HMO Management Regulations: The Duties That Apply to Every HMO in England

The Management of Houses in Multiple Occupation (England) Regulations 2006 apply to every HMO in England, whether or not it needs a licence. They require the manager to keep fire escapes clear, maintain fire alarms, repair common parts and rooms, and provide waste facilities. Breach is an offence under section 234 of the Housing Act 2004, with a civil penalty of up to £40,000 for conduct on or after 1 May 2026.

This article is for general information purposes only and does not constitute legal advice. Landlords should seek independent legal advice for their specific circumstances. It describes the position in England.

Do the HMO management regulations apply to my property?

They apply if the property is an HMO, and licensing has nothing to do with it. Regulation 1(2) applies the regulations to "any HMO in England" other than a converted block of flats to which section 257 of the Housing Act 2004 applies. A three person shared house that falls below the mandatory licensing threshold is still covered.

HMO, meaning a house in multiple occupation as defined in sections 254 to 259 of the Housing Act 2004, broadly covers a property let to three or more people forming two or more households who share a basic amenity such as a kitchen, bathroom or toilet.

The duties fall on the manager, meaning the person managing the HMO. In most cases that is the landlord, or a letting agent who manages on the landlord's behalf. Where an agent manages, the landlord is advised to check what the agency agreement says about who carries out each duty.

This is a different question from whether you need a licence or planning permission. Those are covered in our guides to the licensing threshold and to Article 4 directions. The management regulations are the day to day standard that applies once people are living there.

What do the HMO management regulations require?

The regulations set out duties in regulations 3 to 9 for the manager, and in regulation 10 for occupiers. Each is short, but together they cover most of what a council officer checks on an HMO inspection.

Three details are often missed. First, under regulation 4(3) the manager must display notices showing the location of the means of escape from fire, but regulation 4(6) disapplies this where the HMO has four or fewer occupiers. Second, regulation 4 also requires an unsafe roof or balcony to be made safe or access to it prevented, and safeguards where a window sill is at or near floor level. Third, regulation 7(4) extends the repair duty outside the building, to shared outbuildings, yards, gardens, boundary walls, fences and railings.

What about electrical safety in an HMO?

The electrical inspection duty now sits in the Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020, not in the management regulations. Regulation 6(3) of the 2006 regulations, which used to require a five yearly inspection, was omitted by those 2020 regulations.

In practice, the 2020 regulations require the electrical installation to be inspected and tested at intervals of no more than five years, with the report supplied to tenants and, on request, to the council. Our EICR guide covers the codes, the 28 day remedial deadline and who receives a copy. For a licensed HMO, paragraph 1(3) of Schedule 4 to the Housing Act 2004 adds a licence condition requiring the electrical installation to be in proper working order and safe for continued use, with a declaration on demand.

What do the occupiers have to do?

Regulation 10 places duties on the occupiers themselves. Every occupier must not hinder the manager, must allow access to their room at reasonable times for the manager's duties, must provide information the manager reasonably needs, must take reasonable care not to damage anything the manager has to maintain, must store and dispose of rubbish in line with the manager's arrangements, and must comply with the manager's reasonable instructions on fire escape, fire prevention and fire equipment.

These duties matter when a breach is caused by an occupier, such as a bicycle stored on an escape route. The manager's position is generally stronger where the instruction to keep the route clear was given in writing and the manager's checks are recorded. Regulation 8(3) also relieves the manager of repairs needed because an occupier has not used the accommodation in a tenant-like manner.

What extra conditions apply to a licensed HMO?

A licensed HMO must meet the management regulations and, on top of them, the mandatory licence conditions in Schedule 4 to the Housing Act 2004 plus any conditions the council adds. The mandatory conditions are:

The room size conditions were added by the Licensing of Houses in Multiple Occupation (Mandatory Conditions of Licences) (England) Regulations 2018 from 1 October 2018. Floor area under a ceiling height of 1.5 metres does not count towards the minimum.

Are there minimum amenity standards for kitchens and bathrooms?

Yes, for licensed HMOs, but the national standard is framed as adequacy rather than fixed ratios. Schedule 3 to the Licensing and Management of Houses in Multiple Occupation and Other Houses (Miscellaneous Provisions) (England) Regulations 2006 requires adequate space heating in each unit, an adequate number of bathrooms, toilets and wash basins for the number sharing, shared kitchens suitably located and equipped for the number of users, and appropriate fire precaution facilities and equipment.

Since a 2007 amendment, the national text does not set a number of people per bathroom. Many councils publish local amenity standards that put numbers on what "adequate" means for their area, and they apply those when deciding the maximum occupancy on a licence. Landlords are advised to read their council's published standards before buying or converting a property, since they decide how many people the licence will allow.

On fire precautions, many councils assess HMOs against the LACORS Housing Fire Safety guidance. Some council guidance also states that the Regulatory Reform (Fire Safety) Order 2005 applies to the common parts of bedsit type HMOs but not to shared houses let to a single group, so the position for a particular property is worth confirming with the council or fire authority.

What happens if a landlord breaches the HMO management regulations?

Failing to comply with the regulations is a criminal offence under section 234(3) of the Housing Act 2004. Section 234(4) provides a defence where the person had a reasonable excuse. On summary conviction the penalty is a fine not exceeding level 5 on the standard scale, which for offences committed since 12 March 2015 is an unlimited fine.

Instead of prosecuting, the council may impose a civil penalty under section 249A, which lists section 234 as a relevant housing offence. The maximum is £40,000, substituted for £30,000 from 1 May 2026 by the Financial Penalties (Housing Offences and Breach of Banning Orders) Regulations 2026 (SI 2026/319). Under regulation 4 of those regulations, the £30,000 cap still applies to conduct that took place before 1 May 2026. The council decides the amount within that limit by reference to its own published policy and the circumstances. Our civil penalties table sets the figure alongside the penalties introduced by the Renters' Rights Act.

The rent repayment order position reflects the section 40 table as it stands in October 2026, and the table has been amended several times. A breach of the management regulations can also feed into whether a licence holder is treated as a fit and proper person, and a council can take hazard enforcement under Part 1 of the Housing Act 2004 for the same defects.

A short HMO management checklist

1. Display the manager's name, address and telephone number in a prominent place, and give them to each household.
2. Walk the escape route on each visit, clear any obstruction, and record that you did.
3. Have the fire alarm system and any emergency lighting serviced, and keep the servicing records.
4. Display escape route notices if the HMO has more than four occupiers.
5. Keep the latest gas safety certificate ready to send to the council within 7 days of a written request.
6. Diarise the next electrical inspection, no more than five years after the last.
7. Clean each room before a new occupier moves in, and keep dated photographs.
8. Check common parts, handrails, stair coverings, lighting, gardens and boundary walls, and log repairs.
9. Provide enough bins for every household and explain the collection days in writing.
10. If licensed, diarise the annual gas certificate for the council and check the licence for any added conditions.

Our certificate calendar sets out the renewal cycles for gas, electrical and alarm checks. If you are unsure whether your area also runs an additional or selective scheme, see how to check if your area has a licensing scheme.

Keeping HMO records in one place

Most of these duties are proved by documents rather than by the state of the house on the day of an inspection. The LLCR platform is designed to hold them: compliance tracking with expiry alerts for gas, electrical and alarm servicing, a document vault for licences and certificates, and an issues and hazards log that dates each repair from report to completion. LLCR is free for one property.

LLCR Academy is also building The Complete Landlord Course, which is listed as coming soon in the LLCR Academy catalogue.

Not sure whether your HMO paperwork would satisfy a council request? The free LLCR compliance checker takes a few minutes and shows what is missing.