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Unlicensed HMO (Housing Act 2004 s.72) Rent Repayment Order (RRO) & Section 44 Precedent Index

Housing Act 2004 section 72(1) control or management of an unlicensed House in Multiple Occupation (mandatory or additional HMO licensing): 159 real GOV.UK First-tier Tribunal (Property Chamber) RRO rulings indexed with exact £ claimed, £ awarded, % award, and s.44 mitigation factors.

Download Unlicensed HMO (Housing Act 2004 s.72) Precedent Pack (CSV) Query JSON API Interactive Section 44 Calculator
Indexed GOV.UK Rulings
159
Verified Direct Awards
106
Median Tribunal Award %
60%
Award % Range
2.3% – 100%
Median Direct Award (£)
£3,977.72
Total RROs Awarded (£)
£705,552.05

Section 44 Statutory Deduction & Mitigation Factors Cited

financial_hardship: 140delayed_council_application: 138utilities_deducted: 135director_liability: 126universal_credit_deducted: 123good_condition: 102professional_landlord_aggravation: 69letting_agent_reliance: 68fire_safety_breach: 54tenant_conduct: 40first_offence: 35deposit_unprotected: 7s44_statutory_conduct: 3

Notable GOV.UK First-tier Tribunal Decisions (Unlicensed HMO (Housing Act 2004 s.72))

Case RefPropertyOffenceClaimedAwarded (Provenance)Judicial ExtractSource
LON/00AY/HMF/2025/0801
2026-02-25
96 Camberwell New Road, London SE5 0RS - LON/00AY/HMF/2025/0801Unlicensed HMO (s.72)£36,000.00£30,600.00 (85%) [direct]The Tribunal makes a rent repayment order in favour of the Applicants against the Respondent, in the sum of £30,600, to be paid within 28 days of the date of this decision and apportioned as follows: (a) Safia Mahmood - GOV.UK PDF
LON/00BG/HMF/2026/0022
2026-08-24
Flat 12 Trevelyan House, Morpeth Street, London E2 0PY: LON/00BG/HMF/2026/0022Unlicensed HMO (s.72)£42,316.00£29,621.20 (70%) [direct]Having taken into account all the factors set out above the Tribunal determines the Rent Repayment Order in the sum of 70% of the total rent paid after deducting the Tribunal’s estimate of £550 per year per resident as rGOV.UK PDF
CAM/33UG/HMK/2025/0601
2025-08-11
199 Sentinel House, Surrey Street, Norwich NR1 3SZ : CAM/33UG/HMK/2025/0601Unlicensed HMO (s.72)£27,700.00£24,805.00 (90%) [direct]The application for a rent repayment order succeeds against the Second Respondent, BCR Investments Ltd.GOV.UK PDF
LON/00BG/HMF/2025/0732
2026-05-07
118 Broomfield Street, Poplar, Tower Hamlets, E14 6BQ: LON/00BG/HMF/2025/0732Unlicensed HMO (s.72)£30,600.00£24,480.00 (85%) [direct]The respondent shall repay £24,480 (Twenty-Four Thousand, Four Hundred and Eighty Pounds) to the applicants by 04 June 2026.GOV.UK PDF
LON/00BH/HMG/2025/0616
2025-11-07
15 Dyson Road, London, E11 1NA: LON/00BH/HMG/2025/0616Unlicensed HMO (s.72)£23,953.00£23,953.00 (100%) [direct]The tribunal orders the Respondent to repay to the Applicants the sum of £7,185.GOV.UK PDF
LON/00AG/HMF/2025/0607
2025-09-04
Maryon Mews, 21A South End Road, London NW3 2PT: LON/00AG/HMF/2025/0607Unlicensed HMO (s.72)£39,000.00£23,400.00 (60%) [direct]The Tribunal makes a rent repayment order in favour of the Applicants against the Respondents, in the sum of £23,400 (to be apportioned as set out below), to be paid within 70 days of the date of this decision: (i) The FGOV.UK PDF
LON/00AN/HMF/2025/0815
2026-04-29
39 Steventon Road, London, W12 0SU: LON/00AN/HMF/2025/0815Unlicensed HMO (s.72)£27,699.70£20,774.78 (75%) [direct]The Tribunal makes a Rent repayment order in the sum of £ for the rent paid by the applicant for the period 1 June 2023 to 31 May 2024.GOV.UK PDF
LON/00AJ/HMF/2025/0816
2026-08-10
1C Fairlawn Avenue, Ealing W4 5EF : LON/00AJ/HMF/2025/0816Unlicensed HMO (s.72)£29,125.00£17,475.00 (60%) [direct]Taking all of these matters into account the tribunal determines to award the Applicants 75% of the maximum RRO payable.GOV.UK PDF
LON/00AZ/HMF/2025/0942
2026-07-16
93B Sydenham Road, London, SE26 5EZ - LON/00AZ/HMF/2025/0942Unlicensed HMO (s.72)£22,992.00£17,244.00 (75%) [direct]decision : 16 July 2026 DECISION Decision of the tribunal (1) The Respondent, [Individual Respondent], shall pay to the Applicants the sum of £17,244.GOV.UK PDF
LON/00AP/HMF/2025/0798
2026-04-16
162A Carlingford Road, London N15 3EU: LON/00AP/HMF/2025/0798Unlicensed HMO (s.72)£26,318.70£17,101.15 (65%) [direct]The Tribunal makes a rent repayment order against the First and Second Respondents, who are therefore jointly and severally liable to pay the global sum of £17,101.GOV.UK PDF

