The 5 Most Overlooked HMO Compliance Risks Landlords Are Facing Right Now

If you ask most HMO landlords what keeps them awake at night, they’ll usually mention fire safety, licensing, or anti-social behaviour.

Yet when local authority inspectors visit properties today, many enforcement actions are being triggered by issues landlords didn’t realise had become priorities.

The compliance landscape continues to evolve. Local authorities are under increasing pressure to improve housing standards, tenant protections are expanding, and the implementation of the Renters’ Rights Act is shifting enforcement attention towards property conditions, management standards, and tenant welfare.

The challenge isn’t always knowing the rules.

It’s knowing which rules inspectors are actively focusing on right now.

Here are five of the most commonly overlooked compliance issues we’re seeing across the HMO sector.

1. Fire Doors That Technically Exist, but Don’t Comply

Most landlords know they need fire doors.

What many don’t realise is that inspectors are increasingly focusing on whether those doors actually perform as intended.

A fire door is not compliant simply because it looks like a fire door.

Common inspection failures include:

• Missing or damaged intumescent strips
• Missing smoke seals
• Excessive gaps around door frames
• Defective self-closers
• Damaged hinges
• Doors that have been altered by tenants
• Non-compliant locks affecting escape routes

We’re seeing local authorities and fire services pay far greater attention to the condition and operation of fire doors rather than simply their presence.

A single defective door can result in licence breaches or improvement notices.

What to do now

Carry out a documented fire door inspection throughout the property.

Check:

• ✓ Self-closers fully shut the door
  ✓ Intumescent strips and smoke seals are intact
  ✓ Gaps around the frame are within tolerance
  ✓ Doors have not been damaged or modified
  ✓ Escape routes remain unobstructed

Remember: fire doors are one of the first things many inspectors check during an HMO inspection.

2. Overcrowding and Room Size Compliance

The days of simply counting bedrooms are long gone.

Inspectors are increasingly assessing how properties are actually occupied.

Particular attention is being paid to:

• Room sizes
• Occupancy levels
• Storage provision
• Work-from-home requirements
• Adequacy of communal facilities
• Household composition

Many landlords still assume that because a room was accepted years ago, it remains compliant today.

However, licensing teams are increasingly reviewing occupation patterns against modern standards and local licence conditions.

Following the Renters’ Rights Act reforms, housing authorities are expected to place greater emphasis on living standards and tenant wellbeing rather than purely minimum compliance.

What to do now

Review your:

• HMO licence conditions
• Permitted occupancy levels
• Bedroom measurements
• Kitchen and bathroom ratios
• Communal living space provision

If occupancy has gradually increased over time, now is the time to reassess whether the property still meets current expectations.

3. Electrical Safety Beyond the EICR

Most landlords know they need a valid Electrical Installation Condition Report (EICR).

What many overlook is that inspectors frequently identify electrical risks that sit outside the formal inspection report.

Examples include:

• Extension lead overuse
• Daisy-chained adaptors
• Damaged sockets
• Unsafe charging arrangements
• Tenant-owned appliances creating hazards
• Lack of residual current device (RCD) protection

A growing issue in HMOs is electric vehicle charging.

Across the sector, landlords are reporting tenants running extension leads through bedroom windows to charge vehicles from household supplies.

This creates:

• Fire risks
• Trip hazards
• Potential insurance concerns
• Electricity misuse issues

Increasingly, inspectors are taking a broader view of electrical safety management rather than simply checking whether an EICR exists.

What to do now

Alongside maintaining a valid EICR:

• ✓ Inspect communal electrical equipment regularly
  ✓ Implement an EV charging policy
  ✓ Check for damaged sockets and accessories
  ✓ Remove unsafe extension arrangements
  ✓ Consider PAT testing for landlord-provided appliances

A valid certificate is important—but active management is what inspectors increasingly expect to see.

4. Damp, Mould and Ventilation Management

Few areas have seen a bigger shift in enforcement priorities.

Following the introduction of Awaab’s Law and heightened national focus on housing conditions, damp and mould have become a major inspection priority.

Many landlords still view mould as a maintenance issue.

Inspectors increasingly view it as a management issue.

Authorities are asking:

• Was the issue reported?
• How quickly was it investigated?
• Was the cause identified?
• Was action documented?
• Were tenants kept informed?

This is particularly important in HMOs where:

• Occupancy density is higher
• Moisture generation is greater
• Ventilation systems experience heavier use

Inspectors increasingly expect landlords to demonstrate active management rather than reactive repairs.

What to do now

Review:

• Bathroom extraction performance
• Kitchen ventilation
• Window restrictor arrangements
• Heating provision
• Condensation-prone areas

Most importantly, keep records.

Document reports, inspections, actions and outcomes.

Good record-keeping can be just as important as the repair itself.

5. Documentation, Records and Audit Trails

This is perhaps the biggest hidden compliance risk facing landlords today.

Increasingly, enforcement officers are asking not just:
“Did you do it?”

But:

“Can you prove you did it?”

The Renters’ Rights Act is expected to increase expectations around transparency, record-keeping, and evidence of compliance.

Landlords who have completed the work but cannot demonstrate it are finding themselves exposed.

Areas frequently requested during inspections include:

• Fire alarm testing records
• Emergency lighting checks
• Gas safety certificates
• EICRs
• Property inspection reports
• Repair records
• Tenant communications
• Evidence of licence compliance
• Management arrangements

Without clear records, landlords may struggle to demonstrate compliance even when they have acted appropriately.

What to do now

Create a simple compliance file for every property.

Maintain:

• ✓ Inspection reports
  ✓ Safety certificates
  ✓ Maintenance records
  ✓ Contractor invoices
  ✓ Tenant correspondence
  ✓ Compliance testing logs

The most successful landlords today treat compliance as a documented process rather than a collection of certificates.

Final Thought

The reality is that most HMO enforcement action doesn’t stem from dramatic failures.

It comes from small issues that have been overlooked, undocumented, or allowed to drift over time.

A robust HMO compliance checklist, regular property reviews, and a clear understanding of evolving HMO licence requirements can significantly reduce risk and help ensure a smoother experience when an HMO inspection occurs.

With the Renters’ Rights Act reshaping expectations around housing standards and tenant protections, now is an excellent time to review your portfolio and identify any potential gaps before an inspector does.

If you’d like an informal conversation about your property’s compliance position, upcoming licence renewals, inspection preparation, or your specific Renters’ Rights Act landlord obligations, we’re always happy to help.

Sometimes a 30-minute discussion can prevent a much more expensive compliance problem later.

Article supplied by County Rooms – Specialist in HMO Property Management – to visit their website click here for HMO management for landlords and room find for tenants in the Home Counties.