The Liverpool HMO Article 4 plan concerns houses in multiple occupation (HMOs). Liverpool City Council’s Cabinet approved the plan on 13th October 2026, authorising five immediate C3-to-C4 Directions for defined pressure areas and a separate non-immediate Direction for the rest of the city, intended to take effect in October 2027. The official Cabinet decision records that approval, but it does not itself make the Directions operative.
I would keep the stage distinction firmly in mind. Cabinet approval is permission to proceed, not proof that the legal instruments have been made or that any new boundary is in force. I have not found signed Directions or statutory notices, so the five immediate controls and the exact future commencement date remain unverified.
For a newcomer to the story, an Article 4 Direction can remove a national right that normally allows a house in Use Class C3 to change to a small HMO in Use Class C4 without a planning application. Once a valid Liverpool Direction is operative, that change will need planning permission inside its mapped area. It will not ban HMOs or retrospectively make an existing lawful HMO unlawful.
Liverpool HMO Article 4 plan is citywide in two stages
Cabinet has approved the Liverpool HMO Article 4 plan in two stages: five immediate Directions for defined areas and a separate non-immediate Direction for the remainder of the city:
- Kirkdale West and East, Everton North, County, Walton, Orrell Park and part of Fazakerley North and West
- Part of Tuebrook Larkhill
- Old Swan and part of Stoneycroft
- Penny Lane and part of Calderstones
- St Michaels, Sefton Park and part of Festival Gardens
These five immediate areas are only the first stage. Liverpool’s Cabinet report also recommends a separate non-immediate Direction for the remainder of the city, intended to come into force in October 2027. The Cabinet report and its maps are now locally hosted by Planning Geek. These descriptions are not a substitute for a boundary map. Cabinet has agreed the Liverpool HMO Article 4 proposal, but the formal Directions and their maps will matter: street names and ward labels can be an imprecise guide to whether a particular property falls within the boundary.
The five groups would add to Liverpool’s existing HMO controls. The Council’s current HMO planning guidance says planning permission is already required for a change to a small HMO of three or more people within the existing Article 4 area. The proposed extensions have not yet been incorporated into that guidance.
Why the Council wants to widen the boundary
The Council says HMOs account for between 3% and 4.6% of Liverpool’s housing stock. Its comparison of growth inside and outside the current boundary is the key reason for the proposed extensions: small HMOs increased by about 15% within the existing area over three years, against about 57% in the rest of the city.
That difference is consistent with growth moving more quickly beyond the controlled area, but the headline figures alone do not establish that the existing Direction caused the increase elsewhere. The Cabinet report and supporting evidence will be important for understanding how the Council selected these five locations, what it counted as a small HMO and how it assessed concentrations and displacement.
The Council also says its survey, carried out during August and early September, received 1,070 responses. Of those respondents, 80.7% supported extending Article 4 controls. That is a substantial expression of support among people who took part, although it should not be read as a representative vote of every Liverpool resident unless the survey method and sample support that conclusion.
The Council’s stated case is to give planners a chance to assess the location of new HMOs, including the concentration of existing accommodation, loss of family housing, effects on neighbourhood character and possible pressure on parking, waste services and community facilities.
What the Liverpool HMO Article 4 plan would change
In England, the Town and Country Planning (General Permitted Development) (England) Order 2015 grants the relevant permitted development right under Schedule 2, Part 3, Class L(b). In broad terms, this allows a change from a dwellinghouse in Use Class C3 to a small HMO in Use Class C4, normally housing between three and six unrelated people who share basic facilities, without a planning application.
The Liverpool HMO Article 4 proposal would withdraw that permitted development right within a defined area. If a valid Direction covering one of the proposed locations is made and takes effect, a qualifying C3-to-C4 change there would need planning permission. The Direction would not ban HMOs. It would require the planning merits of a proposal to be assessed against relevant policy and site-specific considerations.
Nor would a new Direction automatically make an existing lawful HMO unlawful. It removes a permitted development route for development within its scope. The starting point for any particular property would still depend on its planning history, existing use, the precise Direction and whether the relevant change of use has already taken place.
The Article 4 planning test is also separate from HMO licensing. A landlord may need to consider both regimes, but a licence does not itself grant planning permission. Planning Geek’s guides explain Class L, Use Class C4 and the HMO Article 4 map.
