Royal Borough of Greenwich

On 1 October 2017, Greenwich Council introduced a borough wide additional licensing scheme.

On 1 October 2022, Greenwich Council are introducing a new selective licensing scheme.  

There is also the mandatory HMO licensing scheme that applies throughout England.

We will help you choose the right licence for your property.

1. Mandatory HMO licence

You will need a mandatory HMO licence if your property meets the standard test, self-contained flat test or converted building test HMO definition in section 254 of the Housing Act 2004 and is occupied by five or more people.

But what are these tests and what does this mean in practice? It means you need a licence for any house or flat that is occupied by five or more people who are not all related and live in the property as their main home. For example, it includes:

• Shared houses and flats occupied by students and young professionals;
• Properties converted into bedsits with some shared facilities; and
• Properties converted into a mixture of self-contained and non self-contained accommodation.  

Prior to 1 October 2018, the mandatory HMO licensing scheme only applied to properties that were three or more storeys in height, but that restriction has now been lifted.

The government have decided to exclude purpose built self-contained flats within a block comprising three or more self-contained flats from the mandatory HMO licensing scheme. While this will be good news for some landlords, it does make the licensing scheme far more complicated.

To find out more, you can read our free guide to mandatory HMO licensing (here).

2. Additional licence

The additional licensing scheme came into force on 1 October 2017 and continues for five years until 30 September 2022, unless the council decide to revoke the scheme early or implement a replacement scheme.

It extends licensing to all HMOs in the Royal Borough of Greenwich, so that includes all properties shared by three or more people who are not all related and share facilities. 

The council have included ‘section 257 HMOs: certain converted blocks of flats’ in the scheme. These are properties that:

• have been converted into self-contained flats; and
• less than two thirds of the flats are owner occupied; and
• the conversion did not comply with the relevant Building Regulations in force at that time and still does not comply.

This is a complex area of law and you may need further advice.

3. Selective licence

Greenwich Council have approved a new selective licensing scheme that will come into force on 1 October 2022 and continue for five years.

You will need a selective licence if your property (house or flat) is let out to a single household or two unrelated sharers and is in parts of Plumstead, Glyndon, Shooters Hill, Woolwich Common and Woolwich Riverside council wards. Once the additional licensing scheme has ended, some HMOs may also need licensing under this scheme. 

At present there is no online search facility to check whether your property will need a licence under this scheme. All we could find is a small scale map on page 4 of the draft scheme designation which you can download from the orange ‘More Information’ box on the right side of this webpage.

It depends on the type of licence you are applying for.

Mandatory HMO and additional licence

The standard application fee is £408 (was £400 in 2020/21, £388 in Sept 2019 and £377 in 2018/19) per habitable room in an HMO. This is a significant increase from the £147.11 per unit that was charged in 2017/18. The fee is now £2,040 for a shared house with five lettings. On this basis, it is one of the highest per-bedroom fees in London, beaten only by Lambeth and Lewisham Councils.

The council charge a reduced fee to landlords who are a member of a professional landlord association or accreditation scheme, which we think is a good idea.

Selective licence

The council intend to charge a fixed fee of £780 per property.

According to the Cabinet Report, the council will offer a 60% early bird discount, but have not said when the discount period will start.

The fees are correct as of April 2022 but could be subject to change in the future. You can view the HMO licensing fees on the council’s website. When we last checked, there was no link to the selective licensing fees.

There is an online application and payment system for mandatory HMO and additional licensing on the council’s website. The selective licence application process has not yet started.

If you need assistance with your licence application, you can find companies offering a licence application handling service in our Landlord Suppliers Directory (here). We also offer a licence application handling service and you can find further information here. Simply complete the online enquiry form to get the process underway.

It is important to remember that submitting a licence application is only the start of the licence approval process. To help landlords understand what happens next, we have published a free guide here.

Yes, Greenwich Council have published HMO Standards that apply to all licensed HMOs. They provide useful guidance that all HMO landlords need to be aware of. The standards were updated in April 2019 and you can download a copy by visiting the council’s website.

The standards cover a range of issues such as kitchen, bathroom and toilet facilities, fire precautions, heating, lighting, ventilation and room sizes.

It is important to note that new absolute minimum bedroom sizes for licensed HMOs have been introduced for HMO licence applications approved on or after 1 October 2018:

• 4.64m2 for a child under 10 years old
• 6.51m2 for one person over 10 years old
• 10.22m2 for two people over 10 years old

The council can still ask for larger minimum sizes. These new minimum sizes will apply throughout England to HMOs licensed under a mandatory HMO or additional licensing scheme.

As of December 2014, Greenwich Council had licensed 54 HMOs. By February 2016 the number had risen to 64, by September 2016 it had risen to 80 and by December 2017, it had risen again to 108.

In May 2019, the council told us there were 279 HMOs licensed under the mandatory HMO licensing scheme and 589 licensed under their additional licensing scheme.

In November 2020, there were 546 HMOs licensed under the mandatory HMO licensing scheme and 809 licensed under their additional licensing scheme.

In September 2021, there were 1245 licensed HMOs listed in the public register on the council’s website. It doesn’t break down the figure between the two HMO licensing schemes. This suggests the number of licensed HMOs may actually have reduced over the last 12 months.

The council keeps a public register of licensed HMOs that is regularly updated and can be viewed online. 

