Accord Buy to Let HMO Requirements: Licensing Update on 14 October 2026

Accord Buy to Let updated its answer to section 6.6.4a of the UK Finance Lenders’ Handbook on 14 October 2026, addressing houses in multiple occupation and property licensing.

The wording distinguishes properties requiring mandatory HMO licensing from those subject to additional, selective or other discretionary licensing. It also explains the lender’s requirements where a licence cannot be obtained before completion in specified circumstances.

For conveyancers, the practical task is to establish which licensing regime applies, whether the property meets Accord’s requirements and what must happen before the mortgage completes.

Accord Buy to Let’s new wording at section 6.6.4a

The relevant Handbook question asks:

“Does the lender lend where the property comes within the definition of a house in multiple occupation? If yes, what are your requirements?”

The updated answer states:

We do not lend where a mandatory licence for the property must be obtained from the Local Authority.

We do lend where the property is or will be (i) a house in multiple occupation which does not require any licence or (ii) a house, whether or not a house in multiple occupation, which is subject to additional licensing, selective licensing or any other form of discretionary licensing which is not mandatory licensing. In all cases where a licence for the property is required, you must ensure that the licence is in place on or before completion of the loan. Where such licence cannot be obtained on or prior to completion because the property is being purchased by the borrower, or the deadline for applying for a licence has not yet expired, our legal advisor must ensure that the borrower is fully aware of their obligation as a condition of the mortgage offer to apply for the required licence promptly following completion and comply with all relevant licensing requirements.

What does the licensing distinction mean?

The answer separates three broad situations:

Property position	Position under the quoted wording
A property requiring mandatory HMO licensing	Accord states that it does not lend.
An HMO that does not require a licence	Potentially acceptable, subject to the remaining lending requirements and mortgage instructions.
A house subject to additional, selective or another discretionary licensing scheme	Potentially acceptable, subject to the licensing conditions and remaining mortgage instructions.

The timing provisions do not override the opening exclusion for properties requiring mandatory licensing. Obtaining a mandatory HMO licence does not, by itself, make such a property acceptable under this answer.

“Discretionary licensing” does not mean the borrower can choose whether to comply

The terminology needs careful explanation to clients. A licensing scheme described as discretionary can still impose a legal obligation on a landlord whose property falls within it.

The conveyancer should establish the applicable local authority scheme, its geographical coverage, commencement date and relevant conditions. The assessment should address both the existing occupation and the borrower’s intended use.

A general statement that the property is “not a licensed HMO” does not answer every relevant question. A property outside mandatory HMO licensing may still fall within another licensing scheme.

The starting requirement: the licence must be in place by completion

For an otherwise acceptable property requiring a licence, Accord’s stated starting position is that the licence must be in place on or before completion of the loan.

The file should therefore establish what licence is required and retain appropriate evidence of its status. Where relevant, check the licence holder, authorised occupation, conditions and expiry date.

Do not assume that a seller’s licence will cover the buyer’s arrangements. Establish what the local authority requires when ownership or management changes.

When does the wording address an application after completion?

The answer identifies circumstances in which the required licence cannot be obtained before completion:

• Because the borrower is purchasing the property; or
• Because the deadline for applying for a licence has not yet expired.

In those circumstances, Accord requires its legal adviser to ensure that the borrower understands the mortgage-offer obligation to apply promptly after completion and comply with the relevant licensing requirements.

This should be addressed expressly in the advice to the borrower, with a record of the circumstances relied on and the information provided.

The wording is not a general permission to complete whenever a licence is outstanding. An unexplained delay, missing information or failure to apply should not automatically be treated as falling within the stated circumstances.

The lender’s instruction also does not displace the borrower’s statutory duties. Establish what the law permits at the relevant stage and seek clarification where the position is uncertain.

Check the remaining Accord Buy to Let requirements

Licensing is one part of the assessment. Accord’s separately published HMO lending criteria also address the number of occupiers and the tenancy arrangement.

The quoted Handbook answer should therefore be read alongside the mortgage offer, special conditions and other applicable instructions. It should not be treated as unrestricted acceptance of every property outside mandatory licensing.

Planning status requires separate consideration too. A property licence does not establish that the intended use has the necessary planning permission.

A practical checklist for live Accord Buy to Let files

For a transaction involving shared occupation or a locally licensed property, consider the following:

1. Confirm the lender record. Use the Accord Buy to Let instructions applicable to the transaction.
2. Establish occupation. Check the existing and proposed arrangements rather than relying solely on the property’s description.
3. Identify the licensing regime. Distinguish mandatory HMO licensing from additional, selective and other schemes.
4. Check the evidence. Establish whether the necessary licence is in place and appropriate for the proposed arrangements.
5. Assess any outstanding licence. Record whether the facts fall within the circumstances described in the updated answer.
6. Advise the borrower. Explain any obligation to apply promptly after completion and comply with licensing conditions.
7. Resolve uncertainty. Obtain further instructions where the firm cannot establish compliance.

These checks should connect with the firm’s Dealing with Lenders Policy and the advice recorded for the borrower.

Our October 2026 Report on Title update also considers HMO licensing and mortgage conditions.

How does your firm identify changes to lender instructions?

This update illustrates why a procedure for monitoring lender instructions matters. A team may be familiar with a lender’s previous requirements while missing revised wording relevant to a live transaction.

LENDERmonitor Notifications monitors changes to lender instructions and emails details of the differences, helping firms identify developments requiring attention.

The practical benefit comes from routing those notifications to the right people, assessing affected matters and recording any action required.

What did Accord Buy to Let require on an earlier transaction?

A current instruction answers a different question from the wording recorded when an earlier transaction completed.

If a licensing issue emerges during a later sale, remortgage, complaint or file investigation, establish the relevant historical instructions before assessing what the conveyancer was required to do.

The Lexsure Accord Buy to Let Lender Handbook Archive holds historical lender requirements, with coverage beginning in November 2014. It provides a route to investigating the record for a specified historical date.

The historical wording must still be considered alongside the transaction documents, mortgage offer and any separate instructions received.

This article discusses the wording notified on 14 October 2026. For a live matter, check the current Handbook, mortgage offer and transaction-specific instructions. Licensing requirements depend on the property, jurisdiction and applicable local authority scheme.