HMO operators got hit with more enforcement notices in 2025 than in any year on record. Councils are well-resourced now and the bar for documentation has risen. This is the checklist we walk every new HMO client through.
1. Your HMO licence
Mandatory licensing applies to HMOs with 5+ unrelated occupants forming 2+ households. Many London boroughs (Bromley included for parts of Beckenham) also operate additional or selective licensing schemes that lower the threshold to 3 occupants — check your council's website to confirm which schemes apply to your address.
Licences are valid for 5 years and require renewal. Operating without a valid licence is a criminal offence with fines starting at £30,000 per property and rent-repayment orders running into tens of thousands more. Renew at least 6 weeks before expiry.
2. Fire safety
- Annual fire risk assessment by a competent person — required under RRFSO 2005.
- Quarterly fire door inspections for HMOs over 11m, six-monthly for smaller HMOs.
- Mains-powered, interlinked smoke alarms on every floor, with battery backup. Heat alarms in kitchens. Tested monthly with logged results.
- Means of escape: clear routes, no obstructions, no double-cylinder locks on escape doors, emergency lighting where required.
- Carbon monoxide alarms in any room with a fuel-burning appliance.
3. Electrical
- Electrical Installation Condition Report (EICR) every 5 years by a registered electrician. C1 and C2 codes must be remedied within 28 days.
- Portable Appliance Testing (PAT) annually for any landlord-supplied appliances.
- RCD protection on all circuits — non-compliance with the 18th edition wiring regs is a fast-track failure point.
4. Gas safety
Annual Landlord Gas Safety Certificate (CP12), carried out by a Gas Safe registered engineer. Copy to be provided to tenants within 28 days of inspection (and to any new tenant before they move in). Keep records for 6 years.
5. Structural & amenities
- Adequate kitchen facilities per occupant count (varies by licence conditions).
- Adequate bathroom facilities — typically 1 bathroom per 5 occupants.
- Minimum room sizes met (per the Housing Act 2004 statutory definition).
- Heating capable of maintaining 18°C in bedrooms and 21°C in living areas.
- Hot & cold water to all kitchen and bathroom outlets.
6. Tenancy & "fit and proper" person
- Right to Rent checks on every adult occupant — repeat for time-limited visas.
- Deposit protected in an approved scheme within 30 days; prescribed information served.
- "How to Rent" guide issued at the start of every new tenancy.
- EPC rated E or better — and the rules tighten to C by 2028 for new tenancies.
7. Furniture & soft furnishings
All upholstered furniture must comply with the Furniture and Furnishings (Fire) (Safety) Regulations 1988 — labels intact, no pre-1988 stock. Don't inherit furniture from outgoing tenants without verifying compliance.
8. Records to keep
Council inspectors will ask for a documented chain of custody on every duty above. The minimum binder we recommend for every HMO:
- Current HMO licence + conditions schedule
- Latest fire risk assessment + remedial action log
- Fire door inspection reports (quarterly or six-monthly)
- Smoke/CO alarm test logs (monthly)
- EICR + remediation evidence
- Annual Gas Safety Certificate
- Annual PAT report
- EPC + improvement plan if rated D or below
- Tenancy documents per unit
What gets HMO operators fined in 2026
From our work with councils in SE London, three recurring themes:
- Out-of-date fire risk assessments — many HMOs have one from when they got their licence and never updated it.
- Disabled self-closers on fire doors — tenants remove them; nobody notices until an inspection.
- Missing EICRs or unactioned C2 codes — the most-quoted line on enforcement notices.
Need an HMO compliance audit?
We'll walk every duty above and give you a written gap-list with priorities and costs.
