Norwich Licensing Consultation Approved. ELA Will Challenge the Evidence.
Cabinet Says Yes. ELA Says We Fight.
On 9th September 2026, Norwich City Council's Cabinet voted to proceed with a public consultation on the introduction of discretionary property licensing schemes across Norwich's private rented sector. While this is undoubtedly a significant moment, landlords should not mistake consultation for implementation. No licensing scheme has yet been approved, and there is still time to challenge both the evidence and the assumptions behind these proposals.
The Eastern Landlords Association has always supported professional landlords, high housing standards and robust action against genuinely rogue operators. However, we remain deeply concerned that discretionary licensing is being presented as a solution to problems that existing legislation already allows councils to address.
More importantly, we believe these proposals risk harming the very people they claim to help: tenants.
What Has Been Approved?
Cabinet has approved consultation on two separate schemes.
Additional Licensing for HMOs
The Council proposes introducing a citywide Additional Licensing scheme for smaller Houses in Multiple Occupation (HMOs) not already covered by mandatory HMO licensing requirements. The Council estimates that around 1,100 currently unlicensed HMOs would be captured by the scheme.
Selective Licensing
A second proposal would introduce Selective Licensing for privately rented properties located in four wards:
Nelson
Mile Cross
Sewell
Town Close
The Council estimates that approximately 6,300 privately rented properties would be affected by this proposal.
Combined with existing mandatory HMO licensing, the schemes would extend licensing requirements across a substantial proportion of Norwich's private rented sector.
Proposed Licensing Boundaries
Proposed Selective Licensing Area
Proposed Additional Licensing Area
The Council's Argument
The Council's proposals are based on a review of housing conditions, property management standards and wider neighbourhood impacts within Norwich's private rented sector. The evidence put forward identifies:
Approximately 20,330 privately rented properties across Norwich.
An estimated 2,286 private rented homes containing at least one serious housing hazard.
Around 470 HMOs predicted to contain at least one serious hazard.
Higher levels of fuel poverty and lower energy efficiency in parts of the city.
Concentrations of anti-social behaviour and housing complaints in specific areas.
The Council argues that discretionary licensing would allow a more proactive approach to identifying poor housing conditions and management failings, rather than relying heavily on complaints and enforcement action after problems have already occurred.
Proposed Fees
If implemented, licensing will come at a cost.
Additional Licensing
Selective Licensing
Under the current proposals, standard Additional Licensing applications would attract a fee of £1,000 per property, while Selective Licensing applications would attract a fee of £700 per property, with limited discounts available for accredited landlords and energy-efficient properties.
For landlords with multiple properties, these costs quickly become substantial.
The Questions Nobody Seems Keen to Answer
At first glance, licensing sounds attractive. Everyone wants good quality housing and effective management standards.
But the real question is not whether poor housing exists.
The real question is whether licensing is the best way to deal with it.
The Council already has extensive legal powers available to tackle poor housing conditions. Improvement Notices, Prohibition Orders, Civil Penalties, Rent Repayment Orders, prosecutions and mandatory HMO licensing already exist. The Council itself acknowledges that these powers are already being used throughout the city.
If existing powers are not delivering the desired outcomes, landlords are entitled to ask whether the answer is another licensing scheme or better use of the powers already available.
The ELA believes this is a legitimate question and one that deserves proper consideration during the consultation.
Why We Believe Tenants Could Lose Out
The Council's own Equality Impact Assessment acknowledges that discretionary licensing carries potential risks, including higher costs for landlords, the possibility of costs being passed on through rents and the possibility of landlords choosing to leave the sector altogether.
Those concerns should not be dismissed lightly.
Landlords are already facing:
Rising borrowing costs.
Increasing compliance requirements.
Significant legislative changes.
Future energy efficiency obligations.
Growing taxation and regulatory burdens.
Adding another licensing regime increases costs still further.
The reality is simple.
When the cost of providing rental accommodation increases, landlords have limited options. Some absorb the costs. Some increase rents. Some postpone investment. Some sell up altogether.
When good landlords leave the market, the supply of rented homes falls.
When supply falls and demand remains high, tenants face fewer choices and greater competition for available homes.
In our view, any proposal that risks reducing housing supply should be examined very carefully before being introduced.
Concerns About the Evidence
Another area that deserves scrutiny is the evidence itself.
Much of the Council's case relies on modelling and predictive analysis rather than physical inspection of every property identified as containing a hazard. The commissioned report explains that statistical modelling and machine-learning techniques were used to predict the likelihood of hazards and hidden HMOs across the city.
However, when schemes that could affect thousands of landlords and tenants are being considered, it is entirely reasonable to ask questions about methodology, assumptions, margins of error and whether the proposals are proportionate to the problems identified.
The consultation process should provide an opportunity for these questions to be properly explored.
What Happens Next?
The most important thing landlords need to understand is that this is not a done deal.
The Cabinet decision authorises consultation only. Before any designation can be introduced, the Council must conduct a statutory consultation lasting at least ten weeks and then consider the responses received before returning with final recommendations.
This means landlords, agents, tenants and residents still have an opportunity to influence the outcome.
The Eastern Landlords Association will be reviewing the proposals in detail, examining the evidence base and preparing a comprehensive response on behalf of members.
We support better housing.
We support professional standards.
We support action against rogue landlords.
But we do not support costly regulation simply for the sake of regulation, particularly where there is a real danger that tenants will end up paying the price through reduced supply, reduced choice and higher rents.
We know that many of our members have valuable experience, local knowledge and evidence that could help challenge these proposals. If you would like to assist the ELA's Selective Licensing team in reviewing the consultation, analysing the evidence base or preparing responses, please contact the office.
Likewise, if you come across information, research, examples from other licensing schemes, case studies, data, media coverage or anything else that may assist our campaign, please let us know. Even small pieces of information can help us build a stronger case and ensure that landlords' concerns are properly represented throughout the consultation process.
This will only be effective if landlords work together. The more evidence, experience and local knowledge we can bring to the table, the stronger our collective voice will be.
We will keep members updated throughout the consultation process and will provide details of when and how landlords can submit their views on the proposals. We will also share information on any public meetings, online consultation events, stakeholder workshops or engagement sessions organised by the Council so that landlords have every opportunity to make their voices heard. The Council has indicated that consultation is expected to include a range of online and in-person engagement activities as part of the statutory consultation process.
If landlords do not engage, others will shape the future of the sector on their behalf.
The Council may have voted to consult. The ELA intends to ensure landlords are represented, informed and heard at every stage of the process.
Further Reading
The full Council documents can be found below:
Discretionary Property Licensing of Private Rented Sector Housing (Cabinet Report)
Summary Evidence for Consultation 2026
Housing Stock Condition and Stressors Report
Equality Impact Assessment
Proposed Licensing Conditions
Proposed Licensing Fees
Proposed Selective Licensing Boundaries
Proposed Additional Licensing Boundaries
HHSRS Hazards Summary
All documents are available via Norwich City Council's committee and consultation webpages.
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