Why “immediate” matters, and what it does not mean
The Council proposes immediate effect only for the five pressure areas. The separate Direction for the remainder of the city is non-immediate and is intended to come into force in October 2027. An immediate Direction can remove the specified permitted development right from the date it comes into force, rather than waiting for a later date after the usual lead-in period associated with a non-immediate Direction.
But this is not simply a way to skip the statutory process. Government guidance says immediate Directions covering development under Parts 1 to 4 or 11 of the GPDO may be made where the development presents an immediate threat to local amenity or prejudices the proper planning of an area, and the authority must already have begun consultation towards a non-immediate Direction.
The Cabinet papers now explain how Liverpool considers those tests and the earlier city-wide survey in this case. Government guidance on Article 4 Directions sets out the framework.
However, Cabinet approval is not itself the same thing as a formally made Direction. The legal instrument must be made, publicised and brought into force in accordance with the General Permitted Development Order. The actual instrument and notice will establish the operative date and mapped boundary. The Cabinet report gives the intended timetable, but the sealed Directions and notices will be decisive.
An immediate Direction is also time-limited unless confirmed. The local planning authority must confirm it within six months of the date it comes into force if it is to remain in force. The Cabinet report expects consultation on both the immediate and non-immediate Directions during October and November 2026, with Cabinet due to consider confirmation in December. The final notices will settle the statutory dates.
We therefore need to distinguish three events: Cabinet’s approval on 13th October, the Council formally making and bringing each Direction into force, and the later decision whether to confirm it. The first event has happened. Until the second is evidenced by the legal instruments and notices, the proposed extension is not verified as operative. If made, each Direction and notice will settle its date and exact mapped boundary.
Compensation is possible, but not automatic
Immediate withdrawal of a permitted development right can raise a compensation issue. Class L of Part 3 is prescribed by regulation 2 of the Town and Country Planning (Compensation) (England) Regulations 2015. For that prescribed right, section 108(2A) sets a 12-month window beginning on the date the Direction takes effect for a qualifying planning application to be made. A route to excluding compensation liability can apply where the authority gives the prescribed 12 months’ notice before the withdrawal takes effect; an immediate Direction does not provide that lead-in.
Sections 107 and 108 of the Town and Country Planning Act 1990 and the Town and Country Planning (Compensation) (England) Regulations 2015 govern the relevant framework. The Government’s planning guidance explains that an authority may face liability where, after an Article 4 Direction takes effect, a qualifying planning application is made and permission is refused or granted subject to conditions in circumstances where the development would otherwise have been permitted.
That does not mean every owner or landlord affected by an immediate Direction is automatically entitled to compensation. The statutory tests, the type of right withdrawn, timing, notice and the outcome of any planning application all matter. Liverpool’s Cabinet report says the precise financial impact cannot yet be reliably quantified and expressly refers to monitoring emerging compensation liabilities. Planning Geek has a practical guide to Article 4 compensation claims.
What landlords, buyers and residents should do now
For now, owners and purchasers anywhere outside Liverpool’s existing Article 4 controls should not assume that the Liverpool HMO Article 4 plan is already in force. Equally, a purchase or conversion decision should not rely on the Cabinet decision alone. Check the current Article 4 map and planning history, then look for the Council’s signed Direction and statutory notice before treating a new boundary as operative.
Following Cabinet approval, the next documents to look for are the actual Directions, their mapped boundaries, the statutory notices, consultation dates and the six-month confirmation deadline. Those documents will answer whether a particular address is covered, when the right is withdrawn and how representations can be made.
Councillor Nick Small, Cabinet Member for Growth and Economy, said the proposals would give the Council “greater oversight of new HMOs” and help protect family housing. Councillor Hetty Wood, Cabinet Member for Housing, said HMOs “provide an important housing option for many people” and would continue to have a place in the city. Both comments reflect the stated balance: the Council is not proposing to exclude shared housing, but to scrutinise where new small HMOs are created.
The key question after the 13th October approval is when the Council formally makes and publicises the Directions, and whether the final maps and notices provide a clear transition. The Liverpool HMO Article 4 plan has passed its Cabinet stage, but the new controls should not be treated as a change to the planning rules on the ground until the relevant legal instruments are made and brought into force.
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