Camden HMO Fit and Proper Person Test: What Landlords Need to Know

Why Camden Runs the Test

Every HMO licence application in Camden — mandatory or additional scheme — requires the proposed licence holder and the named property manager to pass a fit and proper person assessment. It is a statutory requirement under sections 66 and 89 of the Housing Act 2004, not a Camden-specific policy. The council cannot grant a licence to someone who fails the test, regardless of how well the property itself meets physical standards.

The purpose is straightforward: Camden needs to be satisfied that the people controlling the property and managing tenants can be trusted to comply with licensing conditions, maintain safety standards, and manage the HMO responsibly.

What Camden Checks

The screening covers four main areas:

Unspent criminal convictions — specifically convictions involving fraud, dishonesty, violence, drugs, or sexual offences. These do not need to relate to property; a conviction for fraud in a completely unrelated context is relevant. Spent convictions under the Rehabilitation of Offenders Act 1974 are generally excluded.

Housing-related convictions and penalties — unspent convictions or civil penalties for housing law violations, including unlawful eviction, tenant harassment, failure to comply with improvement notices, or previous unlicensed HMO offences. A history of housing enforcement action is a strong negative signal.

Banning orders — under the Housing and Planning Act 2016, a person subject to a banning order cannot hold an HMO licence. Camden's enforcement policy says it must apply to revoke any HMO licence that person already holds.

Associated persons and entities — the council also examines whether the applicant is associated with any company, partnership, or individual that has been subject to licence revocations, enforcement action, or banning orders. A director of a company that previously had licences revoked would face scrutiny even when applying personally.

Who Needs to Pass

Both the proposed licence holder and the proposed property manager must pass. In many cases these are the same person — a self-managing landlord who owns and runs the property. Where a managing agent is appointed, that agent also undergoes the test.

If the property owner lives outside the UK, Camden requires the appointment of a UK-based managing agent. That agent must pass the fit and proper person test, and applications without a designated UK service address and UK-based manager are likely to be refused or granted for a shortened duration.

What Happens If You Fail

Camden can refuse the licence outright. A refusal does not just mean the property stays unlicensed — it means the property cannot lawfully be let as an HMO until either a different person who passes the test applies as licence holder, or the circumstances that caused the failure change (for instance, a conviction becomes spent).

If a licence has already been granted and new information emerges that the licence holder is no longer fit and proper — a new conviction, for instance — Camden can revoke the licence under section 70 of the Housing Act 2004.

Practical Steps to Prepare

The fit and proper person declaration is part of the online portal submission. Camden may undertake checks and request further information to assess the proposed licence holder and manager.

To avoid problems:

• Disclose everything the form asks for. Providing false or misleading information is an offence under section 238 of the Housing Act 2004, carrying an unlimited fine and potentially leading to refusal or revocation of the licence.
• If you have unspent convictions, get legal advice before applying. Some convictions are disqualifying; others require explanation.
• If you are appointing a managing agent, verify their compliance history before naming them on the application. Their failure becomes your problem.

The Camden Landlord Licensing Guide walks through the entire application sequence including the fit and proper declaration, the documents you upload alongside it, and what to do if the council asks follow-up questions during processing.

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