The HMO Management Regulations and What They Are - A Guide for Landlords
Updated October 2026
All landlords who own, or who are planning to own, a house in multiple occupation (HMO) are affected by the HMO Management Regulations. This guide sets out what the regulations are, what they require, and how the enforcement framework has evolved under the Renters' Rights Act 2025.
What are the HMO Management Regulations?
The HMO Management Regulations set out the legal duties of someone acting as the manager of an HMO. The manager may be the landlord themselves, or another person such as a letting or managing agent.
The regulations sit under the Housing Act 2004, the same Act that introduced mandatory licensing of larger HMOs. They are statutory instruments, a form of secondary legislation used to bring the detailed provisions of an Act into force.
There are two sets of regulations in effect in England:
Wales operates similar HMO Management Regulations. Scotland and Northern Ireland have separate regulatory regimes.
What do the HMO Management Regulations apply to?
The HMO Management Regulations apply to every property that meets the definition of an HMO. This includes larger HMOs subject to mandatory HMO licensing and smaller HMOs that may or may not require an additional licence, depending on the local authority area. They apply regardless of whether the HMO is licensed or unlicensed.
The 2006 and 2007 regulations: the differences
The key difference between the two sets of regulations is scope. The 2006 regulations applied to all HMOs but not to HMOs in converted blocks of flats where those flats did not comply with appropriate building standards.
The 2007 Additional Provisions regulations extended the regime to HMOs in converted blocks of flats, with some minor differences. These are known as Section 257 HMOs. In practical terms, if the HMO is a converted block of flats failing the 1991 Building Regulations standard with fewer than two-thirds of the flats owner-occupied, the 2007 regulations will apply.
The duties of an HMO manager under the regulations
Regulation 3: Duty to provide information to occupiers
The manager must provide their name, address, and contact telephone number to every resident of the HMO. This information must also be displayed prominently in the property. The purpose is to make sure that tenants always know who is responsible and how to contact them.
Regulation 4: Duty to take safety measures
This regulation covers fire safety and physical safety. The manager must ensure that fire escapes are kept clear, in good working order, and properly signed, and that fire alarms and firefighting equipment are maintained. The manager must also take reasonable measures to protect occupants from injury, with specific reference to the safety of roofs, balconies, and certain windows.
Regulation 5: Duty to maintain water supply and drainage
The manager must ensure that water supply and drainage systems are maintained in good working order at all times. This includes pipes, taps, fittings, baths, and WCs. Responsibility does not extend to matters where the utility supplier has its own statutory responsibilities.
Regulation 6: Duty to supply and maintain gas and electricity
The manager must ensure that gas and electricity supplies are not interrupted and that current safety certificates are held and available. The current Gas Safety Certificate (CP12) and Electrical Installation Condition Report (EICR) must be provided to the local authority within 7 days of a request.
Regulation 7: Duty to maintain common parts, fixtures, fittings, and appliances
This is a wide-ranging duty. The manager must ensure that all internal common parts of the HMO, fixtures, and fittings are kept in good and clean decorative repair and in safe and working condition. Common areas must not be obstructed. The regulation specifically applies to handrails and banisters, stair coverings, windows, light fittings, and landlord-provided fixtures and fittings in communal areas.
External communal areas such as gardens and yards, including fences, must also be kept in good, clean condition.
Regulation 8: Duty to maintain living accommodation
This regulation covers the condition of individual letting rooms and the fixtures and fittings provided in them. These must be well maintained and clean. The manager is not responsible for a tenant's own belongings or for damage caused by tenant misuse.
Regulation 9: Duty to provide waste disposal facilities
Managers must ensure that sufficient rubbish bins are provided and that rubbish is properly disposed of in accordance with local authority arrangements.
Regulation 10: Duties of occupiers
The regulations also place duties on occupiers themselves. Occupiers must not obstruct the manager in the performance of their duties, must allow the manager to enter the property at any reasonable time, must provide any reasonable information the manager requires, must take reasonable care not to damage anything the manager is responsible for, must dispose of litter correctly, and must comply with the manager's instructions on fire safety.
