HMO licensing

This page was last updated: 02 October 2023

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HMO Licence issues

What is an HMO?

“HMO” stands for “House in Multiple Occupation.” It is defined as being a house where two or more unrelated households share amenities. It includes what people call bedsits.

The property is an HMO if it is tenanted by 3 or more unrelated persons forming two or more households and sharing basic amenities. Note that a group of friends is not regarded as a household, as they are not related; basic amenities are defined as a toilet, personal washing facilities or cooking facilities.

Do all HMOs need a licence?

Yes. In Coventry, Additional licensing of HMOs has been introduced so currently all HMOs need a licence. If they comprise three or more people or are flats provided without Building Regulations these are included in Additional licensing. An HMO with five or more people would need a Mandatory licence.

If you would like an officer to inspect your property to determine whether it is licensable and whether any works are required to bring it up to HMO standard, you can pay for a pre-licensing advice visit.

Is this the case across the UK?

In England and Wales, all HMOs that comprise five or more people require a licence. For local schemes, check with the relevant local authority about whether there are any discretionary licensing schemes in place.

What if my HMO doesn’t take up the whole building?

The HMO regulations look at the whole building, not just the portion being used as a domestic property. So if, for example, your HMO is a duplex flat above a food business, it would require a licence if there were three or more people living there.

How do I apply for an HMO Licence?

You’ve come to the right place! Please see the Licensing Process page to access the on-line application form.

How much does it cost?

Please see the Fees and Charges page for full details of our fees and charges. The Stage 1 fee, which is payable upon submission of your application, is £640. The Stage 2 fee, which is payable when we issue the draft licence, is variable depending upon the length of your licence.

We can only charge what it costs us to process the licensing application and run/ enforce the scheme; we do not make any profit from it.

How long does the application process take?

That depends on how many people are ahead of you in the queue, and how complete your application is. We will always process complete applications as quickly as possible.

One question that is frequently skipped is information about the house’s mortgage provider. If you have a mortgage on your house, we need to write to your mortgage provider as part of the application process, so it’s important that you provide their address. Please ensure your application is accurate and complete for any queries please email hmo@coventry.gov.uk.

Once we have all the necessary information, have performed all the mandated checks, and the fee has been paid, we will issue a Draft Licence to you and to anyone else with a legal involvement in the property. You will then have twenty-one days to let us know if you have any objections to the terms of the Draft. If we receive no objections, we will then issue the Full Licence.

How long does an HMO licence last?

We have three different licence lengths available. a 1 year licence, 2 year licence and 5 year licence. Please see the Length of Licence page for more details and the eligibility criteria.

Are HMO licences transferable?

No. If you buy a house which has a current HMO licence, that licence will cease to be valid once you take ownership, so you will need to submit a new application as soon as possible. If an HMO application is still in progress but the property has been sold, then you should email hmo@coventry.gov.uk and inform us so that we can withdraw the HMO application.

Are HMO licences refundable?

Under most circumstances, no. We realise that if you sell your house one year after your licence is granted, you’ve only benefitted from it for twenty per cent of its duration, but we’ve done a hundred per cent of the work processing your application and issuing the licence and the licence fee covers the cost of that work.

Do I need Planning Permission to operate an HMO?

On 30th September 2023 an Article 4 direction was implemented across certain wards in Coventry. This direction removed the permitted development right to change the use of a C3 property (“dwellinghouse”) to a C4 property (“house in multiple occupation”) within the following wards: Cheylesmore, Earlsdon, Foleshill, Lower Stoke, Radford, St. Michael's, Sherbourne, Wainbody, Whoberley, Westwood and Upper Stoke.

Any person wishing to convert a residential house into an HMO within the affected wards will first need to make a change of use planning application, even if the HMO will have fewer than seven tenants. Properties that were already in lawful use as HMOs with fewer than seven tenants before the direction came into effect will not need to make a planning application.  However, if such a property ceases to be used as an HMO (for example, if it is rented to a single family) then a change of use planning application will need to be made to bring the property back into use as an HMO.

If the HMO will have seven or more lets or add a seventh or greater let to an existing HMO, you will need to apply for planning permission. HMOs occupied by seven or more people is known as Sui Generis and have always needed planning permission when changing from C3. You will also need planning permission if you’re moving from C4 to Sui Generis. The rules on seven-person Sui Generis Use Class apply city-wide. If you have any doubts about whether planning permission is needed or not, please contact our planning team at planning@coventry.gov.uk or consult the Planning Portal website.

