[Landlord UK] The HMO licensing overlap problem — one property needing mandatory, additional and selective licences at the same time

Something that comes up less than it should when people are evaluating HMO investments.

Mandatory licensing applies nationally to five or more occupants from two or more households — no council discretion, no opt-out. But additional licensing schemes for smaller HMOs of three or four people operate council by council, and selective licensing schemes requiring licences for all rental properties in designated areas add another layer on top.

A single property can sit in an additional licensing area and a selective licensing area simultaneously. The fees stack and the conditions of each have to be met separately. In some London boroughs this means a landlord needs two licences for one property before a tenant has even moved in.

The fine for getting it wrong increased to £40,000 per offence on 1 May 2026. Tenants can also claim back up to 12 months rent via a Rent Repayment Order on top of that. And since Section 21 went, an unlicensed HMO blocks Section 8 possession in the same way that deposit non-compliance does.

How are people with portfolios across multiple council areas managing the licensing patchwork? Spreadsheet, software, something else?