Camden HMO Licence: Purpose-Built Flats Exemption and Who Still Needs One

The National Exemption

Under the Licensing of Houses in Multiple Occupation (Prescribed Description) (England) Order 2018, a purpose-built flat in a block containing three or more self-contained flats is exempt from mandatory HMO licensing — even if five or more people from two or more households share it. This is a national exemption that applies across England, not a Camden-specific rule.

The logic is straightforward: purpose-built blocks typically have fire separation, proper escape routes, and structural standards built into the original design. The risks that mandatory licensing addresses — inadequate fire safety, poor conversion standards — are generally lower in these buildings.

Why the Exemption Barely Matters in Camden

Here is where many landlords get caught out. The purpose-built flat exemption only applies to mandatory HMO licensing under Part 2 of the Housing Act 2004. It does not apply to Camden's borough-wide Additional HMO Licensing Scheme (2025 designation, in force from 8 December 2025 to 8 December 2030).

Camden's additional scheme catches properties occupied by three or more persons forming two or more households — regardless of building type. A purpose-built flat in a modern block with three flatmates from different households still needs a licence under the additional scheme, even though it is exempt from the mandatory national scheme.

In practice, the exemption saves you from one licensing route only to require you to licence through another. The application process, fees, and conditions are identical.

Shared Houses and Flatshares

The same principle applies to any shared house or flatshare in Camden. Whether it is a Victorian conversion, a 1960s council-built block, or a new-build apartment, the question is always: how many people live there, and how many separate households do they form?

• Three or more people from two or more households — additional HMO licence required under Camden's 2025 scheme
• Five or more people from two or more households — mandatory HMO licence required (unless the purpose-built flat exemption applies, in which case you fall back to the additional scheme)
• Three people across two households — this meets Camden's additional licensing threshold, unless a statutory exemption applies. A separate exemption applies to resident landlords sharing with no more than two lodgers.

The occupancy test looks at the reality of who lives there, not what the tenancy agreement says. Three friends on a joint tenancy form three separate single-person households because they are not related by blood, marriage, civil partnership, or cohabitation as a couple.

Student Houses

Student accommodation follows the same rules with one narrow exception. Buildings managed or controlled by a university or educational institution under an approved Code of Practice (section 233 of the Housing Act 2004) are exempt from HMO licensing entirely.

Private student houses — properties let by a private landlord to students, even if near a university campus — are not exempt. A four-bedroom house near UCL let to four students from different families is a licensable additional HMO in Camden, and the landlord needs a licence.

Commercial purpose-built student accommodation (PBSA) operated by private companies without direct university management also falls under licensing. The exemption is narrow: only accommodation where the educational institution itself manages or controls the building qualifies.

What to Check

If you own a flat in a purpose-built block and let it to sharers, do not assume the purpose-built exemption covers you. Check:

1. How many occupants are there, and how many separate households do they form?
2. If three or more people from two or more households: you need a licence under Camden's additional scheme regardless of the building type.
3. If the property is student accommodation: is it managed by the university itself under an approved Code? If not, it needs a licence.

The Camden Landlord Licensing Guide includes a decision flowchart for working out which licence your property needs — mandatory, additional, or whether one of the narrow statutory exemptions actually applies in your case.

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