In Tunbridge Wells, 2025 has brought a spike in council attention on high-turnover properties. For hosts, this has raised an important question: are holiday lets being mistakenly treated as HMOs (Houses in Multiple Occupation)? Misclassification can trigger unnecessary compliance requirements, penalties, and stress for landlords and short-term rental operators.
This blog explores why confusion is happening, what properties are most affected, how the council identifies risk, and what hosts can do to protect their listings while staying compliant.
The council monitors both HMOs and short-term lets to manage:
Housing supply
Noise and neighbour complaints
Health and safety compliance
Fire and electrical safety
Properties with high guest turnover, multiple bedrooms rented separately, or minimal host oversight are sometimes flagged as HMOs. For example:
A four-bedroom property rented to separate guests on staggered short-term bookings may appear to function like an HMO.
Properties with locks on individual bedroom doors, shared facilities, and high occupancy levels can be misinterpreted as HMOs.
Buildings in dense residential streets, such as St John’s, Pantiles, or Mount Ephraim, are more likely to draw attention.
Even when hosts are fully compliant with short-let rules, the council may issue queries to clarify whether a property falls under HMO regulations.
Tunbridge Wells Borough Council uses several indicators when reviewing properties:
Guest turnover frequency – multiple bookings within a single week can trigger a review.
Physical layout – bedrooms rented separately with locked doors may resemble HMO use.
Duration of stays – properties operating near the threshold between short-term and mid-term lets are scrutinised.
Complaints history – noise, parking, and waste complaints increase the likelihood of inspection.
Landlord oversight – low engagement or absence of a local manager can flag risk.
Properties meeting several of these criteria may receive correspondence from the council requesting clarification, even if the property is only used for legitimate short-term lets.
Confusion between HMOs and short-term lets can have practical consequences:
Requests for additional licenses or certificates
Formal inspections from planning or environmental health teams
Risk of penalties if the property is incorrectly classified
Insurance implications if a short-let is considered HMO use
Increased administrative burden for hosts needing to demonstrate compliance
Hosts who fail to respond or misunderstand the council’s queries may face escalated enforcement action.
Why it’s unique: High student and young professional population, narrow streets.
What to expect: Apartments and terraced homes with multiple bookings per week are most likely to be questioned.
Why it’s unique: Mix of residential and holiday accommodation.
What to expect: Flats above shops or in small residential blocks can trigger HMO-like reviews.
Why it’s unique: Larger Victorian houses often converted into multi-bedroom units.
What to expect: Multi-room bookings are flagged, particularly when guests use separate keys.
Maintain clear records of guest stays, including dates and duration.
Provide detailed check-in and check-out documentation to demonstrate short-term letting rather than HMO use.
Ensure shared facilities are managed safely and clearly labelled.
Respond promptly to council correspondence and keep evidence of compliance.
Consider local management support for properties in high-risk streets or buildings.
For hosts navigating these changes, Pass the Keys Tunbridge Wells, led by James, offers expertise and practical support:
Reviewing properties to assess HMO risk vs short-term let compliance
Handling all council correspondence professionally and promptly
Ensuring proper fire, safety, and legal documentation is in place
Providing hands-on management of guest bookings, check-ins, and housekeeping
Helping maintain clear records that demonstrate legitimate short-term letting
By combining regulatory insight with operational management, Pass the Keys ensures hosts remain compliant, risk-aware, and optimised for bookings — reducing the chance of misclassification while maintaining a smooth hosting experience.