HMO Compliance Checklist for London Landlords 2025

The Complete HMO Compliance Checklist for London Landlords

Operating a House in Multiple Occupation in London means carrying a compliance burden that goes far beyond the standard private rental. Every certificate has a renewal interval, every physical requirement has a standard, and the penalties for getting it wrong are severe. This checklist organises every obligation by category so you can audit your property and your documentation in a single pass.

Gas Safety: CP12 (Annual)

Every gas appliance, fitting, and flue in the HMO must be inspected annually by a Gas Safe registered engineer. The Landlord Gas Safety Record — commonly called the CP12 — must be provided to existing tenants within 28 days of the inspection and to new tenants before they move in. The record must be retained for at least two years. A gas safety check on an HMO with a central boiler, multiple gas hobs, and any gas fires will typically take longer than a single-let property — factor this into booking lead times. Do not let the certificate lapse: there is no grace period under the Gas Safety (Installation and Use) Regulations 1998.

Electrical Safety: EICR (Every 5 Years, Some Boroughs 3)

An Electrical Installation Condition Report must be carried out by a qualified electrician and must produce a result of "Satisfactory" before it can be used as a compliance document. The standard renewal interval is every five years, but many London borough HMO licences impose a three-year condition. Check your licence conditions carefully. Any C1 (danger present) or C2 (potentially dangerous) observations require remediation before the installation is considered satisfactory. A copy must be provided to tenants on request and to the local authority within seven days of a written request.

Fire Risk Assessment (Annually for Complex HMOs)

The Regulatory Reform (Fire Safety) Order 2005 requires a Fire Risk Assessment for the common parts of all HMOs. For larger or more complex HMOs — those with more than two storeys, more than five occupants, or complex layouts — annual review is recommended and many London boroughs require evidence of an annual FRA as a licence condition. The assessment must be carried out by a competent person and must be reviewed whenever a significant change occurs: new occupants, structural works, change of use of a room, or an incident.

PAT Testing (Annually)

Portable Appliance Testing is not required by a single specific law but is required by many HMO licence conditions in London. For HMOs where the landlord provides electrical appliances — kettles, microwaves, washing machines, vacuum cleaners — annual PAT testing is the standard required interval. Each tested item must be labelled with the test date and pass result. Items that fail testing must be removed from service immediately.

Legionella Risk Assessment (At New Letting)

HSE L8 ACOP requires every landlord to assess and document the Legionella risk in the water system. For HMOs with stored hot water, cold water tanks, shared showers, and complex pipework, the risk is higher than in a combi boiler single-let. A written Legionella risk assessment must be produced and retained. Annual re-assessment is recommended for HMOs. The assessment must be reviewed on re-letting and after any work on the water system.

Smoke Alarms and Heat Detectors

Every floor of the HMO must have at least one smoke alarm. Every bedroom must have its own smoke alarm — this is a specific HMO requirement beyond the general residential standard. A heat detector must be installed in the kitchen, where cooking fumes would cause a smoke alarm to false-trigger. All carbon monoxide alarms must be positioned in every room that contains a gas appliance. Alarms must be tested at the start of every tenancy. Interlinked alarms are required in HMOs so that an alarm in one room activates all alarms throughout the property.

Fire Doors

All habitable rooms opening onto a shared escape route must be fitted with FD30 fire doors — doors rated to resist fire for 30 minutes. This includes every bedroom door and the kitchen door. Fire doors must be self-closing and must not be held open by non-compliant door retainers. Intumescent strips and cold smoke seals must be fitted and must be undamaged. Gaps around the door frame must not exceed three millimetres. Fire door maintenance should be checked as part of every routine HMO inspection.

HMO Room Size Requirements

Statutory minimum room sizes apply to all licensed HMOs: 6.51 square metres for a single occupant, 10.22 square metres for two occupants. Any room below 4.64 square metres cannot be used as a sleeping room under any circumstances. Measurements exclude areas where the ceiling height falls below 1.5 metres. Many London boroughs impose stricter standards as licence conditions. Non-compliant rooms must either have their occupancy reduced or — if they fall below the absolute minimum — be taken out of use as bedrooms.

HMO Licensing Documentation

A mandatory HMO licence is required for all properties occupied by five or more people from two or more separate households. Additional and selective licensing schemes across many London boroughs extend this requirement further. Licence applications typically require: proof of ownership or authority to manage, a current CP12, a current EICR rated satisfactory, a current Fire Risk Assessment, a floor plan showing room sizes, and evidence of planning permission where required. Fees range from approximately £500 to £2,000 depending on the borough and property size. Licences run for five years.

Penalties for Non-Compliance

Operating a licensable HMO without a licence is a criminal offence. The local authority may issue a civil penalty of up to £30,000 per offence rather than prosecuting. Tenants may apply to the First-tier Tribunal for a Rent Repayment Order requiring the landlord to repay up to twelve months of rent received while operating without a licence. Failure to comply with licence conditions — including certificate requirements — can result in revocation of the licence, banning orders, and inclusion on the national rogue landlord database. The financial and reputational consequences of non-compliance in London are substantial, making a structured compliance programme essential for every HMO landlord.