Article 4 Directions and HMOs: Every London Borough's Rules (2026)
Planning to convert a property into an HMO in London? Over two-thirds of London boroughs now require planning permission for small HMO conversions. This guide covers every borough's Article 4 status, when each direction was introduced, and what it means for your project.
TL;DR - The Quick Answer
Normally, you can convert a house (Use Class C3) into a small HMO for 3-6 people (Use Class C4) without planning permission, thanks to Class L of Part 3 of the GPDO 2015. But an Article 4 direction removes this right. As of April 2026, at least 22 London boroughs have Article 4 directions in force that require planning permission for C3 to C4 HMO conversions. These range from borough-wide blanket restrictions (Newham, Barnet, Tower Hamlets) to targeted coverage of specific wards (Haringey, Merton). If you are converting a property with 7 or more occupants, you always need planning permission regardless of Article 4 status, because large HMOs are classified as Sui Generis. Always check with the specific borough council before starting work.
What Is an Article 4 Direction?
Under the Town and Country Planning (General Permitted Development) (England) Order 2015, Class L of Part 3, Schedule 2 grants permitted development rights to change a dwelling (Use Class C3) into a small HMO (Use Class C4) and vice versa. In plain English: you can normally convert a house into a shared house for up to 6 unrelated people without applying for planning permission.
An Article 4 direction is a legal order made by a local council that removes specific permitted development rights in their area. When a council introduces an Article 4 direction targeting C3 to C4 conversions, it means you must apply for full planning permission before converting any dwelling into a small HMO.
Councils introduce these directions when they have evidence that uncontrolled HMO growth is causing problems - parking pressure, waste management issues, loss of family housing, or changes to neighbourhood character. The direction does not ban HMOs outright. It simply means each conversion is assessed on its merits through the planning system.
Key point: An Article 4 direction does not prevent HMO conversions. It means you need planning permission. Many applications are approved - councils just want to assess each one individually rather than allowing automatic conversions.
How Article 4 Directions Are Introduced
There are two types of Article 4 direction:
- Non-immediate: The council gives 12 months' notice before the direction takes effect. This is the standard route and means the council does not have to pay compensation for refused applications.
- Immediate: Takes effect straight away but the council may be liable for compensation if planning permission is subsequently refused. Used in urgent situations to prevent a rush of conversions before the direction takes effect.
London Boroughs WITH Article 4 HMO Restrictions
The following boroughs have confirmed Article 4 directions that remove permitted development rights for C3 to C4 HMO conversions. We have split them into borough-wide (covering the entire borough) and partial (covering specific wards or areas).
Borough-Wide Article 4 Directions
In these boroughs, planning permission is required for any C3 to C4 conversion anywhere in the borough.
Barking and Dagenham
- Coverage: Borough-wide
- In force since: 14 May 2012
- Type: Non-immediate (made 14 May 2011)
- Notes: One of the earliest London boroughs to introduce HMO Article 4 restrictions.
Barnet
- Coverage: Borough-wide
- In force since: 29 May 2016
- Type: Non-immediate (made 28 May 2015)
- Notes: Covers all houses and flats. Planning permission needed for any new C3 to C4 conversion.
Bexley
- Coverage: Borough-wide
- In force since: 24 September 2017
- Type: Non-immediate
Brent
- Coverage: Borough-wide
- In force since: 1 November 2022
- Type: Non-immediate (confirmed 3 February 2022)
Bromley
- Coverage: Borough-wide (phased)
- In force since: 8 February 2022 (immediate, Biggin Hill and Darwin wards); 1 September 2022 (non-immediate, all remaining wards)
- Notes: Now covers the entire borough. Approved by councillors against planning officer advice.
Croydon
- Coverage: Borough-wide
- In force since: 28 January 2020
- Type: Non-immediate (made 28 January 2019)
- Notes: Applies to both houses and flats.
Ealing
- Coverage: Borough-wide (two directions combined)
- In force since: 30 October 2024 (immediate direction, Perivale ward); 14 November 2025 (non-immediate direction, rest of borough excluding OPDC area)
- Notes: Introduced in two phases. The immediate direction for Perivale may carry compensation liability. The OPDC administrative area within Ealing is excluded.
