Camden Penalty for Unlicensed HMO: Fines, Civil Penalties and Rent Repayment Orders

The penalties for operating an unlicensed HMO in Camden go well beyond a fine. Camden's enforcement team uses a combination of civil penalties, criminal prosecution, rent repayment orders and the rogue landlord database — and the financial exposure from multiple routes hitting at once can be devastating.

Civil Penalty Notices

Camden Council can impose civil penalty notices as an alternative to criminal prosecution under section 249A of the Housing Act 2004. The maximum penalties depend on the offence:

• Operating an unlicensed HMO (section 72(1)): up to £40,000
• Breaching licence conditions (section 72(3)): up to £40,000
• Failing to comply with HMO Management Regulations: up to £40,000 per offence
• Providing false or misleading information (section 238): unlimited fine on conviction

A civil penalty is a financial penalty imposed by the council, not a criminal conviction. But the amounts are severe — Camden sets the level based on the landlord's culpability, the harm caused, the financial benefit gained from non-compliance, and the landlord's compliance history.

Criminal Prosecution

If Camden chooses prosecution over a civil penalty (they can't do both for the same offence), conviction for operating an unlicensed HMO carries an unlimited fine. The council's enforcement policy reserves prosecution for the most persistent or egregious cases, but it remains on the table.

A housing-related criminal conviction also affects your fit and proper person status for any future licence applications — in Camden or any other borough.

Rent Repayment Orders

This is the financial risk that landlords most underestimate. For qualifying offences committed on or after 1 May 2026, tenants can apply to the First-tier Tribunal (Property Chamber) for a rent repayment order covering up to 24 months of rent paid during the period you were operating without a licence.

The application uses Form RRO1 and costs the tenant £114 (plus £227 if it goes to an oral hearing). The tribunal can order repayment of some or all of the rent the tenants paid while the property was unlicensed.

For a Camden HMO renting rooms at market rates, 24 months of rent across multiple tenants can easily reach five or six figures. And the application can be made jointly against the immediate landlord, superior landlords in rent-to-rent structures, and company directors.

The local authority can also apply for an RRO to recover housing benefit payments made during the unlicensed period.

The Rogue Landlord and Agent Checker

Landlords who receive a civil penalty of £500 or more or are convicted of a housing offence can be listed on the Mayor of London's public Rogue Landlord and Agent Checker. Civil penalty entries can remain public for up to one year; paying the penalty does not automatically remove the entry.

In severe cases, Camden can apply for a banning order under the Housing and Planning Act 2016, which prohibits you from letting property or engaging in property management for a set period.

Late Renewal Creates Unlicensed Gaps

You don't have to be deliberately avoiding licensing to face these penalties. The most common route is a missed renewal deadline. Camden opens the renewal portal 30 days before expiry; an application outside the renewal window is treated as a new application. If the licence expires before a new application is duly made, the property becomes unlicensed immediately and stays that way until then.

Even a few days of unlicensed operation creates exposure to civil penalties and rent repayment orders. Camden's enforcement team can identify licence expiry dates from their own records.

Appealing a Penalty

If you receive a civil penalty notice or a licensing decision you disagree with:

• At the draft decision stage (Schedule 5 notice): you have 14 days to submit written representations to Camden Council
• At the final decision stage: you have 28 days from service of the notice to appeal to the First-tier Tribunal

Contacting Camden informally does not stop or extend the 28-day tribunal deadline. Missing it means you lose the right to appeal.

The Camden Landlord Licensing Guide walks through the full enforcement framework and includes a conditions tracker to help you stay compliant throughout the licence term.

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