This is Scotland, so may be different elsewhere.
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We have a 3 bed flat, that last year was an House of Multiple Occupancy property and met all 2006 building regs and HMO regs after a complete re-furb less than two years ago. So firedoors, closers, extinguishers, emergency lighting etc etc.
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We let the HMO go when our new tenant (a local hotel business) that rented it for their staff only wanted two people in. Tenancy agreement specified only two. Spot check from council last week reveals a breach of the tenancy and HMO rules – they had an extra person in ‘only for a few days…’. This was without my knowledge, but I am held responsible.
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So I decide to re-do the HMO, to prevent this again. The new HMO rules brought in in October are horrendous! Some examples:
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The fire blanket in the kitchen needs it’s own emergency light, despite every room having its own emergency light.
The newish firedoors all need extra smoke seals, in addition to the intumescent strips.
The lounge door, main flat door, and main outside building door all need swapping round to outward opening, not inward opening.
All the neighbours need to change their doors / windows onto the stairwell to new firedoors as well.
Tenants have to be trained in fire evacuation, every 6 months. They/I should also do a weekly check of fire alarm, inspect sensors and emergency lights. If they miss this, or there is a problem, I am liable to immediate fine.
The kitchen has 1.8m of ‘clean run’ worktop (ie not including the corners), I need 2m minimum, so new kitchen worktops, moving freezer etc.
The wooden floors and tiles throughout have sound proofing, but we could be asked to replace them with carpet to deaden noise.
Bedroom minimum width of 2.25m – we have one measured at 2.22m x 4m, so a good single room, but now not allowed as a bedroom…
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Supposedly all this is now also going to be slowly retro-applied – so ALL public buildings, HMO’s etc will need to meet this standard soon.

Thats a LOT of work required there matt. Good luck with that.

Well, it has put us off doing it actually. We have written to tenant, cc’ing in Council HMO lady threatening to evict them ASAP if the do it again. We have also removed the bed from one room….!

I think they are generally trying to get rid of HMO’s through this type of regulation. My dad has one (converted victorian hotel) and the rules just change constantly. This appears to be coming mainly from the council however (this is in England too so maybe diferent regs) in order to get his HMO ‘license’. I work in fire safety for a large organisation and some of the rules they seem to be trying to apply retrospectively to old properties that are HMO’s are in a diferent league to what we have even in higher risk areas such as labs.

The other way round this is of course to change what you do with the building and rent it as a single property. In the past this meant taking locks off doors to individual rooms etc and only having one tennant. There seems to be much less regulation about letting a single property.

Not much help but it is annoying how they keep changing the goalposts.

3 or more people, unrelated = HMO
You can have 10 from same family in there, but no HMO needed.
All let under 1 tenancy agreement as single property, we don’t have door locks etc.
And I agree, the ‘rules’ seem beyond good measure.
The worst bit of all is it costs a fee of £650+ and you may only get a 6 month licence!

Is there no way to change the properties use? I.e. maybe re classify as a B&B?

nope.

Split it into two flats ?? Might be cheaper in the long run…

Seems a bit extreme making neighbours change doors and windows. I can check with our fire safety guys at work if you want?

Or just let it as a non HMO

I thought it was extreme, read it a few times, checked with council lady who re-read new stuff, came back and said yes we did need to.