Enfield
- Coverage: Borough-wide
- In force since: 22 October 2013
- Type: Non-immediate (made 22 October 2012)
Royal Borough of Greenwich
- Coverage: Borough-wide
- In force since: 27 September 2018
- Type: Non-immediate (made September 2017)
Havering
- Coverage: Borough-wide (two directions combined)
- In force since: 13 July 2016
- Type: Non-immediate (made 3 November 2015)
- Notes: Two separate directions cover different property types across the borough. The first covers all property types in four specific wards; the second covers flats, terraced houses, and semi-detached houses across the remaining wards.
Hillingdon
- Coverage: Borough-wide (all 21 wards)
- In force since: 11 December 2025
- Type: Immediate
- Notes: Previously covered only "hotspot" wards. Expanded to the entire borough in December 2025. Because it was immediate, the council may be liable for compensation on refused applications.
Hounslow
- Coverage: Borough-wide (excluding industrial land, business parks, and Mogden Sewage Works)
- In force since: 4 September 2023
- Type: Non-immediate (confirmed 8 August 2023)
Lewisham
- Coverage: Borough-wide (phased)
- In force since: 7 March 2020 (southern wards: Bellingham, Downham, Grove Park, Whitefoot); 19 January 2024 (all remaining wards)
- Notes: Now covers the entire borough after the second direction came into force in January 2024.
Newham
- Coverage: Borough-wide
- In force since: 31 July 2013
- Type: Non-immediate (made 31 July 2012)
- Notes: One of the earliest and most established Article 4 HMO directions in London.
Redbridge
- Coverage: Borough-wide (all postcodes)
- In force since: 6 December 2019
- Type: Non-immediate (made 3 December 2018, confirmed April 2019)
- Notes: Any HMO that existed before 6 December 2019 is not required to obtain planning permission retrospectively. Only conversions after that date need consent.
Sutton
- Coverage: Borough-wide
- In force since: 22 February 2025
- Type: Non-immediate (made 22 February 2024)
- Notes: One of the most recently implemented directions in London.
Tower Hamlets
- Coverage: Borough-wide (all houses and flats)
- In force since: 1 January 2021
- Type: Non-immediate (made 24 July 2019, confirmed 29 January 2020)
- Notes: Restricts occupation to a single family or two sharers unless planning permission is obtained for change of use to C4.
Waltham Forest
- Coverage: Borough-wide
- In force since: 16 September 2014
- Type: Non-immediate (made 16 September 2013)
Partial Article 4 Directions
These boroughs have Article 4 directions covering specific wards or areas only. If your property is outside the designated area, you can still convert from C3 to C4 under permitted development.
Haringey
- Coverage: Partial - eastern wards of the borough
- In force since: 30 November 2013
- Notes: Covers most of the east of the borough. The western side of Haringey is not covered, so C3 to C4 conversions there may still proceed under permitted development. Check Haringey's interactive map to confirm if your property is within the Article 4 boundary.
Merton
- Coverage: Partial - seven eastern wards
- In force since: 17 November 2022 (immediate)
- Wards covered: Figge's Marsh, Graveney, Longthornton, Pollards Hill, Colliers Wood, Cricket Green, and Lavender Fields
- Notes: Western Merton (Wimbledon, Raynes Park, etc.) is not currently covered.
Southwark
- Coverage: Partial - specific streets/areas
- In force since: 27 October 2014 (Henshaw Street, Walworth SE17); 27 October 2016 (Bywater Place, Surrey Quays SE16)
- Notes: Unlike most boroughs on this list, Southwark's HMO Article 4 directions are very localised rather than borough-wide. The vast majority of Southwark is not covered. However, the borough operates an extensive HMO licensing scheme separately. Check with Southwark Council for the latest status.
Other Boroughs With Article 4 HMO Directions
The following boroughs also have Article 4 directions for HMOs, though implementation dates and exact coverage areas should be confirmed directly with each council:
- Lambeth - Partial. Article 4 direction covering Streatham Common & Vale and Streatham St Leonard's wards, in force since 11 August 2025.