Are there any Article 4 restrictions in Coventry?

On 6 September 2022, the Council voted to consult on an Article 4 designation to remove the permitted development right to change the use of a C3 property (“dwellinghouse”) to a C4 property (“house in multiple occupation”) within certain wards of the city. The Wards are: Cheylesmore, Earlsdon, Foleshill, Lower Stoke, Radford, St. Michael's, Sherbourne, Wainbody, Whoberley, Westwood and Upper Stoke.

This designation was approved and came into effect on 30 September 2023. Any person wishing to convert a residential house into an HMO within the affected wards will first need to make a change of use planning application, even if the HMO will have fewer than seven tenants. Properties that are already in lawful use as HMOs with fewer than seven tenants will not need to make a planning application, though the landlord may wish to consider applying for a Lawful Development Certificate.

Why do I need a licence and planning permission to run an HMO?

HMO licences and planning permission are governed by two entirely separate pieces of legislation, each of which considers criteria.

Put simply, licensing legislation is primarily concerned with the safety of the people living in the house – the licensing process establishes that the house has sufficient amenities for the tenants living there, has acceptable standards of fire safety, and that the landlord is a fit and proper person.  Planning legislation meanwhile is primarily concerned with the suitability of the use in principal and the impact the use may have on surrounding residents, roads and environment.

The two areas of legislation each have very specific and detailed requirements, which is why members of the Housing Enforcement and Property Licensing Team cannot give advice about Planning legislation, and vice versa. 

What do you mean by “Manager”?

A manager is a person or company, such as a letting agent, who manages the day to day running of your HMO. They may undertake any or all of the following duties: dealing with contracts, collecting rent, being the first point of contact for repairs, or otherwise administering the house and dealing with tenants. If you employ a manager, it is important that you include their details in the application paperwork.

Note that if you employ a manager, it is still your legal responsibility to ensure that the house is operated correctly and lawfully.

Do I have to employ a manager?

No, you can perform these duties yourself. However, if the Council determines that you will struggle to perform these duties in a timely manner (for example, if you live overseas and may not be able to come to the house quickly in the event of an emergency) we may make it a condition that you employ a local manager.

Can you recommend a manager/letting agent?

Coventry City Council is not able recommend third party businesses. However, you can view agencies that have been accredited by us on the CLAS webpages.

Do I need to notify you if there are any changes to the property?

You should notify us if you move house, change manager, if your manager changes address, or if you change mortgage provider. You should also notify us if you wish to change the maximum number of tenants and/or households in your HMO, or otherwise alter the amenities, as we may need to issue a Licence Variation.

Is there any charge for a Licence Variation or a Temporary Exemption Notice?

No. You may vary the details on a licence for without charge. You may also apply to exempt your property from licensing for 3 months without charge. You can apply for a TEN using the online application form.

What are the consequences of operating a licensable HMO without a licence?

You could face an unlimited fine, be prohibited from operating rented properties in Coventry, and be placed on a nationwide database of rogue landlords.

Do you operate a Landlord Accreditation Scheme?

Yes. the Coventry Landlord Accreditation Scheme (CLAS) is a free, voluntary scheme that private residential Landlords and Letting Agents are encouraged to join.

Do you have a list of HMOs in Coventry?

We have public registers of licensed HMOs and pending licence applications.

The HMO licence register includes landlords' details - is this not a breach of GDPR?

No. Article 6(1)(c) of the GDPR states that the processing of personal data is lawful if doing so “is necessary for compliance with a legal obligation to which the controller is subject”. Article 4(2) defines “processing” to include “disclosure by transmission, dissemination or otherwise making available”. The requirement to maintain a public register of HMO licences is set out in Section 232 of the Housing Act 2004, and the prescribed information to be provided on the public register is detailed in Regulation 11 of the Licensing and Management Regulations. Therefore, the publication of landlords’ details on our public register does not constitute a breach of the GDPR, as Coventry City Council is under a legal obligation to provide these data.

HMO Property condition requirements:

What standards does the HMO need to meet?

We have two documents that go into the necessary standards in depth: Homestamp, which details fire safety standards, and our Room Size and Amenity Provision Standards. Both documents are available in our advice library.

I’m in the process of setting up an HMO – can an officer come round to check that I’m doing everything right?

