Coventry Section 257 HMO Licensing: Do Converted Flats Need a Licence?

What a Section 257 HMO Is

A Section 257 HMO is an entire building that was converted into self-contained flats where the conversion work didn't comply with the Building Regulations that applied at the time (the 1991 Building Regulations for conversions before that date, or subsequent standards). The building also has to be mainly or wholly tenanted — specifically, fewer than two-thirds of the flats can be owner-occupied.

This classification applies to the building as a whole, not to individual flats within it. If you own the freehold or head lease of a converted block in Coventry and most of the flats are rented out, Section 257 is probably relevant to you.

Coventry's Additional Licensing Covers Section 257 Buildings

The 2025–2030 city-wide Additional Licensing designation explicitly captures Section 257 HMOs. That means the whole building needs its own HMO licence, separate from any licences individual flats might need.

The licence duty sits with the freeholder or head lessor who controls the overall building — not with individual flat leaseholders or tenants.

The Two Exemptions

Coventry's designation excludes two specific building types from Section 257 licensing:

1. Two-flat buildings with no commercial premises: a building consisting of just two self-contained flats where neither flat sits above or below a commercial unit.
2. Two-storey buildings with no shared common parts: a building no more than two storeys high where the individual flats share no internal or external common areas (corridors, stairways, entrance halls).

If your building meets either exemption, it doesn't need a Section 257 licence. But verify carefully — a shared front door or communal staircase removes you from exemption 2.

Double Licensing: When Individual Flats Also Need Licences

Here's the trap that catches block owners. If an individual flat inside a Section 257 building is then let to three or more unrelated occupants who share amenities, that flat independently triggers a separate Section 254 Additional HMO licence.

You'd need both: a Section 257 licence for the building and a Section 254 licence for the individual flat. Two applications, two sets of fees, two inspection cycles.

Evidence You'll Need

To apply for a Section 257 building licence, you'll need documentation showing:

• The building's conversion history and when the work was carried out
• Whether the conversion complied with the Building Regulations that applied at the time
• Current ownership structure (freehold, leasehold, percentage of owner-occupied vs tenanted flats)
• Standard documents: gas safety certificates, EICR, fire safety, and floor plans for the building

Checking Your Building

Start with the conversion date and the Building Regulations compliance. If your block was converted after 1991 and the work met the regulations, it's not a Section 257 HMO at all — standard licensing rules based on occupant numbers apply instead.

For a complete walkthrough of how Section 257 licensing works alongside mandatory and additional schemes in Coventry, including the fee structure and application process, see our Coventry Landlord Licensing Guide.

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