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Compliance guides· 8 min read

HMO Compliance Checklist London 2026: Every Requirement Explained

Houses in Multiple Occupation (HMOs) carry more compliance obligations than standard lets — tighter certificate renewal cycles, mandatory fire safety measures, and licences that councils inspect and enforce. This checklist covers everything you need to stay on the right side of London's councils in 2026.

Does my property qualify as an HMO?

A property is an HMO if **three or more unrelated people** share basic facilities (kitchen or bathroom) and it is their only or main home.

  • A 4-bedroom house rented to 4 unrelated young professionals: **HMO**
  • A 2-bedroom flat rented to a couple: **not an HMO**
  • A 3-bedroom house with a live-in landlord and two lodgers: the landlord-occupier exemption may apply — check with your local authority

Large HMOs (5+ people, 3+ storeys) require a mandatory HMO licence from the council. Many London boroughs have extended their licensing schemes to include smaller HMOs — check your specific borough.

HMO licences — what's required

If your property requires a licence (mandatory, selective or additional depending on your borough), you must:

  • Apply before tenants move in (you cannot retrospectively licence an already-occupied unlicensed HMO without risk of enforcement)
  • Provide all required safety certificates as part of the application
  • Meet the council's physical standards (room sizes, facilities, amenity standards)
  • Renew the licence every 5 years (some boroughs charge per-bedroom)

London boroughs with the broadest licensing schemes include Newham, Waltham Forest, Southwark, Brent, Harrow, and most inner-London authorities. Always check your specific council's requirements.

Gas Safety Certificate (CP12) — annual, mandatory

Same rules as standard lets: every 12 months by a Gas Safe registered engineer. Certificate must be given to tenants within 28 days and before a new tenant moves in.

For HMOs with a communal boiler or gas supply, all appliances on the system must be inspected — don't assume the gas check for one part of the building covers shared pipework or communal equipment elsewhere.

EICR — every 3 years for HMOs

Where a standard let requires an EICR every 5 years, **most HMOs require one every 3 years**. Some London council HMO licence conditions specify even shorter intervals or require a copy of the current certificate to be lodged with the licensing team at every renewal.

The wiring in older converted properties common in London (Victorian and Edwardian houses split into bedsits or flats) often shows deterioration more quickly under heavier shared use. A 3-year cycle reflects this.

Fire Risk Assessment — mandatory for all HMOs

A documented fire risk assessment by a qualified assessor is a hard requirement for every HMO. It must be:

  • Carried out before the property is first let as an HMO
  • Reviewed annually (or sooner after structural changes)
  • Made available to tenants and the council on request

The assessment covers: escape routes and fire doors; means of detection (alarms); means of giving warning; means of fighting fire (extinguishers); emergency lighting; and general housekeeping.

Fines for failing to have a compliant fire risk assessment in place are unlimited, and prosecution is possible in cases of serious risk.

Fire alarm system (BS 5839)

Most HMOs with 3+ storeys or 5+ occupants require a Grade D or Grade A connected fire alarm system. Interlinked mains-powered smoke alarms are the minimum standard for most smaller HMOs.

The required grade and category (L1, L2, L4 etc.) should be specified in your fire risk assessment and/or your council's HMO licensing conditions. We carry out alarm certification and panel inspections to BS 5839.

Emergency lighting (BS 5266)

Larger HMOs — typically those with communal corridors, stairwells or more than two storeys — require emergency lighting in escape routes. The specification is set by your fire risk assessment.

Emergency lighting must be tested monthly (brief function test) and annually (full-duration test), with records kept.

PAT testing

For furnished HMOs, PAT testing of all portable appliances provided by you (white goods, kettles, lamps, extension leads) is expected annually. Many HMO licences explicitly require it as a condition of licensing.

Room and amenity standards

London councils set minimum room sizes for HMO bedrooms (typically 6.51 m² for a single adult, 10.22 m² for two adults sharing). You must also provide:

  • A minimum number of bathrooms/shower rooms and toilets based on occupancy
  • An adequate kitchen with cooking facilities proportional to the number of residents
  • Adequate natural lighting and ventilation in all habitable rooms

Your council's HMO licensing team will inspect these standards as part of the licensing process.

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