We are not able to offer any general advice on HMO legislation beyond that contained on this website. If you are considering converting a property into an HMO, and you would like us to visit your property to advise you on the HMO licensing requirements before you apply, you can request a pre-licensing inspection. There is a charge for this service. Please note that we are not able to physically inspect properties during the coronavirus lockdown.

Do I need to display the licence in the house?

Yes, the front page of the licence needs to be displayed clearly in a suitable communal area alongside other management information. The other pages of the licence (Schedules 1 & 2) do not need to be displayed, but they must be easily available to tenants. For example, you could give a copy to each tenant with their tenancy agreement or keep a copy in a “useful documents” folder in a communal area.

Where can I get further information on HMOs?

The Government’s web pages contain a wide range of useful information.

If you have specific questions about fire safety, you can contact the fire service at firesafety.admin@wmfs.net

If you have any general HMO questions that have not already been answered by this document, you can e-mail hmo@coventry.gov.uk or phone 024 7697 5467 during office hours. If you have a technical question about fire safety or amenity provision, please check to see whether it is answered in the Homestamp or Room Size and Amenity Provision Standards documents first.

Is a fire risk assessment compulsory? Who can conduct it?

Yes - for a licensable HMO it is a legal requirement to have a Fire Risk Assessment. A competent person can conduct the fire risk assessment and it must be reviewed on an annual basis. More information can be found on our Fire Risk Assessment page.

What legal requirement must be met for non-mandatory licensable HMOs?

Please note that currently, all HMOs in Coventry are licensable.

All HMOs, regardless of licensability, are subject to:

• Management Regulations – either The Management of Houses in Multiple Occupation (England) Regulations 2006 or The Licensing and Management of Houses in Multiple Occupation (Additional Provisions) (England) Regulations 2007 depending on the type of HMO
• The Housing Health and Safety rating System (HHSRS)

What information needs to be displayed on an HMO noticeboard?

You need to display the following information on an HMO noticeboard:

• Licence (if you have one to display)
• Manager's details
• Fire notice (what to do in the event of a fire)
• Waste notice

Do I have to display my details in the HMO?

The management details are required to be displayed within an obvious part of the HMO. On the HMO noticeboard is a good place.

Is emergency lighting compulsory in all licensable HMOs?

Emergency lighting is normally required for the larger higher risk HMOs, typically where they comprise three or more storeys. It could also be required where there are 6 or more occupants in a three storey HMO and in other HMOs where appropriate – it is dependent upon the risk and whether the layout of the building is such that the escape route is complicated or does not have sufficient borrowed light.

Are hardwired smoke detectors with battery back-up compulsory in all HMOs?

Yes – mains wired interlinked detectors are a legal requirement for all HMOs. Battery smoke detectors are not suitable.

Is an electrical certificate mandatory for all HMOs?

Yes – five yearly periodic testing of the electrical system is a legal requirement for HMOs. From July 2020, a five-yearly electrical safety certificate will be required for all privately rented properties, regardless of HMO status.

Who is responsible for cleaning the HMO and maintaining the gardens?

You are responsible, you can do this through an agreement with the tenants. However, if the property is not cleaned or the garden not-maintained, you will need to take steps to remedy the situation.

How long are supporting certificates for HMO applications valid?

• Gas Safety certificate (valid for 12 months).
• Electrical Installation and Condition Report (valid for a period of up to five years unless any shorter period was specified by the person who carried out the check). Please note that where an electrical safety report requires the landlord to undertake further investigative or remedial work (C1 or C2), the landlord must ensure that this work is carried out by a qualified person within 28 days or the period specified in the report if less than 28 days. A written confirmation for completion of the remedial work must be provided to each tenant and to the authority via email: housingenforcement@coventry.gov.uk
• Fire Alarm Test certificate (valid for a period of up to 12 months unless any shorter period was specified by the person who carried out the check). We do accept a self-certification form for Grade D fire alarm systems.
• Emergency Lighting Test certificate – if two or less storeys – this is not compulsory. However, if emergency lighting is fitted, then the certificate must be provided (valid for a period of up to 12 months unless any shorter period was specified by the person who carried out the check). We do accept a self-certification form for emergency lighting.
• Energy Performance Certificate (EPC) – minimum energy rating must be E or above (valid for 10 years).
• PAT certificate for any electrical equipment supplied to the tenants that is more than one year old (valid for 12 months).

