The HMO Compliance Checklist: Gas, Electrics, Fire and More

An HMO is a property occupied by three or more people from two or more households who share a kitchen or bathroom. At five or more people across two or more households, it needs a mandatory licence, and from that point the compliance list only grows.

The mandatory HMO licence

Five or more occupants from two or more households means a mandatory licence from the local authority, and many councils run Additional Licensing schemes that catch smaller HMOs too, so check locally. Apply before occupation, not after; licences usually last five years, and you must declare the maximum occupancy and layout, with the property meeting the council’s room-size and amenity standards. Record the licence number, issue and expiry dates, and any attached conditions.

Gas Safety, annual

Every gas appliance, pipe and flue must be checked yearly by a Gas Safe engineer, with a Landlord Gas Safety Record issued after each. Inspect within 12 months of the last check, serve a copy on existing tenants within 28 days and on new tenants before they move in, and keep records for two years. Check the certificate carries the inspection date, property address, engineer’s Gas Safe number, the appliances checked, and the expiry date.

EICR, every five years

A qualified electrician must produce an Electrical Installation Condition Report every five years, or at the start of a new tenancy if the last one is older than five years. Serve a copy on tenants within 28 days, complete any required remedial work within 28 days (or the shorter period the report specifies), and get written confirmation the work is done. A Satisfactory result needs no action; an Unsatisfactory one must be remedied before occupation or within 28 days.

EPC, minimum E rating

You need an EPC before marketing, and the property must be rated E or above; F and G properties cannot legally be let under the Minimum Energy Efficiency Standards. For HMOs, each self-contained unit may need its own EPC, while a shared non-self-contained HMO typically needs one for the whole property. Tighter standards are expected, with a C rating potentially required by 2028, though private-sector timelines remain under consultation.

Fire safety, HMO-specific

HMOs carry extra duties under the Housing Act 2004 and the Fire Safety Order:

• Fire risk assessment for any HMO of three or more storeys or five or more occupants
• Interlinked smoke alarms in every room and hallway
• Carbon monoxide detectors in any room with a solid-fuel or gas appliance
• Fire doors between high-risk areas such as the kitchen and escape routes
• Emergency lighting in some larger HMOs
• Fire blankets and extinguishers in kitchens

The exact standard depends on size, layout and storey count, and your council’s licensing conditions will set it out.

HHSRS hazards

Councils assess properties against 29 hazard categories under the Housing Health and Safety Rating System, from damp and mould to excess cold and carbon monoxide. You do not have to run an assessment yourself, but you must address hazards once identified, whether by an inspector, a tenant complaint, or your own survey. Retaliatory eviction after a disrepair complaint is a statutory defence for the tenant.

Deposit protection

For room-by-room lets, each tenancy usually carries its own deposit. Every one must be protected in an approved scheme within 30 days, capped at five weeks’ rent (six weeks where annual rent is £50,000 or more), with prescribed information served within 30 days.