Three councils took decisions on HMOs inside a fortnight, and the tools they are reaching for are changing. Stoke-on-Trent’s cabinet approved a package on 11 August 2026 built around a city-wide Article 4 direction and a new licensing scheme, with ward-level caps following in a Local Plan policy that is not yet adopted. Bolton’s cabinet agreed a borough-wide licensing scheme on 17 August. Burnley then agreed to consult on extending its Article 4 direction to the six wards it does not yet cover. For anyone underwriting a conversion in the north west or the midlands, the change that matters is not the fee. It is that permission is being set up to be refused by arithmetic rather than judged on merit.
Stoke would cap HMOs by ward
Stoke-on-Trent City Council published its proposals on 4 August 2026. A city-wide Article 4 direction would remove the permitted development right that lets a family house become a small HMO without a planning application. That part is familiar. The rest is not.
Separately from that package, the council’s emergent Local Plan carries a ceiling on HMO numbers in every ward: 4% of residential properties in wards that already have a very high concentration, 2.5% in wards with a high concentration, and 1.5% everywhere else. A new HMO would be supported only where it would keep HMOs at or below 5% of all homes within a 50 metre radius. Two HMOs could not sit side by side under a single frontage, and a house could not be sandwiched between two of them.
The published cabinet decision of 11 August 2026 approves introducing the city-wide Article 4 direction, subject to following the statutory processes necessary, and approves additional licensing subject to consultation and detailed design. That is a decision to proceed, not a rule you are bound by yet. No Article 4 direction covering HMOs is in force in Stoke today, and the council’s existing Article 4 directions relate to its conservation areas, which control alterations rather than use.
Burnley consults on six more wards
Burnley has had an Article 4 direction on small HMO conversions covering nine of the borough’s fifteen wards. The council’s Article 4 direction page records it as made on 13 October 2023, confirmed in June 2024, and in force from 14 October 2024. It has now agreed to consult on extending it to the remaining six wards: Briercliffe, Cliviger with Worsthorne, Coal Clough with Deerplay, Hapton with Park, Lanehead, and Whittlefield with Ightenhill.
The proposed direction is non-immediate, and that is the detail carrying the money. A non-immediate direction is announced well ahead of taking effect, and LandlordZONE reports Burnley’s is set to start in September 2027 if confirmed. Until then the permitted development right survives in those six wards. Councillor Howard Baker, the executive member for housing and planning, says removing the rights will “give the council more control over how many there are and where”.
Bolton licences nearly every HMO
Bolton’s cabinet agreed its additional licensing scheme on 17 August 2026. It is borough-wide and it catches properties occupied by three or more people from different households who share at least one basic amenity, which pulls smaller HMOs into a regime that until now applied to those with five or more occupants. The fee is £1,211 for a licence of up to five years, and the council expects the scheme to be fully operational in early 2027.
At the full term that is roughly £242 a year per property before a single repair is done. Across a portfolio of ten that is £12,110 over the term. The sharper number is the room standard: the council’s consultation document sets a minimum of 7.5 square metres for a single-occupant bedroom against the statutory 6.51. Newly licensed properties get up to three years to comply. The council’s conditions also require training for the licence holder or their managing agent. A room that lets today may not qualify later, which is a supply question as much as a compliance one.
Licensing, Article 4 and ward caps
Licensing, Article 4 and concentration caps do different jobs, and they are not interchangeable. A licence is a cost you can budget for. An Article 4 direction is a process you can attempt, and a well argued application can still succeed. A ward cap is neither. If the ward already sits at its ceiling and your target property would push it past, the merits of your scheme do not come into it.
That is the shift worth registering. We wrote in July that licensing had become a national cost line rather than a local irritation, and that still holds. What is new is planning policy being written so the answer arrives before the application does.
What this means for property investors
Check the three statuses separately, and do it at offer stage. Licensing, Article 4 and any concentration policy are three different questions to three different parts of a council, and a clean answer on one tells you nothing about the other two. Our guide to Article 4 directions and HMO investing sets out how to establish whether a direction is in force, proposed or absent at a given address.
Treat a non-immediate direction as a dated window rather than a reprieve. Burnley’s six wards keep the permitted development right until September 2027 if the direction is confirmed. A conversion completed inside that window stays lawful afterwards. One that is not becomes a planning application in a borough that has already said what it thinks.
Price consented stock higher where the door is closing. This cuts both ways and the second half is the part people miss. Restricting new conversions makes existing lawful HMOs scarcer, and scarcity supports the value of stock that already holds its consent and its licence.
Do not underwrite a decision to proceed as though it were law. Stoke’s ward caps sit in an emergent Local Plan policy that is not yet adopted, so they could still be changed or dropped at examination. Equally, do not treat consultation as a reason to relax: Burnley’s nine covered wards went out to consultation in late 2023 and have been in force since October 2024.
This is general information, not advice on your position, so take your own before acting. Browse our current listings, including HMOs, or join the insider list to see off-market opportunities before they are advertised.