Medway Council is consulting on proposals that could see all Houses in Multiple Occupation (HMOs) within several wards require a licence, regardless of property size. If approved, the new scheme would significantly widen the scope of landlord regulation across the borough, with implementation expected as early as next summer.

Understanding HMO licensing

HMO licensing is often confused with planning controls under Article 4 Directions, but the two are distinct. Whereas Article 4 removes permitted development rights—often requiring planning permission to convert a dwelling into an HMO—licensing governs the operation of an HMO once in use.

Under current rules, landlords must register their property with the local authority, undergo inspection, and meet prescribed safety and amenity standards before being granted a licence. Medway Council charges £1,305.30 for a five-year licence, which must be renewed at expiry.

The scheme aims to ensure that shared accommodation meets acceptable living conditions. Requirements include adequate kitchen and bathroom facilities, appropriate room sizes, and evidence of valid gas and electrical safety certification. While responsible landlords typically meet these obligations already, the cost and administrative burden remain a recurring concern across the sector.

The Medway proposals

The council is proposing additional and selective licensing schemes for nine wards:

• Chatham Central
• Brompton
• Fort Pitt
• Gillingham North
• Gillingham South
• Luton
• Strood North
• Frindsbury
• Watling

Consultation documents cite research by Cadence Innova showing that 22% of shared-amenity HMOs in Medway present at least one serious hazard, including mould, electrical defects, and fire safety risks. Over a five-year period, the council received 339 complaints relating to HMOs, alongside 101 anti-social behaviour reports linked to such properties.

The number of HMOs across Medway is estimated at 1,018, of which 658 are located in the proposed licensing areas. These figures include both known and suspected unlicensed properties.

The consultation period runs until early 2026, with a review scheduled for April 2026 ahead of possible implementation later that year. Meanwhile, Naushabah Khan MP (Gillingham and Rainham) has reportedly urged the council to explore introducing an Article 4 Direction, though no formal proposal has yet been tabled.

Implications for landlords

The potential impact on Medway’s private rented sector remains to be seen. While there is limited local evidence on how borough-wide licensing affects housing supply or rental values, experience from similar schemes elsewhere suggests that compliant landlords will face little operational disruption beyond the additional cost.

However, unlicensed or non-compliant landlords are likely to face stronger enforcement action, as councils increasingly view licensing as a tool to tackle substandard housing and anti-social behaviour. Critics, however, argue that the schemes often operate as a revenue-raising exercise rather than a targeted enforcement mechanism.

Commenting on the proposals, Hasan from Home-Share said:  “Responsible landlords have nothing to fear from these changes. Most already meet the required standards, and the licensing cost is likely to be absorbed through normal rent reviews. The real test will be whether Medway Council enforces compliance effectively rather than allowing non-registered landlords to operate unchecked.”