Incoming: Boroughs With Proposed or Pending Directions
- Hammersmith and Fulham - The council published a cabinet report in February 2026 proposing a borough-wide non-immediate Article 4 direction for small HMOs. If confirmed, it would take effect approximately 12 months after the direction is made. Check with LBHF planning for current status.
| Borough | Coverage | In Force Since |
|---|---|---|
| Barking & Dagenham | Borough-wide | May 2012 |
| Barnet | Borough-wide | May 2016 |
| Bexley | Borough-wide | September 2017 |
| Brent | Borough-wide | November 2022 |
| Bromley | Borough-wide (phased) | February/September 2022 |
| Croydon | Borough-wide | January 2020 |
| Ealing | Borough-wide (two directions) | October 2024/November 2025 |
| Enfield | Borough-wide | October 2013 |
| Greenwich | Borough-wide | September 2018 |
| Haringey | Partial (eastern wards) | November 2013 |
| Havering | Borough-wide (two directions) | July 2016 |
| Hillingdon | Borough-wide | December 2025 |
| Hounslow | Borough-wide | September 2023 |
| Lewisham | Borough-wide (phased) | March 2020/January 2024 |
| Merton | Partial (7 eastern wards) | November 2022 |
| Newham | Borough-wide | July 2013 |
| Redbridge | Borough-wide | December 2019 |
| Southwark | Partial (specific streets) | October 2014/2016 |
| Sutton | Borough-wide | February 2025 |
| Tower Hamlets | Borough-wide | January 2021 |
| Waltham Forest | Borough-wide | September 2014 |
Source: Council websites and London Property Licensing • Data as of April 2026
London Boroughs WITHOUT Article 4 HMO Restrictions
In these boroughs, you can still convert a dwelling (C3) into a small HMO (C4) for up to 6 unrelated people under permitted development without applying for planning permission. You do not need to notify the council (though you may need an HMO licence separately - see below).
Based on available data as of April 2026, the following boroughs do not appear to have Article 4 directions specifically targeting C3 to C4 HMO conversions:
- Camden
- City of London
- Hackney
- Islington
- Kensington and Chelsea
- Kingston upon Thames
- Richmond upon Thames
- Wandsworth
- Westminster
Important: This list can change. Boroughs regularly introduce new Article 4 directions, and several of the above may be considering or consulting on new restrictions. Always verify with the specific council before relying on permitted development rights. The trend across London is clearly towards more boroughs introducing Article 4 HMO restrictions, not fewer.
No Article 4 does not mean no rules. Even in boroughs without an Article 4 HMO direction, you may still need a mandatory HMO licence (for 5+ people in 2+ households), an additional HMO licence (varies by borough), and you must comply with HMO management regulations, fire safety requirements, and minimum room sizes. See the licence vs planning section below.
When You Still Need Planning Permission - Even Without Article 4
Article 4 directions only affect small HMOs (Use Class C4) - that is, shared houses with 3-6 unrelated occupants. But there is a separate category that always requires planning permission regardless of Article 4 status.
Large HMOs: 7+ Occupants = Sui Generis
If your HMO will house 7 or more unrelated people forming 2 or more separate households, the property falls outside both C3 and C4 use classes entirely. It is classified as Sui Generis (Latin for "of its own kind") - a unique use that has no automatic permitted development rights.
This means:
- You always need planning permission to convert to a large HMO, in every London borough, with or without Article 4
- You also need planning permission to upsize from a small HMO (C4) to a large HMO (Sui Generis)
- A mandatory HMO licence is required from the council (this applies to all HMOs with 5+ people in 2+ households, not just Sui Generis)
| Scenario | Without Article 4 | With Article 4 |
|---|---|---|
| C3 to C4 (3-6 people) | Permitted development - no planning needed | Planning permission required |
| C3 to Sui Generis (7+ people) | Planning permission required | Planning permission required |
| C4 to Sui Generis (expanding HMO) | Planning permission required | Planning permission required |
| C4 to C3 (reverting to family home) | Permitted development | Permitted development |
Source: GPDO 2015, Schedule 2, Part 3, Class L • Data as of 2026
HMO Licence vs Planning Permission: They Are Different Things
One of the most common mistakes landlords make is confusing HMO licensing with planning permission. They are two completely separate legal requirements governed by different legislation.
| Aspect | HMO Licence | Planning Permission |
|---|---|---|
| Legislation | Housing Act 2004 | Town and Country Planning Act 1990 |
| Purpose | Ensures property is safe and well-managed | Controls change of use of land/buildings |
| When required | Mandatory for 5+ people in 2+ households; additional licensing varies by borough | Required for C3 to C4 in Article 4 areas; always required for Sui Generis (7+) |
| Covers | Fire safety, room sizes, kitchen/bathroom ratios, management standards | Whether the use is acceptable in that location (parking, amenity, housing mix) |
| Having one means... | You can legally operate the HMO | The change of use is legally permitted |
You may need both. Having an HMO licence does not mean you have planning permission, and vice versa. In an Article 4 area, you need planning permission for the change of use and an HMO licence if required. Operating without either can result in enforcement action and fines.
