London councils have now levied almost £25 million in fines against landlords and letting agents, with licensing offences alone accounting for £14.85 million — more than half the total. That figure covers 4,229 cases involving 2,010 landlords and 1,226 properties.
That is not a niche enforcement statistic. That is the single biggest landlord fine category in England, and the gap between licensing and every other enforcement category is widening every quarter.
This edition covers the complete licensing picture — all three schemes, what changed in December 2024 that opened the door to schemes in areas previously protected, what the Renters' Rights Act has done to the penalty structure, and why the landlords outside London who assume licensing doesn't apply to them are increasingly wrong.
The number that defines the 2026 licensing landscape
In 2017, there were just two discretionary licensing schemes operating in the UK. By 2025, that number had reached 149. With 13 schemes already scheduled or live in 2026, the count now stands at 162, and further launches are expected before year-end.
That growth — from 2 to 162 in nine years — is the story of landlord licensing in England. And the pace is accelerating.
There were 49 new selective and additional licensing schemes across the country in 2025, with 16 more already planned for 2026. The councils that have moved fastest are now seeing the fee income roll in and enforcement teams built out. Every landlord with property in England should assume a scheme will reach their area within the next three years and plan accordingly. Goodlord
The December 2024 change that opened the floodgates
Before December 2024, any selective licensing scheme proposed to cover more than 20% of a council's geographical area or more than 20% of the private rented stock required approval by the Secretary of State for Housing. That approval process could take twelve to eighteen months and was frequently refused or significantly amended.
That requirement was removed in December 2024.
From December 2024, councils can introduce selective licensing schemes of any size without central government approval. The only requirements are consultation with the local community and — in mayoral areas — notification of the mayor.
The practical effect has been immediate. Councils that had schemes in planning but stuck in the Secretary of State approval queue have been able to proceed. Councils that had avoided proposing larger schemes due to the approval risk are now consulting on borough-wide coverage. Barking and Dagenham and Bexley have already introduced schemes under the relaxed framework. Simply Business
Leeds is the most relevant example for this newsletter's readers. The selective licensing scheme in Leeds came into force on 9 February 2026. Landlords must apply for a license within 14 days of purchasing a property in the designated areas. The scheme covers significant portions of the city, and failure to comply can result in prosecution with an unlimited fine or a civil penalty of up to £30,000. Smart Sleep Property
The three schemes — what each one covers
Mandatory HMO licensing — national, no council discretion
Mandatory HMO licensing applies nationally to any property occupied by five or more people forming two or more separate households who share basic amenities such as a kitchen or bathroom. Since October 2018, there is no minimum storey requirement. A bungalow shared by five unrelated adults requires a mandatory license in the same way a three-storey house does. Rentalsandsales
This is the only national scheme. Every other licensing obligation depends on which council area the property sits in.
Additional HMO licensing — council by council, smaller HMOs
Additional licensing is a discretionary scheme that councils can introduce to cover smaller HMOs, typically those with three or four occupants, beyond the mandatory threshold. Rentalsandsales
Councils can introduce new additional licensing schemes at any time, subject to consultation. Check the council's website under 'HMO licensing' or 'private rented sector licensing' — the scheme boundaries and active dates will be published. Augustapp
Selective licensing — all private rentals in designated areas
Selective licensing covers all private rented properties in a designated area, regardless of whether they are HMOs. A single-occupancy buy-to-let in a selective zone needs a license in the same way a three-bedroom shared house does. Rentalsandsales
This is the scheme that catches the most landlords off guard. A standard single-let family home in a selective licensing area needs a license. The tenant number is irrelevant. The property type is irrelevant. If the postcode is in the designated area — a license is required.
The penalty structure — what changed on 1 May 2026
Two changes to the penalty structure came in with the Renters' Rights Act on 1 May 2026.
Change 1 — Maximum civil penalty increased to £40,000
Operating an HMO without a license can result in a civil penalty of up to £40,000. The Renters' Rights Act 2025 raised the maximum from £30,000 to £40,000 from 1 May 2026. Rentalsandsales
Change 2 — Rent Repayment Order extended to 24 months
This is the change that most landlords haven't heard about and that fundamentally changes the financial risk calculation.
Under the previous framework, a tenant could apply to the First-tier Tribunal for a Rent Repayment Order covering up to 12 months of rent paid during an unlicensed period. From 1 May 2026, Rent Repayment Orders will extend from 12 to 24 months. This potentially doubles the financial penalty for operating without a license. Smart Sleep Property
A landlord with a five-bedroom HMO charging £700 per room operates with a monthly rent roll of £3,500. An unlicensed period of two years generates a potential Rent Repayment Order of £84,000 — in addition to any civil penalty.
Change 3 — Superior landlords now jointly liable
The new amendments will make superior landlords jointly liable for licensing failures by management companies, including fines and rent repayment orders. Smart Sleep Property
Portfolio landlords who use management companies to operate their properties can no longer rely on the management company as a shield against licensing liability. If the management company fails to obtain the required license — the superior landlord is jointly exposed.
