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Rent Repayment Order – HMO

Unlicensed HMOs

The law changed on 1 May 2026. The Renters’ Rights Act 2025 raised the maximum Rent Repayment Order from 12 months’ rent to 2 years’ rent, and extended the deadline for applying from 12 months to 2 years from the date of the offence.

These new limits apply to offences committed on or after 1 May 2026. If your landlord’s offence was committed before that date, the previous rules still apply to you: a cap of 12 months’ rent, and 12 months to apply. Not sure which applies? Tell us the dates and we will work it out for you.

Most Rent Repayment Order claims come down to one thing: a shared house that needed a licence and did not have one. This page is the overview — how the pieces fit together, and where to go for the detail on each.

The chain, in five links

  1. Your home was a House in Multiple Occupation — two or more households sharing a kitchen, bathroom or toilet.
  2. An HMO of that size, in that area, required a licence.
  3. Your landlord did not have one.
  4. That is an offence under section 72(1) of the Housing Act 2004.
  5. That offence is on the section 40 list in the Housing and Planning Act 2016, so you can apply for a Rent Repayment Order — up to 2 years’ rent back.

Every link has to hold. If the property was not an HMO, or did not need a licence, or had one, the chain breaks and there is no claim on this ground.

Link 1: was it an HMO?

Under section 254 of the Housing Act 2004, broadly: units of living accommodation that are not self-contained flats, occupied by more than one household as their only or main residence, paying rent, and sharing a basic amenity.

The word that decides it is household. People who are related or living as a couple are one household; everyone else is separate. Three friends sharing is three households. A family of six is one.

Full guide to what counts as an HMO →

Link 2: did it need a licence?

Three schemes, and you only need one of them to apply:

SchemeTypical thresholdWhere it applies
Mandatory5+ people, 2+ households, sharing amenities Everywhere in England
AdditionalUsually 3+ people, 2+ households Only where the council has designated
SelectiveAny private let — no sharing needed Only where the council has designated

Link 3: was there a licence?

Check your council’s public register, which it must keep under section 232 of the Housing Act 2004. Look at the holder’s name and the start and end dates, and compare them with your own tenancy. What you are looking for is a period when you were paying rent and no valid licence was in force.

How to check, and what the red flags are →

Links 4 and 5: the offence and the claim

Section 72(1) is a strict liability offence — intention is irrelevant. But the tribunal must be satisfied beyond reasonable doubt, and the landlord has two statutory defences: that an application had been duly made (s.72(4)), or that they had a reasonable excuse (s.72(5)).

The award is calculated using the four-step approach in Acheampong v Roman [2022] UKUT 239 (LC): whole rent, less any landlord-paid utilities that benefited only you, adjusted for the seriousness of the offence and then for the conduct and circumstances of both parties.

The offence, the defences and the calculation in detail →

What it is worth

Offence before 1 May 2026Offence on or after 1 May 2026
Maximum award12 months’ rent2 years’ rent
Deadline to apply12 months2 years
Who can be ordered to payImmediate landlord Immediate and/or superior landlord

Two decisions we have written up in full, both under the old 12-month cap: £7,020 for two tenants in Hammersmith and Fulham, and £11,268 for one tenant in Camden. The same facts today would be worth considerably more.

Where to start

In order: get your bank statements for the whole tenancy, write down your exact move-in and move-out dates, and check the council’s register. Those three things decide most claims.

The practical step-by-step guide →

Or let us do the checking. Send us the address and the dates you lived there. We will establish whether a licence was required, whether there was one, and what a claim would be worth — free, and with no obligation.

This article is general information about the law in England and is not legal advice about your own circumstances. The rules differ in Wales, Scotland and Northern Ireland.

Think this applies to you? Checking whether your landlord needed a licence is free and takes about two minutes. Check whether your landlord needed a licence.

Find out if you have a claim — free, in two minutes

Answer a few questions about your tenancy and we will tell you whether your landlord needed a licence. There is no charge, and no obligation.