Frequently Asked Questions (Unlicensed HMO (Housing Act 2004 s.72))

What is the average or median Rent Repayment Order (RRO) award in Unlicensed HMO (Housing Act 2004 s.72)?

Across 159 indexed GOV.UK First-tier Tribunal (Property Chamber) decisions covering Unlicensed HMO (Housing Act 2004 s.72) (106 positive RRO awards), the median Tribunal award is 60.0% of rent claimed (range 2.3% to 100.0%), with a median monetary award of £3,977.72 and £705,552.05 in total RROs awarded. Notable ruling: LON/00AY/HMF/2025/0801 (96 Camberwell New Road, London SE5 0RS, Unlicensed HMO (s.72)) — £30,600.00 (85.0%), decided 2026-02-25 by Tribunal Judge S. McKeown.

Do Property Tribunal judges deduct utilities and Universal Credit in Unlicensed HMO (Housing Act 2004 s.72) RRO claims?

Yes. Under section 44 of the Housing and Planning Act 2016, in Unlicensed HMO (Housing Act 2004 s.72) rulings utilities or council tax included in the rent were cited/deducted in 135 of 159 cases, Universal Credit or Housing Benefit was deducted under s.44(3)(b) in 123 of 159 cases, pending or delayed council licensing applications featured in 138 cases, and letting/managing agent reliance featured in 68 cases.

How does the 1 May 2026 Renters' Rights Act 24-month RRO cap affect Unlicensed HMO (Housing Act 2004 s.72) landlords and tenants?

From 1 May 2026, the Renters' Rights Act doubled the maximum Rent Repayment Order cap under the Housing and Planning Act 2016 from 12 months' rent to 24 months' rent, extended the tenant application limitation period from 12 to 24 months, and introduced personal liability for company directors where a corporate landlord commits a relevant licensing or eviction offence in Unlicensed HMO (Housing Act 2004 s.72).

Where can I download the official GOV.UK Property Tribunal RRO precedent pack for Unlicensed HMO (Housing Act 2004 s.72)?

You can search all 159 Unlicensed HMO (Housing Act 2004 s.72) decisions for free under Open Government Licence v3.0 (OGL v3.0) at https://parish.technoplusit.co.uk/rro/unlicensed-hmo-s72, export the filtered CSV precedent schedule at https://parish.technoplusit.co.uk/api/rro-search?offence_type=Unlicensed+HMO&format=csv, or query the zero-token JSON API at https://parish.technoplusit.co.uk/api/rro-search?offence_type=Unlicensed+HMO.

Licensed under the Open Government Licence v3.0 (OGL v3.0). Contains public sector information from GOV.UK Residential Property Tribunal Decisions.