The Section 8 connection — the same pattern again
Regular readers will recognize this. Deposit non-compliance blocks Section 8. Unlicensed HMOs block Section 8. PRS Database non-registration blocks Section 8.
Crucially, letting a property without the correct license can invalidate possession notices and expose landlords to significant fines or rent repayment orders, even where non-compliance is accidental. Smart Sleep Property
With Section 21 abolished on 1 May 2026, an unlicensed property blocks your only possession route. A landlord who discovers during a possession claim that their property required a licence they never obtained is not just facing a fine — they are facing the prospect of being unable to recover their property at all until the licence is obtained.
The PRS Database connection
The Government has confirmed that selective licensing should complement and align with the database. The database will make it significantly easier for councils to identify unlicensed properties, improving enforcement capabilities. Smart Sleep Property
The PRS Database launching in late 2026 will cross-reference against council tax records, selective licensing registers and HMO registers simultaneously. A property that should be licensed but isn't will be visible to the council without any tenant complaint being needed. The enforcement model changes from reactive to proactive — councils find unlicensed properties, rather than waiting to be told about them.
The banning order risk
A serious or repeated breach can land you on the national rogue landlord database. Banning orders prevent you from letting any property in England for at least 12 months. LandlordZONE
A banning order is the nuclear consequence. It prohibits a landlord from managing or letting residential property in England — not just in the area where the offence occurred. A portfolio landlord hit with a banning order effectively loses their business.
Banning orders are recorded on the national database that will merge into the PRS Database. Once on it — it is publicly accessible.
How to check your licensing position right now
Three questions for every property:
Question 1 — Does it meet the HMO definition?
Three or more people from two or more separate households sharing facilities. If yes, proceed to Question 2.
Question 2 — Does it meet the mandatory licensing threshold?
Five or more occupants from two or more separate households. If yes — mandatory license required nationwide. No council discretion.
Question 3 — What schemes does your council operate?
Search your council name plus "selective licensing" and "additional licensing." Check whether your postcode falls within any designated area. The MHCLG register of selective and additional licensing schemes is the national cross-reference — check it even if your council says they have no scheme, because schemes from neighboring authorities sometimes overlap boundaries.
New schemes live or launching in 2026
Leeds selective licensing scheme came into force on 9 February 2026 — covers significant portions of the city. Smart Sleep Property
Reading Borough Council is rolling out a borough-wide additional licensing scheme for HMOs from March 2026 and is also consulting on further selective licensing in additional wards. Smart Sleep Property
Wandsworth introduced a second selective licensing scheme from 1 April 2026 covering East Putney, Northcote and West Putney wards.
Barking and Dagenham and Bexley have introduced schemes under the relaxed December 2024 framework.
Multiple further consultations are underway across England — this list will be longer by the end of 2026.
Your landlord licensing checklist
✅ Check mandatory licensing — five or more occupants from two or more households. Required everywhere. No exceptions.
✅ Check your council's additional licensing schemes — smaller HMOs with three or four occupants may be licensable depending on your specific local authority.
✅ Check selective licensing in every area you operate — including areas you may have held properties in for years without realizing a scheme has been introduced or expanded.
✅ Check your license renewal dates — licenses from 2019-2021 are expiring now. Operating after expiry is treated identically to never having had a license.
✅ If you use a management company — check the license is held in the correct name and that you are satisfied it exists. You are now jointly liable for their licensing failures.
✅ Do not rely on retrospective applications to cure the breach — the unlicensed period remains an offence. Rent paid during it is potentially recoverable via Rent Repayment Order for up to 24 months.
✅ Factor the 24-month RRO risk into your risk assessment — the financial exposure from an unlicensed period has doubled since 1 May 2026. A two-year unlicensed period on a moderately priced HMO can generate a six-figure RRO.
✅ Check the PRS Database timeline — when registration opens for your area, your licensing status will be a required field. Getting licensed now means you'll be ready to register without scrambling.
The bottom line
The £25 million fine figure from London is not a London story. It is a preview of what England's licensing enforcement landscape looks like when councils have the tools, the data and the financial incentive to act. The December 2024 rule change removed the last significant barrier to councils introducing large-scale schemes. The PRS Database arriving in late 2026 removes the last enforcement barrier — the need for a complaint to trigger investigation.
Landlords who check their licensing position now — and fix any gaps before the database goes live — are in a fundamentally different position to those who wait.
The landlords who wait are the ones who will generate the 2027 version of that £25 million headline.
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Coming up next edition — Smoke and CO alarms: the rules, the checks and the fines.
The Landlords Brief is published for UK landlords. Subscribe free at thelandlordsbrief.co.uk. This newsletter is for general information only and does not constitute legal or financial advice.
