Compliance certificates for an HMO: the licence isn't enough
Compliance certificates for an HMO in England don't stop at the licence. A landlord who tracks the licence and assumes the rest is covered has covered exactly one duty out of six.
Last reviewed 19 August 2026 · England
Get an HMO licence approved and it feels like the big one is done. It took the most paperwork, the longest wait, and the most attention from the council of anything on the file. It doesn’t replace anything else. Every certificate that applies to an ordinary single let in England applies to an HMO too, and the licence sits alongside them, not above them.
This gap doesn’t show up because a landlord is careless. It shows up because the licence process is so involved that it reads like the whole job. Nowhere does it say, in the same place, that the standard six-certificate checklist still runs underneath it, on its own dates, whether or not the property is licensed.
What an HMO actually needs
Nothing on the standard list changes for a shared house. The certificate types are the same as any other rental in England. The licence is an addition, not a substitute, and it answers a different question: not whether the gas or the wiring is safe, but whether the property is suitable to be let as shared accommodation at all.
| Certificate | Applies to an HMO |
|---|---|
| Gas Safety (CP12) | Every rental with a gas appliance, HMO or not |
| EICR | Every rental property in England, HMO or not |
| EPC | Every rental property in England, HMO or not |
| Smoke and CO alarms | Every rental property in England, HMO or not |
| Legionella risk assessment | Every rental property in England, HMO or not |
| HMO licence | Only if the property meets a licensing trigger, national or local |
Why the licence doesn’t cover the rest
A council reviewing an HMO licence application will often ask to see the gas safety certificate and the EICR, because a property with unsafe wiring or gas isn’t one it wants to license. Asking to see a certificate is not the same as issuing it, and it is not the same as tracking its renewal afterwards. The licence gets granted, the certificates keep running on their own separate clocks, and nothing about the licence checks them again until the licence itself is up for renewal, which can be years later.
A gas safety certificate still needs renewing every twelve months. An EICR still runs on the five-year default, or the earlier date the report itself sets. None of that changes because a licence is sitting in date on the wall.
Whether the property needs a licence in the first place
Not every shared house is licensable, and not every licensable house looks like the classic HMO. Mandatory licensing kicks in at five or more tenants forming two or more households, but a council’s own additional or selective licensing scheme can reach much smaller properties, sometimes down to three tenants. Whether a given property needs one at all is a separate question from the certificate checklist, answered locally by the council it sits in, and covered in full here.
What to do now
- List the property’s certificates separately from its licence: gas, EICR, EPC, alarms and legionella each have their own date, and the licence has its own date too.
- Check each certificate against its own clock rather than the licence’s renewal date. A licence in date says nothing about whether the gas check is overdue.
- Keep all six against the same property. CertSorted tracks every certificate on its own clock and reminds you at 90, 60, 30 and 7 days before each one runs out, licence included.
This applies to rental properties in England. Scotland, Wales and Northern Ireland run separate HMO and certificate rules.