HMO Article 4 coverage is not uniform across London. Check the property's mapped area, the direction's commencement and confirmation, and the precise change of use it controls. A direction requiring a planning application is not a blanket ban, and the licensing question remains separate. [1][2][3]
What the direction usually controls
The council examples here concern a change from an ordinary dwellinghouse in Class C3 to a small HMO in Class C4, occupied by between three and six unrelated people sharing facilities. The direction removes the specified permitted-development route, so an application is required for the covered change. It does not establish that every proposal will be refused. [1][2]
Do not use a borough's Article 4 webpage as a substitute for identifying the proposed planning use. A licensing definition and a planning use-class description serve different regulatory purposes. [3][4]
Ealing: check the development-corporation boundary
Ealing introduced an immediate direction for Perivale on 30 October 2024. Its wider direction took effect on 14 November 2025, extending the restriction across the rest of the borough apart from the Old Oak and Park Royal Development Corporation planning area. The exclusion is important when checking an address near that boundary. [1]
A postcode search that says only “Ealing” does not resolve the planning-authority boundary or the applicable map. Use the council's direction documents and the actual site location. [1]
Waltham Forest and Tower Hamlets
Waltham Forest's current Article 4 page identifies a borough-wide direction controlling the C3-to-C4 change. It provides the local direction information alongside other Article 4 controls. Check that the selected document concerns HMOs rather than another restricted development type. [5]
Tower Hamlets identifies an HMO direction taking effect on 1 January 2021, with supporting direction and mapping material. The council explains that affected proposals require a planning application and are assessed against planning policy. The map remains the appropriate way to establish whether a particular site is covered. [2]
Merton: distinguish confirmed coverage from a later announcement
Merton's council page records the earlier direction covering Colliers Wood, Cricket Green, Figges Marsh, Graveney, Lavender Fields, Longthornton and Pollards Hill, confirmed on 19 April 2023. It also describes an immediate direction introduced on 24 March 2026 for the other wards. [3]
For an address relying on the later direction, obtain the current signed instrument and formal confirmation record before assessing continuing post-September coverage. The council page's general borough-wide wording is not sufficient to establish the later direction's status for the property. [3]
Licensing is still a separate check
GOV.UK explains that a large HMO generally needs a licence where at least five occupants form more than one household and share facilities; councils may also require licences for smaller properties through additional schemes. A licence question therefore cannot be answered simply by checking whether an Article 4 direction exists. [4]
Conversely, Merton expressly distinguishes licensing from planning permission. Evidence that a property has a licence should not be treated as the planning decision for a proposed change of use. [3]
An address-level checking method
Record the proposed use, the relevant mapped area, the signed direction, its effective date and any confirmation or replacement. Then identify the operative HMO planning policies and check licensing separately. These checks should be repeated when the project is ready to proceed, because a proposal, an immediate direction and a confirmed direction are not interchangeable documents. [1][2][3]
These examples are not a complete London register. Check the current instruments for the relevant borough; an unlisted borough should not be assumed to have no HMO controls.