I would like a status update regarding my HMO application:

We have noted that we receive a substantial number of requests for an update regarding HMO applications status. If you are looking for a quick update on your HMO application you can log into our HMO Licence register. You can manually search for your property. Once you have found your property if you select ‘Details’ on the right-hand side. You can view what stage of the licensing process your application is currently in. We are updating this section regularly so if you spot any issues with your property information, please let us know by emailing HMO@coventry.gov.uk.

Please see the below for more details regarding the licensing status meanings:

• Application Under Review – We have received an application, but it has not yet been allocated to a Property Licensing Assistant (PLA) to validate.
• Application Incomplete (Chasing) – A PLA has reviewed the application and determined that there is outstanding information or certificates.
• Application Complete (Valid) – A PLA has reviewed the application and determined it is complete and valid. This property is now awaiting an inspection from one of our officers.
• Inspected – Pending for Draft – The property has been inspected by one of our officers and we are waiting for this to be allocated back to a PLA.
• Draft Issued (Pending Reps) – A PLA has sent the Intention to Grant a Licence paperwork.
• Licence Granted Stage 2 Fee Outstanding – The licence has been granted. However, the stage 2 fee has not yet been paid and the licence is at risk of being revoked if it is not paid.
• Issued Granted – The licence has been granted.

If you search on our online register and do not find your application, this may be due to it being an application received before 26 September 2022. If you want an update on an application received before this date, you may need to email our HMO inbox and ask for an update.

Issues making an application or registering on our new system:

I cannot find my address when registering to make an account or fill in the application form?

You need to select ‘Can’t find your address and need to add it manually?’. This will enable you to input your address.

When I try to sign in, the system does not recognise my account even though I already have an account?

You may have been registered on our old system. As we have changed to a new system you will be required to register a new account. This can be done by selecting ‘Register here’ in the top right corner of the webpage. Then you can create an account.

I am not sure what type of application I need to make?

When you are on our application webpage. There are two options to identify the type of application you need to make. If you are unsure on the application type, you can click on our application triage (on the left hand side of the webpage) and answer some questions which will help you determine your licence type. Or if you already know the type you can select it from the options on the right.

I have received a message from the Property Licensing Team that I have not paid the Stage 1 Fee. How do I make this payment?

Please log in to our Online Portal (https://planandregulatory.coventry.gov.uk/licences/index.html), select Licensing / Licensing Home Page. On top of the page, you will find all recently submitted applications, with outstanding payments (Online Licences Invoices section). Please use "Pay" button to make the payment.

Alternatively, you can pay via our website: https://www.coventry.gov.uk/payonline, Select “Other Payments / Business and Licensing / Mandatory or Additional HMO Licence”.

If you cannot pay online, you can pay over the telephone with a credit or debit card by calling 02476 975 467.

I have accidentally added the wrong address or I would like to change my address when registering my profile. Can I change this address?

You can change this address at any point. You just need to select ‘edit profile’ in the top right corner after you have logged in. Then select edit profile. From here you can edit your address, email and contact number.

HMO and Article 4 Questions:

How does this affect HMO licensing?

When we receive an application for a licence, if there is no evidence that the accommodation was used as C4 before 30 September 2023, we may grant you a one-year licence. This period is to allow for you to put the planning affairs of your property in order by applying for (and being granted) planning permission for a change of use to C4.

If you are refused permission, or you are unsuccessful at any appeals to the Planning Inspectorate, then you must wind-down the business. This is done by commencing eviction proceedings on the occupants to reduce the numbers to a maximum of two or replace them with a single household family.

If you apply for a HMO licence again when you’ve been refused planning permission, we’ll refuse to grant a licence as the property is not suitable for use as an HMO.

How can I prove to HMO licensing the property has been occupied as an HMO?

If the property has not been licensed before 30 September 2023, you may consider providing with your HMO licence application a Lawful Development Certificate.

What if I have a C4 or Sui Generis HMO with a licence and a family move in?

You will have moved from C4/Sui Generis to C3 and lost your C4/Sui Generis planning use class. To move back to C4/Sui Generis, you must re-apply for planning permission.

My HMO property is not in the 11 wards

If your property is situated in Woodlands, Bablake, Holbrooks, Longford, Henley, Wyken or Binley & Willenhall, then you may change from C3 to C4 without restriction. However, you will need planning permission to change to Sui Generis (seven or more person HMO).

I want to report a HMO without planning permission

Please email planningenforcement@coventry.gov.uk 

I have more questions about Article 4

For further help & advice, please contact the Planning Policy team.