HMO Article 4 Directions in London: Which Boroughs Need Planning Permission for a Small HMO

What an HMO Article 4 direction removes

Planning counts the people in a house. A family home sits in Class C3. A small HMO, Class C4, is a dwellinghouse shared by not more than six residents as a house in multiple occupation. A house for seven or more is outside Class C4 and needs planning permission everywhere.

Class L of the General Permitted Development Order lets a house change between C3 and C4 with no application. That is the right an HMO Article 4 direction takes away. Article 4 lets a council withdraw a named permitted development right over a named area.

Two things stay the same. Licensing is a housing matter, not a planning one. GOV.UK says a mandatory licence applies to a large HMO rented to 5 or more people from more than one household. Some councils license smaller ones too.

National policy limits directions to cases that protect local amenity or wellbeing. It names an over-concentration of small HMOs as an example.

London boroughs with an HMO Article 4 direction

The table below lists only directions we verified on the council's own notice or page, or its row in the national register. All were checked on 2 November 2026. Boroughs not listed are not clear. Some we could not verify that day, and some have no HMO direction on their page. Always read the live map for the address.

Two more are on the way. Hammersmith and Fulham's Cabinet agreed on 9 February 2026 to make a non-immediate direction, with the area still to be set by an evidence study. Havering consulted until 16 October 2026 on a borough-wide direction that would take effect a year after it is made.

Hackney's Article 4 page lists no HMO direction. Enfield's pages would not load for us on the day, so Enfield is not in the table: ask the council. We did not check Camden, the City, Islington, Kensington and Chelsea, Kingston, Richmond, Wandsworth or Westminster.

The pattern matters for a buyer. Outer east and south London went first, from 2012. The west and north followed in 2024 to 2026, and the last gaps are closing. A house that was a permitted conversion in 2023 may not be one today.

Caught by a direction and the numbers still work? The route is change of use planning permission, priced with the conversion by the team that builds it.

How to check a specific address

No single map is complete. The national register on planning.data.gov.uk warns that its data may be incomplete. Use four checks, in this order.

1. The national dataset. Search the Article 4 direction area dataset on planning.data.gov.uk for the address. Treat it as the first look, not the answer.
2. The council's Article 4 page and map. Every borough in the table publishes a page, and most an interactive map. Note the date the direction took effect.
3. The direction document. It names the classes removed and shows the area on a plan. Read the schedule: some name Class L(b) only, Bromley names L(a) and L(b).
4. The consultation list. A non-immediate direction is advertised at least 21 days before confirmation and takes effect 28 days to 2 years later. An immediate one takes effect on notice and lapses after 6 months unless confirmed. Ask what is proposed.

Then look at the house itself. A direction does not undo a use that began lawfully before it. If the seller says the house was already an HMO, ask for tenancy agreements, council tax records and any licence. A certificate of lawfulness turns that history into a document a lender will accept.

What happens if you convert anyway

The council can serve an enforcement notice requiring the HMO use to stop. Ignoring a notice is a criminal offence. The court sets the fine with regard to any financial benefit you gained from the breach, so the rent counts against you.

A change of use becomes immune from enforcement only after ten years of continuous breach. For a house let room by room, that means ten years of evidence, through every void and every change of tenant. Few investors want to carry that risk, and a lender will not.

An HMO licence does not help here. The housing team can grant a licence for a house that has no planning permission, and the planning team can still enforce. The two regimes do not talk to each other on your behalf.

Compensation is narrow. It is payable only if the council later refuses permission for development that was otherwise permitted. The claim must be made within 12 months of the direction taking effect. Where the council gave at least 12 months' notice, the statute rules it out. That is why nearly every London direction is non-immediate.

The full application after Article 4: what the officer tests

Once a direction applies, the council judges a small HMO against its local plan. The tests differ by borough, but the same five come up in London. Check each against the house before you offer.

1. Amenity of neighbours. Noise, comings and goings, bin storage and the loss of a garden to bike sheds. A mid-terrace with a shared side return is harder than an end of terrace.
2. Concentration. Many boroughs cap the share of HMOs within a set radius or on a street. Count the HMOs around the house before you apply; the officer will.
3. Parking and cycles. Outer boroughs test car parking against the local standard. Inner boroughs expect secure cycle storage and often a car-free condition.
4. Room sizes and shared space. Councils publish HMO standards for bedrooms, kitchens and bathrooms. A box room that passes licensing may still fail planning.
5. Loss of family housing. Some boroughs protect family-sized homes. A four-bedroom house may face a harder test than a two-bedroom one.

The application is a full planning application, with a fee. Our guide to planning application fees covers it. If the house is better as flats, that is a different route, set out in converting a house into flats.

Before you buy: the HMO Article 4 check

Do the check before you exchange, not after. A direction changes the deal from a permitted conversion to a planning application with a refusal risk, and the price should follow.

Work through the list below with the agent and the seller. If a line is blank, ask again. If two lines are blank, send us the address. We check the Article 4 position, the planning history and the route within 48 hours. Then we price the application and the conversion as one job.