What Happens If You Convert Without Planning Permission in an Article 4 Area?
If you convert a property to a small HMO in an Article 4 area without first getting planning permission, the council can take enforcement action against you. This can include:
- Enforcement notice: Requiring you to stop using the property as an HMO and revert to C3 use
- Breach of condition notice: If you have conditions on a previous planning permission that prevent HMO use
- Prosecution: In serious cases, the council can prosecute for breach of planning control
You can apply for a retrospective planning application if you have already converted without permission, but there is no guarantee it will be approved. If refused, you may be required to revert the property to its original use.
It is worth noting that the council has up to 10 years to take enforcement action for a change of use. Some landlords mistakenly believe the 4-year rule applies, but this is only for building operations, not changes of use. For more on enforcement timescales, see our guide to the 4-year rule and planning enforcement.
Tips for Getting HMO Planning Permission Approved
If your property is in an Article 4 area and you need to apply for planning permission, these are the factors councils typically assess:
What Councils Look For
- Concentration of existing HMOs: Most councils have policies limiting HMO density. A common threshold is no more than 10-20% of properties within a set radius being HMOs.
- Impact on residential amenity: Noise, waste storage, and general disturbance to neighbours.
- Parking provision: Particularly in outer London boroughs where car ownership is higher.
- Quality of accommodation: Room sizes, natural light, access to outdoor space, kitchen and bathroom facilities.
- Waste and cycle storage: Adequate bin storage for multiple households and cycle parking where required.
- Loss of family housing: Councils protect family-sized dwellings (3+ bedrooms), particularly in areas with a shortage.
A standard change of use planning application fee applies (currently £610 from April 2026). Processing time is typically 8 weeks. Pre-application advice is available from most boroughs for an additional fee and can help you understand whether your proposal is likely to be approved before you invest in a full application.
As of April 2026, at least 22 London boroughs have Article 4 directions removing permitted development rights for C3 to C4 HMO conversions. These require planning permission before converting a house into a small HMO (3-6 people). Borough-wide directions are in force in Barnet, Barking & Dagenham, Bexley, Brent, Bromley, Croydon, Ealing, Enfield, Greenwich, Havering, Hillingdon, Hounslow, Lewisham, Newham, Redbridge, Sutton, Tower Hamlets, and Waltham Forest. Partial directions apply in Haringey, Merton, and Southwark. Large HMOs (7+ people) always need planning permission regardless. Mayfair Studio checks Article 4 status instantly for any London address.
Frequently Asked Questions
What is an Article 4 direction for HMOs?
An Article 4 direction is a legal order made by a local council that removes specific permitted development rights. For HMOs, it removes the right to convert a dwelling (Use Class C3) into a small HMO for 3-6 people (Use Class C4) without planning permission. Under normal circumstances, this conversion is allowed automatically under Class L of Part 3 of the General Permitted Development Order 2015. When an Article 4 direction is in place, you must submit a full planning application and get approval before converting. The direction does not ban HMOs - it means each conversion is assessed individually. Source: GPDO 2015, Schedule 2, Part 3, Class L.
Which London boroughs have Article 4 directions for HMOs?
As of April 2026, at least 22 London boroughs have Article 4 directions targeting HMO conversions. Borough-wide directions are in force in Barking & Dagenham, Barnet, Bexley, Brent, Bromley, Croydon, Ealing, Enfield, Greenwich, Havering, Hillingdon, Hounslow, Lewisham, Newham, Redbridge, Sutton, Tower Hamlets, and Waltham Forest. Partial directions cover parts of Haringey, Merton, and Southwark. Kingston and Richmond also have directions in place. Boroughs currently without HMO Article 4 directions include Camden, Hackney, Islington, Lambeth, Wandsworth, Westminster, Kensington & Chelsea, and the City of London - though this list is shrinking as more boroughs introduce restrictions.
