Greenwich Council Considers Changes to HMO Licensing Process and Policy

Greenwich Council is considering changes to its licensing process for Homes in Multiple Occupation (HMOs) after a council meeting on Wednesday, 29 October 2025, prompted by a rise in HMO applications and concerns about the effectiveness of the current Additional Licensing Scheme.

The council aims to address both the increasing number of applications and the worries of residents. The council also seeks to establish legal clarity on member involvement, resident engagement, and the process for handling objections to HMO license determinations, operating within the framework of the Housing Act 2004¹.

Councillor Roger Tester, Councillor Charlie Davis, and Councillor Pat Greenwell initially put forward a motion to modify the process for granting HMO licenses. Their proposal included notifying members of new applications, allowing ward members to call in applications for consideration by a sub-committee of the Licensing Committee, and giving residents the opportunity to make submissions.

An amendment to the motion was proposed by Councillor Rachel Taggart-Ryan, Cabinet Member Community Safety and Enforcement, and Councillor Majid Rahman, Cabinet Member Planning, Estate Renewal and Development. The amendment acknowledged the Additional Licensing Scheme and the fines issued to landlords who have not licensed their properties, noting that £1,083,500 worth of fines have been issued to HMO landlords that have not licensed their properties. It also noted that all applications to convert a family home into an HMO must apply for planning approval under Article 4.

The amendment proposed ensuring that the emerging new Local Plan includes a policy specific to HMOs, introducing new policy to deal with areas with over concentrations of HMOs, establishing legal clarity on member involvement in HMO license determinations, holding a public awareness campaign, and investing in new technologies to expand the capacity and enforcement capability of the HMO Compliance Team. The aim of investing in new technologies is to ensure that all landlords who are required to be licenced are brought within the schemes and increase the number of enforcement actions taken against rogue landlords who fail to comply or keep their property in an unsuitable condition. This increased capacity will help allow the enforcement team to not only pursue and clamp down on rogue landlords who do not meet expected standards but also allow free up capacity to allow the Council to be more responsive to resident and tenant complaints.

The council ultimately resolved to:

• Ensure that the emerging new Local plan will include a policy specific to HMOs and that this will seek to manage the loss of family housing, preventing 3 bed family homes to conversions for HMO.
• Introduce new policy in the emerging Local Plan to deal with areas that are considered to exhibit over concentrations of HMOs, with a focus on wards which are considered to have an over concentration.
• Establish legal clarity on the possible extent of Member’s involvement, resident engagement, written submissions of support or objection, or ‘call in’ in the determinations of HMO licences within the legislative framework set out by the Housing Act 2004. As well as establishing the legal criteria for such provision to avoid the council being taken to court by applicants.
• Hold a public facing campaign across the borough to increase awareness, both for landlords and tenants, of the Mandatory, Additional, and Selective Licensing Schemes.
• Invest in new and emerging technologies that will allow the Council to expand the capacity and enforcement capability of its HMO Compliance Team.

During the meeting, Councillor Roger Tester asked Councillor Rachel Taggart-Ryan a series of questions regarding HMO licensing:

• How many properties, or their owners, have been reported to the Council for operating as a HMO without a licence or without the correct licence in the last 12 months? Councillor Taggart-Ryan responded that 167 properties have been reported to the Council for operating as an HMO without a licence or without the correct licence in the last 12 months.
• How many individual properties in Royal Borough of Greenwich which have been identified as unlicensed HMOs following investigation have since applied and been granted an HMO licence? Councillor Taggart-Ryan responded that in the last 12 months, 8 properties that were identified as unlicensed HMOs have subsequently applied for and been granted an HMO licence, with the average time taken for this process being approximately 12 weeks.
• How many applications for HMO licences have been refused and approved in the last 12 months? Councillor Taggart-Ryan responded that over the past 12 months, the Council has not formally refused any HMO licence applications in accordance with the legislation, however, around 184 applications were closed for various reasons, most commonly because applicants failed to provide the necessary information or complete the process. The majority of these applicants subsequently reapplied and were successfully licensed. During the same period, 418 HMO licences were approved.
• How many fines have been issued in the last 12 months to landlords who have failed to licence HMOs? Councillor Taggart-Ryan responded that in the last 12 months, the Council has issued 16 fines to landlords for failing to licence a licensable property. In addition, 84 Civil Penalty Notices have been issued as an alternative means of enforcement across both Selective and Additional Licensing schemes. The council's enforcement policy allows for fines up to £30,000 for this offense.
• How many HMOs have been found to be in breach of the conditions of licences? Councillor Taggart-Ryan responded that due to a recent change in our licensing software we are unable to provide an accurate figure for the number of HMOs found to be in breach of licence conditions or the number of sanctions issued. Since January 2025, we have inspected 78 licensed HMOs. Of these, 33 were found to be non-compliant with one or more licence conditions. We have issued 5 financial penalties under the HMO Management Regulations 2006– 2007.