Coventry Mandatory vs Additional HMO Licensing: Which One Applies?

The Core Difference: Occupant Count

The distinction is straightforward once you know the threshold.

Mandatory HMO licensing applies to properties occupied by five or more people forming two or more separate households who share a kitchen, bathroom, or toilet. This is a national requirement under the Housing Act 2004, enforced everywhere in England — not just Coventry. There's no scheme expiry date; it runs continuously.

Additional HMO licensing applies to properties occupied by three or four people forming two or more separate households sharing amenities. This is a local designation — Coventry City Council chose to extend licensing to smaller shared properties across the entire city. The current scheme runs from 4 May 2025 through 3 May 2030.

Both use the same application portal, the same fit-and-proper test, the same document requirements, and the same fee schedule. The practical difference for landlords is mainly which application category you select on the portal.

Why Coventry Has Both

Mandatory licensing is set by Parliament. Every council in England must enforce it. But it only catches the larger HMOs — five or more people.

Coventry's additional scheme exists because the council found that properties with three or four sharers — particularly student houses and small professional lets — also needed oversight. The city-wide designation means every property in Coventry with three or more unrelated people sharing amenities is caught, regardless of which area it's in.

Without the additional scheme, a house let to four unrelated sharers in Earlsdon would need no licence at all. With it, every shared let in the city is covered.

Section 257 Buildings

The additional licensing scheme also captures Section 257 HMOs — buildings converted into self-contained flats where the conversion failed to comply with the Building Regulations that applied at the time (the 1991 Regulations or applicable subsequent standards) and fewer than two-thirds of the flats are owner-occupied. These buildings require their own licence, separate from any licences for individual flats that might themselves qualify as HMOs.

Mandatory licensing doesn't capture Section 257 buildings in the same way. It applies to individual flats within those buildings only if a flat itself meets the five-person threshold.

Getting the Application Category Right

When you log into the Coventry licensing portal, you select whether you're applying for a mandatory or additional HMO licence. Pick the wrong category and the application gets rejected.

The decision turns on one number: how many occupants form separate households in the property? Five or more means mandatory. Three or four means additional. If you're licensing a Section 257 building, that goes under additional.

For a decision flowchart covering all three licence types (mandatory, additional, and Section 257) and the complete application process, see our Coventry Landlord Licensing Guide.

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