Do I need planning permission to convert a house to an HMO in London?
It depends on three things: (1) How many people will live there - if 7 or more, you always need planning permission regardless of borough, because large HMOs are Sui Generis. (2) Whether your borough has an Article 4 direction for HMOs - if yes, you need planning permission for conversions to small HMOs (3-6 people) too. (3) Whether any previous planning permission on the property has conditions restricting HMO use. In boroughs without Article 4, converting to a small HMO (3-6 people) is permitted development under Class L of the GPDO 2015 and does not need planning permission. But you may still need an HMO licence separately.
What is the difference between C4 and Sui Generis HMOs?
Use Class C4 covers small HMOs with 3-6 unrelated people sharing. Sui Generis ('of its own kind') applies to large HMOs with 7 or more unrelated people. The key difference is that C4 HMOs can benefit from permitted development rights (conversion from C3 without planning permission) unless removed by an Article 4 direction. Sui Generis HMOs always require planning permission, in every borough, regardless of Article 4 status. Both types may require HMO licences depending on the number of occupants and the borough's licensing scheme.
Can I still convert to an HMO in an Article 4 area?
Yes. An Article 4 direction does not ban HMO conversions. It means you must apply for planning permission first, and each application is assessed on its merits. Many applications are approved. Councils typically look at the concentration of existing HMOs in the area, impact on neighbours, parking, waste storage, and whether the accommodation meets minimum standards. A standard planning application costs £610 from April 2026 and takes approximately 8 weeks to determine.
Do I need an HMO licence as well as planning permission?
Potentially, yes. HMO licensing and planning permission are two separate legal requirements. A mandatory HMO licence is required for properties with 5 or more people forming 2 or more households. Many London boroughs also operate additional licensing schemes covering smaller HMOs (3-4 people). Having a licence does not grant planning permission, and having planning permission does not replace the need for a licence. You may need both. Operating without either can result in enforcement action and significant fines.
How long does the council have to take enforcement action for an unauthorised HMO?
The council has up to 10 years to take enforcement action for an unauthorised change of use to an HMO. This is a common misconception - many landlords incorrectly believe the 4-year rule applies, but that time limit is for building operations (physical works), not changes of use. If you have been operating an HMO without planning permission in an Article 4 area for less than 10 years, you are still at risk of enforcement action.
Is Hackney an Article 4 area for HMOs?
No. As of April 2026, Hackney does not have an Article 4 direction removing permitted development rights for C3 to C4 HMO conversions. This means you can convert a dwelling into a small HMO (3-6 people) under permitted development without planning permission. However, you may still need an HMO licence, and if the HMO will house 7 or more people, planning permission is always required. Always verify the current position with Hackney Council as this may change.
Summary
The HMO planning landscape in London has shifted significantly over the past decade. What was once a straightforward permitted development conversion now requires planning permission in the majority of London boroughs. The trend is clearly towards more restriction, not less.
Before starting any HMO conversion in London, you should:
- 1Check whether the borough has an Article 4 direction for HMOs and whether your property falls within it
- 2Determine how many occupants you plan to house - 7+ always needs planning permission
- 3Check whether you need an HMO licence (mandatory, additional, or selective) from the council
- 4If planning permission is needed, consider pre-application advice before submitting
- 5Ensure the property meets minimum room sizes, fire safety requirements, and management standards before tenants move in
Related Articles
Over two-thirds of London boroughs have Article 4 directions requiring planning permission for small HMO conversions (C3 to C4). Borough-wide directions: Barking & Dagenham (2012), Barnet (2016), Bexley (2017), Brent (2022), Bromley (2022), Croydon (2020), Ealing (2024/25), Enfield (2013), Greenwich (2018), Havering (2016), Hillingdon (2025), Hounslow (2023), Lewisham (2020/24), Newham (2013), Redbridge (2019), Sutton (2025), Tower Hamlets (2021), Waltham Forest (2014). Partial coverage: Haringey, Merton, Southwark. Without Article 4 HMO restrictions: Camden, City of London, Hackney, Islington, Kensington & Chelsea, Lambeth, Wandsworth, Westminster. Large HMOs (7+) always need planning permission. Mayfair Studio offers free instant Article 4 checks for any London address.