the point of application. If the property is five-plus persons in two-plus households, mandatory licensing applies. If it is three-plus persons but below mandatory threshold, check whether the borough has additional licensing — many do.

Confirm which scheme covers the property. The council website usually has a postcode search that returns the licensing position for the address. Where the property is in a selective licensing street as well as a mandatory HMO, both licences are needed separately.

Identify the licence holder. The holder must be the person who controls or manages the property — usually the freeholder or long leaseholder. A managing agent can be named as the manager but the holder must be the property's controlling owner.

Run a DBS check on the named manager. Standard DBS is sufficient; enhanced DBS is not required for HMO licensing. The check takes 2-4 weeks and is the most common delay point in first-time applications.

EICR — Electrical Installation Condition Report, full periodic, within 5 years and satisfactory. The EICR must cover the entire installation including communal areas. Any C1 or C2 findings must be remedied and a separate confirmation of remediation provided.

EPC — Energy Performance Certificate within 10 years and at band E or higher (MEES current threshold). Forward MEES plan to reach band C by October 2030 is required by some boroughs as supporting documentation rather than a hard requirement.

CP12 — Landlord Gas Safety Record within 12 months from a Gas Safe registered engineer. Required for every gas appliance in the property.

FRA — Fire Risk Assessment under the Regulatory Reform (Fire Safety) Order 2005. PAS 79 format is the standard expectation. Must cover communal areas and identify the responsible person.

Smoke and CO alarm schedule — written confirmation that BS 5839-6 Grade D LD2 coverage is installed throughout, with model details and end-of-life dates per alarm. CO alarms documented per the 2015 Regs as amended 2022.

Management plan — written plan covering tenant selection, tenancy agreements, repair response times, complaint handling, out-of-hours contact and refuse arrangements. Most boroughs publish a template.

DBS check — Standard DBS certificate on the named property manager, within 3 years.

Floor plans — scaled to show room sizes meeting Schedule 4 minimums: bedrooms over 10 years old occupants minimum 6.51m², children under 10 years minimum 4.64m², plus communal kitchen 10.22m² for up to five occupants. Drawn to scale, ideally CAD or competent hand survey.

Most London boroughs operate an online HMO licensing portal. The application is completed online with evidence uploaded as PDFs. Each document has a maximum file size — large floor plans sometimes need optimising before upload.

Fee bands vary by borough and property size. Westminster runs at the higher end (£1,200 for a 5-bed HMO); outer boroughs like Bexley run lower (£700-£850). Some boroughs charge a flat fee per property; others charge per bedroom.

Two-part fees are common — Part A on application (typically 60% of total) and Part B on grant of licence (typically 40%). The Part A fee covers the initial processing and is non-refundable even if the application is refused.

Payment is online card or BACS. Cheque is still accepted by some boroughs but processing is slower. Receipt of payment is the formal application date that starts the council's statutory decision clock.

Most councils inspect the property as part of the licensing decision. The inspection is usually within 6-10 weeks of application and is arranged via the licensing officer assigned to the case.

The inspector verifies that the evidence pack matches the property as inspected. Room sizes, fire safety arrangements, alarm coverage and amenity standards are all checked against the application documents. Any discrepancy is flagged and the application is paused for clarification.

Where the inspection identifies remedial works, the council typically issues a conditional licence — the licence is granted subject to specified works completed within a defined window (28 days for safety items, often 6 months for amenity items). Failure to complete conditions can lead to licence revocation.

Decision timeline is 12-16 weeks from complete application. Add 2-4 weeks where DBS is in progress at application date or where inspection requires re-attendance.

Letting an HMO without a required mandatory licence is a criminal offence. The Civil Penalty in lieu of prosecution can reach £30,000 per breach per property. Multiple breaches across a portfolio produce stacked penalties.

Rent Repayment Orders can require the landlord to repay up to 12 months of rent received during the unlicensed period. The order can be claimed by the tenant or by the council. Newham, Hackney and Croydon all run active RRO programmes and tenant solicitors will act on a no-win-no-fee basis.

Banning orders prevent the landlord from letting any property anywhere in England for up to 12 months and are recorded on the national Rogue Landlord Database. A banning order substantially damages the landlord's commercial position and is increasingly used for repeat offenders.

Our HMO licensing assistance service is £400 per property and covers full evidence-pack preparation, application submission, council liaison and inspection attendance. The fee is paid back many times over by avoiding the most common reasons applications are rejected — incomplete evidence, mis-stated room sizes, expired certificates and inconsistent management plans. We have a 100% first-pass success rate across the boroughs we routinely work in.

Room sizes — the Schedule 4 minimums are precise (4.64m² for children under 10, 6.51m² for adults, 10.22m² for a double bedroom) and the inspector measures wall to wall, excluding sloping ceilings below 1.5m head height. Loft-room conversions frequently fail because the usable floor area is smaller than the gross floor area shown on the original conversion drawings.

Expired EICR — an EICR issued more than five years before application date is not valid, even if it was satisfactory at the time. Some landlords submit an old EICR thinking that 'satisfactory' means perpetual; the council rejects the application and requires fresh testing.

Inconsistent management plan — the plan must match the actual management arrangement. Where the application names the freeholder as licence holder but the day-to-day management is an agent, the plan must specify the agent's role, contact details and out-of-hours arrangement. Inconsistencies trigger rejection.

Missing DBS — the named manager's Standard DBS certificate must be within three years of application date. DBS processing takes 2-4 weeks and is the most common single delay point in first-time applications. We routinely start DBS on day one of engagement to remove it from the critical path.

Outdated FRA — the FRA must be current and reviewed within the past 12 months. A two-year-old FRA without an annual review is rejected. The council inspector expects to see the latest review date on the cover page.

Schedule 4 of the Licensing of Houses in Multiple Occupation (Prescribed Description) (England) Order 2018 sets the minimum amenity standards for licensed HMOs. The provisions are detailed and unambiguous, and councils apply them strictly.

Bedrooms — minimum 6.51m² for any room used by a person over 10 years old. Double-occupancy bedrooms minimum 10.22m². Rooms with a sloping ceiling are measured at floor level excluding any area where the ceiling is below 1.5m. Loft bedrooms and converted-attic bedrooms are the most likely to fail.

Kitchen — minimum 10.22m² for a kitchen serving up to five occupants, with proportional increases for larger HMOs. The kitchen must have appropriate worktop space, sufficient cooking facilities (rings, oven), refrigerator and food storage, and adequate ventilation. Open-plan kitchen-diners count the total floor area.

Bathroom and lavatory — at least one bathroom and one separate lavatory for every five occupants. The bathroom must contain a bath or shower, a wash basin and adequate ventilation. A combined bathroom-lavatory counts as both if there is no separate facility, but the ratio remains one combined facility per five occupants.

Common pinch point — Edwardian and Victorian terrace conversions often have an upstairs single bathroom serving five-plus occupants. This fails the Schedule 4 ratio and requires either a second bathroom retrofit or a reduction in occupancy. We routinely see this on inspection.

London councils vary in their responsiveness during the application process. The best-organised teams (Newham, Hackney, Southwark) respond to queries within 5-10 working days. Less well-resourced teams can take 4-6 weeks to respond to a clarifying question.

We maintain working relationships with the licensing teams at every major London borough. A direct call from a known professional often resolves queries faster than the formal portal route. This is one of the practical advantages of using a specialist assistance service rather than handling the application in-house.

Where the council issues a conditional licence with remedial works required, we project-manage the works to the deadline. The conditions typically specify 28 days for safety items and 6 months for amenity items. Failure to complete within the window can lead to revocation.