What Is an HMO in Camden? How Many People Make a House an HMO
Whether your Camden property counts as an HMO depends on how many people live there and whether they form separate households — not on what the tenancy agreement calls the arrangement. The legal definition catches properties that many landlords don't realise are HMOs, and Camden's additional licensing scheme sets a lower bar than the national mandatory rules.
The Legal Definition
Under section 254 of the Housing Act 2004, a house in multiple occupation is a property (or part of a property) occupied by three or more people forming two or more separate households who share at least one basic amenity — a kitchen, bathroom or toilet.
A household means people related by blood, marriage, civil partnership, cohabitation, adoption, foster care or step-relationships. Everyone outside those relationships forms a separate household. Two friends sharing a flat are two households. A couple is one. A couple plus an unrelated flatmate is two.
The test is factual. A joint and several tenancy agreement doesn't make unrelated tenants into a single household. It's the actual relationships between the people living there that count.
Camden's Thresholds
Camden has two active licensing schemes, each catching properties at different occupancy levels:
Mandatory HMO licensing (national): 5 or more people, 2 or more households, sharing amenities. Applies everywhere in England.
Additional HMO licensing (Camden's borough-wide scheme): 3 or 4 people, 2 or more households, sharing amenities. This is Camden's own designation, running from December 2025 to December 2030.
The additional scheme is what makes Camden stricter than many other boroughs. In a borough with no additional licensing, a flat shared by three friends wouldn't need a licence. In Camden, it does.
Common Scenarios
A couple and one friend sharing a two-bed flat. Three people, two households (the couple is one household, the friend is another). They share a kitchen and bathroom. This is an HMO under Camden's additional scheme and needs a licence.
Three students sharing a house. Three people, three households (each student is a separate household unless they're related). Sharing kitchen and bathroom. Needs an additional HMO licence in Camden.
A family of four renting a house. Four people, one household (all related). Not an HMO — there's only one household, regardless of how many people.
Five unrelated professionals in a shared house. Five people, five households. Sharing facilities. This crosses the mandatory threshold — needs a mandatory HMO licence, which would apply in any English borough.
Two couples sharing a flat. Four people, two households. Sharing amenities. Needs an additional HMO licence in Camden.
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What Triggers the Obligation
The licence obligation exists from the moment the property meets the HMO definition with actual occupants — not from when you intended to let it as a shared property, and not from when you applied for a licence.
If your Camden flat has been occupied by three unrelated people since the tenancy started, it has been a licensable HMO since day one. Operating without a licence from that point carries exposure to civil penalties and rent repayment orders.
A common trigger is a change in tenant composition. A flat let to a couple becomes an HMO the day a third, unrelated person moves in and the group shares facilities. Students adding a flatmate mid-year, or a lodger moving into a spare room, can push a property across the threshold.
Exemptions
Not every multi-person property is an HMO. Statutory exemptions under Schedule 14 of the Housing Act 2004 include:
- A resident landlord with no more than two lodgers
- Purpose-built student accommodation managed by a university under an approved code of practice (but private student lets without university management are caught)
- Social housing managed by registered providers or local authorities
The Camden Landlord Licensing Guide includes a scheme determination worksheet to walk through the occupancy test for your specific property.
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