Hammersmith and Fulham Article 4 Direction: HMO Planning Permission Rules

As of 31 October 2026, LBHF has not brought an HMO Article 4 Direction into force. In February 2026, the council's Cabinet approved preparing a proposed direction to remove permitted-development rights for changes from C3 to C4 use and commissioned an evidence study to determine its geographic scope. Until a direction takes effect, a C3-to-C4 small HMO conversion is generally permitted development, subject to other planning controls.

What an Article 4 Direction Would Change

Under normal planning rules, a property classified as a C3 dwellinghouse (a family home) can be converted to a C4 small HMO (three to six unrelated people sharing) without planning permission. This is a "permitted development" right under the Town and Country Planning (General Permitted Development) Order 2015.

LBHF's Cabinet approved preparation of a proposed non-immediate Article 4 Direction in February 2026. The council said the proposed direction would remove that right in an area to be determined after an evidence study. It was not in force as of 31 October 2026. If a direction covering a property comes into force, converting C3 to C4 there would require planning permission from LBHF Planning Services.

Large HMOs Need Permission Too

Properties housing seven or more unrelated occupants are classified as "sui generis" — a use class of their own — and always require explicit planning permission. The Article 4 Direction didn't change this; large HMOs have never had permitted development rights.

Planning Permission Is Separate from Licensing

This is where landlords get confused. A property licence under the Housing Act 2004 and planning permission under the Town and Country Planning Act 1990 are two different legal systems. Getting one doesn't grant you the other.

A landlord who obtains an HMO licence from the private sector housing team is not automatically cleared for planning. If the property was converted from C3 to C4 use after April 2021 without planning permission, the council's planning enforcement team can take action regardless of whether a valid HMO licence exists.

Similarly, having planning permission for HMO use doesn't remove the obligation to apply for a property licence.

Practical Impact for Landlords

The council's February 2026 report says the proposed direction would not apply retrospectively to small HMOs already in use. Check the property's planning history and lawful use with LBHF before relying on that position.

If you're buying a property to convert into a shared house, check the planning status before exchanging. The purchase price might assume HMO income, but if planning permission is refused, you're stuck with a single-family let.

What to Do

1. Confirm the property's current planning use class — check with LBHF Planning or look at the property's planning history online
2. Check LBHF's latest Article 4 notices to see whether a direction has been made and brought into force for the address
3. If a relevant direction comes into force before you convert from C3 to C4, submit a planning application before changing the use
4. Apply separately for the appropriate property licence once the planning position is settled

For the full licensing application process, see the Hammersmith and Fulham Landlord Licensing Guide.

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