In May 2019, Greenwich Council told us they think about 2,250 properties need to be licensed under the mandatory HMO licensing scheme and a further 7,500 properties need to be licensed under the additional licensing scheme.

With only 1,245 properties licensed four years after the additional licensing scheme started, there are either far fewer HMOs than expected, or most are being operated illegally without a licence.

The council estimate that a further 4,400 properties will need licensing under the new selective licensing scheme.

Ignore the law and you could pay a heavy price. You risk being prosecuted by the council and if found guilty you could get a criminal record, be fined an unlimited amount and ordered to pay court costs and victim surcharge.

Alternatively, the council can issue you with a civil penalty notice of up to £30,000 for not having the correct licence without any warning being given, so this is really serious stuff.  

You could also be subject to a Rent Repayment Order and may have to repay up to 12 months rental income.

Whilst the property is unlicensed, you can’t use a Notice of Seeking Possession under Section 21 Housing Act 1988 to evict your tenants. 
  
And following a successful prosecution, you would probably fail a fit and proper person assessment, making it very difficult for you to obtain a property licence in the future.

Don’t put your livelihood and reputation at risk. Make sure you comply with the law.

Greenwich Council told us they took fifteen housing prosecutions over the five years from April 2011 to March 2016, so on average three prosecutions a year. 

Greenwich Council did not obtain any Rent Repayment Orders from the landlords of unlicensed HMOs over the six years from April 2011 to March 2017. This is based on data published by the Courts and Tribunals Judiciary. 

For all the latest information, you can search for housing prosecutions on the Mayor of London's 'Rogue landlord and agent checker', available here.  

There are landlord accreditation schemes operated by the London Landlord Accreditation Scheme, the National Landlords Association (NLA) and the Residential Landlords Association (RLA).  

Whilst we don’t have any figures for the NLA or RLA schemes, we have got information about the London Landlord Accreditation Scheme that is supported by all the London Boroughs. In January 2016, they told us there were 243 accredited landlords in Greenwich, which was the lowest number out of all London boroughs. 

January 2018: 655 accredited landlords
January 2019: 793 accredited landlords
January 2020: 841 accredited landlords and
January 2021: 902 accredited landlords

By January 2022 there were 1,144 accredited landlords which is slightly below average when compared to all the London boroughs. To find out more about becoming accredited, you can visit the London Landlord Accreditation Scheme website here.

In addition to training and development, accredited landlords are entitled to various benefits, including discounted licensing fees in some boroughs. If you are not already a member, we would encourage you to think about joining!

Yes, Greenwich Council started consulting on plans for a selective licensing scheme on 17 February 2020. The area under consideration included Woolwich Common, Glyndon, Woolwich Riverside, Shooters Hill and Plumstead wards. The consultation was due to run until 26 April 2020 but was paused due to the COVID-19 pandemic. The consultation restarted on 23 July 2020 and ended on 10 September 2020. You can find more information on the council’s website.

On 23 March 2022, Greenwich Council’s Cabinet meeting approved the new selective licensing scheme and decided it will come into force on 1 October 2022 (read here).

The council already operates an additional licensing scheme. From 29 November 2016 to 24 February 2017, the council consulted on proposals to extend licensing to all Houses in Multiple Occupation (HMOs) in the borough. On 19 April 2017, the council’s Cabinet meeting approved plans for a borough wide additional licensing scheme which came into force on 1 October 2017.

There is clearly a lot happening in Greenwich and so we will monitor the situation closely. For all the latest news, you can sign up to our free newsletter.

You will need planning permission if you are changing your property from a single-family property to a house in multiple occupation (HMO) occupied by more than six people. HMOs occupied by more than six people fall within ‘sui-generis’ use for which planning permission is required. You will also need planning permission if you a splitting up a property into smaller self-contained units of accommodation.

For small HMOs, the rules are a bit more complicated. HMOs occupied and shared by between three and six people fall into planning use class C4 whereas single-family properties fall into planning use class C3.

On 27 September 2017, the council made a non-immediate borough-wide HMO Article 4 Direction which was later confirmed.

From 27 September 2018, planning permission is required to change any property from a single-family home (use class C3) to an HMO with up to six occupants (use class C4). So even letting your property to three people who are not all related could require planning permission.

The changes are not retrospective and so properties converted into small HMOs (use class C4) before that date are not affected. More information is available on the council’s website. 

Remember that this is only intended as general advice and no liability can be accepted for any reliance upon information provided. We would strongly encourage you to contact the Council’s Planning Department or seek independent legal advice before you start a new HMO development.

We certainly can. We understand the challenges of being a private landlord and so we have developed a Landlord Suppliers Directory to provide you with access to the goods and services you need. The Directory concentrates on businesses that operate in the London area.

Whether you a looking for a letting agent, want a property inventory for a new tenancy or fire risk assessment, we have got it covered - and far more besides!

As the leading experts in property licensing, we also offer a range of services ourselves. From handling the licence application process to advice on new HMO developments, we can help to ensure your property business remains compliant. If you need assistance, please drop us a line and see if we can help! 

New suppliers are regularly being added and we would encourage you to take a look. Some of our featured listings also contain YouTube videos, helping you to find out more about the business. 

You can contact the council at: 

Residential Services Team
Royal Borough of Greenwich
4th Floor, Woolwich Centre
35 Wellington Street
London SE18 6HQ

Email: hmo-licensing@royalgreenwich.gov.uk 
Tel:   020 8921 8157
Website: www.royalgreenwich.gov.uk