HMO Pet Request Rules for Landlords in England

HMOs Are Not Exempt

Houses in multiple occupation are not excluded from the pet request rules under Section 16A of the Housing Act 1988. If a tenant in an HMO holds a private assured periodic tenancy, they have the statutory right to submit a written pet request, and you must respond in writing within 28 days.

That said, HMOs raise complications that single-household lettings do not. Shared communal spaces, multiple tenants with different preferences, and licensing conditions all affect how you assess a request.

Shared Spaces and Other Tenants

The most common HMO-specific issue is the impact on other occupants. An animal in one tenant's room inevitably uses shared corridors, kitchens, and sometimes gardens. Other tenants may have genuine medical allergies — not preferences, but documented clinical conditions.

A severe, documented allergy in another occupant of the same shared house is a legitimate ground for refusing a pet request. But "my other tenants don't like dogs" is not. The test is objective and evidence-based: a GP letter confirming a severe allergy to animal dander, not an email from a housemate saying they'd rather not have a cat around.

If no other tenant has a documented medical condition, the shared-space argument alone is unlikely to justify refusal. The statutory test is whether the refusal is reasonable, and general inconvenience in communal areas does not meet that threshold.

HMO Licensing Conditions

Check your HMO licence. Some licensing conditions imposed by local housing authorities include occupancy restrictions, amenity requirements, or specific conditions about property use. If your licence explicitly restricts animal-keeping, that specific condition may provide a relevant ground for refusal.

If the licence is silent on pets, it does not help your case. You cannot infer a restriction that the licence does not state.

Small Flats and Studio Lets

Property size is a relevant factor in any pet request, not just HMOs. A studio flat with no outdoor access is a genuinely different proposition from a three-bedroom house with a garden. MHCLG guidance recognises physical property suitability as a factor in the reasonableness assessment.

The key is specificity. "The flat is too small" is vague. "The property is a 25 sqm studio flat on the third floor with no balcony, no garden access, and no outdoor space within the building — the requested Labrador retriever requires regular outdoor exercise that this property configuration cannot provide" is a defensible, evidence-based ground.

For smaller animals — cats, hamsters, fish, caged birds — the property-size argument is much harder to sustain. A cat in a studio flat does not raise the same welfare or suitability concerns as a large dog.

Practical Steps for HMO Landlords

When you receive a pet request in an HMO:

1. Check your HMO licence conditions for any restrictions on animals
2. Ask existing tenants (in writing) whether they have documented medical conditions that would be affected — do not ask for opinions or preferences
3. Assess the physical property: room size, shared spaces, outdoor access
4. If you reasonably need more information about the animal, request it within the 28-day window to trigger the statutory extension; put the request in writing to keep a clear record

Document every step. In an HMO, you are managing the interests of multiple tenants, and your compliance file needs to show that you assessed the specific impact on the shared household rather than applying a blanket "no pets in HMOs" policy.

The Tenant Pet Requests guide covers HMO-specific assessment criteria and includes a pet suitability assessment form that walks through property size, shared-space impact, licensing conditions, and medical documentation.

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