Additional HMO Licensing Requirements | Coopers Inventory Services

Not every House in Multiple Occupation (HMO) falls within the national mandatory HMO licensing rules.

However, that doesn't necessarily mean the property can be operated without a licence.

Under the Housing Act 2004, local authorities in England can introduce Additional HMO Licensing schemes that extend licensing requirements to HMOs that fall outside mandatory licensing.

This means that a smaller shared property which doesn't require a mandatory HMO licence could still require an Additional HMO Licence, depending upon its location and the licensing scheme operated by the local council.

For landlords, letting agents and property managers, checking the specific licensing requirements for the property address is therefore essential.

Additional HMO Licensing allows a local authority to extend HMO licensing beyond the properties covered by the national mandatory licensing regime.

Under Section 56 of the Housing Act 2004, a council can designate all or part of its area as subject to additional licensing for specified types of HMO.

Unlike mandatory HMO licensing, an Additional Licensing scheme does not automatically apply everywhere in England.

It only applies where a local authority has formally introduced a designation and only to the types of property covered by that particular scheme.

Additional HMO Licensing is location-specific;

A property may require an Additional HMO Licence in one council area while a similar property elsewhere may not.

Additional licensing is commonly used to bring smaller HMOs within a council's licensing regime.

For example, a property occupied by:

may meet the definition of an HMO without meeting the five-person threshold for mandatory HMO licensing.

If that property is situated within an area covered by an Additional Licensing scheme — and is of a type included within the designation — it may still require a licence.

However, landlords shouldn't use “three or four tenants = Additional Licence” as a universal rule.

The precise properties covered depend upon the council's individual designation.

Some schemes can also cover particular types of HMO that aren't obvious shared houses. Certain buildings converted into self-contained flats can, for example, fall within the HMO provisions in specific circumstances.

So the correct question isn't simply:

“How many tenants live there?”

It is:

“What type of HMO is this, and is it covered by an Additional Licensing designation at this address?”

Mandatory HMO Licensing | Additional HMO Licensing

Where does it apply? | National regime | Only designated council areas

Typical occupancy | 5+ people forming 2+ households | Can cover smaller HMOs

Who determines

coverage? | National legislation | Local authority designation

Same rules

everywhere? | Core mandatory | No — designation varies

threshold applies locally nationally

Should landlords

check the council? | Yes | Absolutely

For the full explanation of the national HMO requirements:

Additional licensing gives councils a mechanism to address problems associated with HMOs that aren't already caught by mandatory licensing.

The Housing Act framework allows councils to designate additional categories of HMOs where the statutory requirements for introducing a scheme are met.

Before introducing a designation, a local authority must consider matters including its wider housing strategy and whether other courses of action could address the identified problems. Consultation requirements also apply.

For landlords, though, the important practical point is:

Licensing schemes can change.

A property that didn't require an Additional Licence when it was first purchased or let may later fall within a new designation.

Landlords should check the website of the local authority in which the property is situated.

Look specifically for:

GOV.UK also provides a service that directs landlords to the appropriate council for HMO licensing enquiries.

Check HMO licensing for your property — GOV.UK

Coopers Inventory Services works with landlords, letting agents and property managers across Surrey and surrounding areas.

Property licensing requirements can differ between local authorities, so landlords with properties across several locations should check the requirements for each individual property rather than assuming the same licensing rules apply across their portfolio.

Where an Additional Licence is required, the application is made through the relevant local authority.

The exact application process, documentation and fee can vary between councils.

Landlords may be asked for information concerning matters such as:

The council will also need to be satisfied about matters such as the suitability of the property and whether the proposed licence holder or manager meets the applicable fit and proper person requirements.

HMO licences can be issued for a maximum of five years.

A council can grant a licence for a shorter period, so landlords shouldn't simply assume:

Licence granted = forget about it for five years.

Record the actual expiry date and check the council's renewal requirements in good time.

A licence can contain conditions concerning how the property is occupied and managed.

Depending upon the scheme and property, landlords may need to demonstrate appropriate arrangements concerning:

The local authority may impose additional conditions appropriate to the property or its licensing scheme.

Operating an HMO that requires licensing without the appropriate licence is an offence under the Housing Act 2004.

For relevant offences committed from 1 May 2026, a local authority can impose a civil financial penalty of up to £40,000 as an alternative to prosecution. The government's current civil-penalty guidance specifically includes an unlicensed Additional HMO among Housing Act 2004 offences.

Criminal prosecution can alternatively result in an unlimited fine for operating an HMO without the required licence.

There may also be other consequences, including the possibility of a Rent Repayment Order in qualifying circumstances.

Important 2026 Update

From 1 May 2026, the maximum civil financial penalty for relevant Housing Act 2004 offences increased from £30,000 to £40,000.

There are interactions between property licensing and possession proceedings, but possession law changed significantly from 1 May 2026, and the consequences can depend on the possession ground and circumstances.

Failure to comply with applicable property-licensing requirements can also have consequences beyond the immediate licensing offence. Landlords considering possession proceedings where licensing requirements have not been met should obtain current specialist advice.

Generally, no.

An HMO licence is granted to a particular licence holder and is not simply transferred with the property to a new owner.

If ownership or management arrangements change, the new owner should contact the relevant council promptly to establish what application or licensing action is required.

Additional HMO Licensing is ultimately about maintaining appropriately managed shared accommodation — and good property records can form part of professional property management.

Coopers Inventory Services provides independent written and photographic reporting for landlords, letting agents and property managers throughout the tenancy lifecycle.

An Inventory & Schedule of Condition provides a detailed record of individual rooms, communal areas, fixtures, furnishings and visible property condition at the beginning of a tenancy.

Mid-Term Property Inspections can provide a further documented snapshot during occupation, helping landlords and property managers identify visible changes, deterioration or maintenance concerns that may require attention.

A Check-Out Report provides a further record when the tenancy ends.

Coopers reports do not determine whether a property requires an Additional HMO Licence and are not licensing, HHSRS, fire-risk or legal compliance assessments. Licensing requirements should always be checked directly with the relevant local authority.