Standard of repair expected
The standard of maintenance or repair that is reasonable in the circumstances may take account of the age, character, and prospective lifespan of the property, together with the locality in which it is situated. In practice this means the standards expected in a newer property may be higher than in an older one, but all HMOs are expected to meet a reasonable baseline.
Enforcement of the HMO Management Regulations
It is a criminal offence for an HMO manager not to comply with the HMO Management Regulations. Local authorities are responsible for enforcement and may inspect an HMO as part of their own inspection regime, in connection with a licence application, or following a complaint from a tenant.
Inspections commonly include an assessment under the Housing Health and Safety Rating System (HHSRS). The HHSRS framework was substantially reformed from 23 June 2026, with the previous list of 29 hazards consolidated to 21 and the introduction of baseline indicators within each hazard profile. Local authorities retain a mandatory statutory duty to take enforcement action where a Category 1 hazard is identified. We cover the current HHSRS framework in more detail in our dedicated guide, HHSRS Reform 2026: What's Changed.
Where a breach is identified, enforcement options available to the local authority include:
Informal advice or a formal advisory letter.
A hazard awareness notice.
An improvement notice.
A prohibition order.
Revocation of the HMO licence (where one is held).
Prosecution under the Housing Act 2004, with an unlimited fine on conviction.
A civil penalty of up to £40,000 as an alternative to prosecution.
A new civil penalty of up to £7,000 under section 6A of the Housing Act 2004 for Category 1 hazards identified during a local authority inspection (in force from June 2026).
A Rent Repayment Order for up to 24 months' rent, applied for by the tenant or the local authority at the First-tier Tribunal.
Application for a banning order against the landlord or manager following a conviction.
The civil penalty ceiling was uprated from £30,000 to £40,000 by the Renters' Rights Act 2025, and the Rent Repayment Order window was extended from 12 to 24 months by the same Act. These changes substantially increase the exposure for landlords who breach the regulations.
A landlord receiving two or more civil penalties within 12 months, or convicted of certain offences and banned, can be entered onto the government's Rogue Landlord Database.
Local authorities will generally also have other standards they impose on HMOs through their own amenity standards, and can attach specific conditions to a licence. Enforcement action may therefore extend beyond a simple breach of these regulations.
Relationship with the Private Rented Sector Database
The national Private Rented Sector Database begins its phased regional rollout from 15 December 2026 in the West Midlands, with a registration fee of £65 per property. Other regions will follow through 2027. Registration will be a legal requirement before letting a property in a designated area. The PRS Database does not replace the HMO Management Regulations or HMO licensing. Landlords operating HMOs in designated areas will need to be licensed where required, registered on the PRS Database, and continuing to comply with the Management Regulations in parallel.
Some final thoughts
Compliance with the HMO Management Regulations is the ultimate legal responsibility of the HMO manager. For a licensed HMO, this person will be identified in the property's HMO licence. The manager may or may not be the same person as the owner, landlord, licence holder, or person having control.
Everyone connected with the ownership or running of an HMO should know who the nominated manager is and should be confident that this person understands their legal duties and has the knowledge and skills to comply with them.
HMO managers should be proactive. They should not wait for a tenant complaint or a local authority inspection to reveal that they are in breach of their duties, particularly given the materially increased civil penalty and Rent Repayment Order exposure under the Renters' Rights Act 2025.
In practice, the duties imposed by these regulations are not excessively onerous for a competent operator. The challenge is less about doing the right thing and more about being able to demonstrate compliance when challenged. Good record-keeping is essential.
How Surrey Property Licensing can help
The regulatory environment around HMOs has become significantly more complex and the consequences of non-compliance have become more serious. We work with landlords, agents, solicitors, and enforcement teams across London, the South East, and nationally. Our services include:
HMO licence applications under mandatory and additional licensing schemes.
Property health checks to confirm Management Regulations compliance before a local authority inspection.
HHSRS assessments and reports, including as a check against proposed enforcement.
Fire Risk Assessments carried out by qualified assessors.
Representations against enforcement action, including civil penalty representations.
First-tier Tribunal appeals including Rent Repayment Order defences and licence condition disputes.
Expert witness work in disrepair, licensing, and civil penalty cases.
If you are unclear about your responsibilities as an HMO manager, or want to be confident your property meets the required standards before a local authority inspection, please get in touch for a free initial consultation.
