HMO Licensing in London 2025: Recent Changes and What Landlords Need to Know
An update on HMO licensing requirements in London for 2025 — mandatory licensing thresholds, additional and selective licensing schemes in London boroughs, and the key compliance documents required.
Mandatory HMO Licensing: The National Threshold
Mandatory HMO licensing under the Housing Act 2004 applies to any property occupied by five or more persons forming two or more separate households, regardless of the number of storeys. This definition has been in place since October 2018, when the previous "three storey" threshold was removed. A purpose-built bedsit block with five rooms on a single floor requires a mandatory HMO licence. A Victorian terraced house let to five professionals requires a mandatory HMO licence. There is no minimum storey requirement at the national level.
Mandatory HMO licences are issued by the local authority for the area in which the property is located and are typically valid for five years. The licence conditions specify the maximum number of occupants, the fire safety measures required, the electrical and gas safety certificate requirements, and often the specific physical standards to which the property must be maintained — room sizes, kitchen facilities, bathroom provision, and waste disposal arrangements. Non-compliance with licence conditions can result in licence revocation, civil penalties of up to £30,000, and rent repayment orders requiring landlords to refund up to 12 months of rent to tenants.
Additional Licensing in London Boroughs
In addition to mandatory licensing, London borough councils can designate areas for additional licensing, which extends the HMO licence requirement to smaller HMOs — typically properties occupied by three or four persons forming two or more households that fall below the mandatory licensing threshold. Additional licensing designations must be renewed every five years and require consultation and sign-off by the Secretary of State. As of 2025, a significant majority of inner London boroughs operate some form of additional licensing scheme covering parts or all of their area, including Hackney, Tower Hamlets, Southwark, Lambeth, Lewisham, Newham, Islington, and Camden. Landlords should check with the relevant local authority to confirm whether their property falls within an additional licensing designation.
Selective Licensing
Selective licensing extends licensing requirements beyond HMOs to all privately rented properties — including single-let properties — within a designated area. Selective licensing schemes are used by local authorities in areas with high concentrations of private renting, low housing conditions, or anti-social behaviour issues. London boroughs that have operated or are operating selective licensing schemes include Newham (the pioneering scheme), Waltham Forest, Croydon, Brent, and several others. A selective licence typically costs between £500 and £800 per property and is valid for five years.
Key Compliance Documents for HMO Licensing
An HMO licence application requires a comprehensive set of compliance documents. The core documents required by virtually all London boroughs include: a valid gas safety certificate (CP12) issued within the past 12 months; a valid EICR issued within the past five years (some boroughs require three-year cycles); an EPC; a PAT testing certificate for all landlord-supplied appliances; a fire risk assessment; and evidence of smoke and CO alarm installation. Some boroughs also require a Legionella risk assessment, evidence of building insurance, and a management plan describing how the property will be managed during the licence period.
Room Size Standards
The Housing Act 2004 and the Licensing and Management of Houses in Multiple Occupation (Additional Provisions) (England) Regulations 2007 set minimum room sizes for sleeping accommodation in HMOs. As of 2018, the minimum floor area for a room occupied by one person is 6.51 square metres; for a room occupied by two persons, 10.22 square metres. Rooms below 4.64 square metres cannot be used as sleeping accommodation. These are absolute minimums — many London boroughs apply more generous standards as licence conditions, and the HHSRS assessment framework may identify overcrowding as a Category 1 hazard at sizes above the statutory minimum.
Changes to Expect in 2025 and Beyond
The Renters Reform Bill and subsequent Renters (Reform) Act 2024 have introduced changes to the tenancy framework that affect HMO landlords alongside other private sector landlords. The abolition of Section 21 "no fault" evictions means that landlords must rely on Section 8 grounds to recover possession — this has implications for how HMO landlords manage problematic tenancies and for the practical operation of co-living arrangements. The Decent Homes Standard, which currently applies only to social housing, has been proposed for extension to the private rented sector, which would introduce mandatory physical standards that overlap with but are distinct from HMO licensing conditions. Landlords should monitor the progress of this legislation and its implementing regulations.