Westminster Licence Variation and Change of Manager: How to Update an Existing Licence

Circumstances change during a licence term of up to five years. A managing agent leaves, a room is converted, or the landlord restructures ownership through a company. Some of these changes need a formal licence variation. Others void the licence entirely and require a brand-new application.

What Triggers a Variation

A licence variation is needed when the details on the granted licence no longer reflect reality but the licence itself is still valid. The most common triggers:

Change of managing agent. If you switch letting agents or appoint a new property manager, the person named on the licence as the managing agent is no longer correct. The new agent must pass the fit-and-proper-person test, and the licence must be updated to reflect the change.

Room reconfiguration. Converting a living room into a bedroom, splitting a large room into two or removing a partition changes the property's room layout — potentially affecting the occupancy cap and the room size compliance recorded on the licence.

Reduction in occupancy. If a five-person HMO drops to three occupants, the property may shift from mandatory to additional licensing. The existing licence conditions (particularly room size standards and amenity ratios) may need adjusting.

Change of licence holder contact details. A change of address, phone number or email for the licence holder or managing agent should be reported even though it does not change the substance of the licence.

The Variation Process

Variations are submitted through the MetaStreet portal. The council assesses whether the change is administrative (a name or contact detail correction) or substantive (a new managing agent who needs vetting, or a structural alteration that requires re-inspection).

Administrative variations — updating contact details or correcting a typo — typically incur no fee.

Substantive variations — such as a change of managing agent — require the new agent to complete a fit-and-proper-person self-declaration. The council may charge a processing fee and may require updated documents (for example, fresh floor plans if rooms have been reconfigured).

When a Variation Is Not Enough

A licence is non-transferable. If the property is sold, transferred to a different legal entity (such as moving ownership from a personal name into a limited company) or assigned to a new management company that also becomes the licence holder, the existing licence terminates automatically. The new owner or licence holder must submit a completely fresh application and pay both Part A and Part B fees.

This catches out landlords who incorporate their property portfolio. Moving a Westminster flat from personal ownership into an SPV (special purpose vehicle) company is a change of the person having control of the property — the licence does not follow.

The licence is non-transferable. If the licence holder dies, the executor or beneficiary should contact the council promptly to confirm whether a new application is needed.

Temporary Exemption Notices

If you intend to stop operating the property as a licensable let — for example, taking it back for personal use or selling with vacant possession — you can apply for a Temporary Exemption Notice (TEN) under section 62 (HMO) or section 86 (selective) of the Housing Act 2004. A TEN grants three months of legal exemption from licensing. In exceptional circumstances, the council may grant one extension of three months, for a maximum of six months total.

A TEN is not a variation — it is a separate application acknowledging that the property will leave the licensing regime. If plans change and you decide to continue letting, you must apply for a full licence before the TEN expires.

Keeping the Licence Current

The simplest way to stay compliant is to report changes promptly. The council's private sector housing team can be reached at [email protected]. Material changes such as a new managing agent should be submitted as a variation; contact the council to confirm any documents or fee needed.

The Westminster Landlord Licensing guide includes a compliance tracker for recording changes during the licence term, along with the full list of mandatory and local conditions attached to each scheme.

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