Medway Council is moving closer to making its HMO Article 4 Direction permanent across seven wards, despite attracting only four consultation responses during the formal feedback period.
Cabinet decision could lock in planning checks
The proposed direction would remove permitted development rights for smaller HMOs in parts of Chatham, Gillingham and Strood, meaning landlords would need planning permission before converting a property from C3 use to a small HMO. According to reporting on the consultation outcome, two responses backed the move and two objected, with critics arguing the policy should be applied street by street rather than ward wide.
For landlords, that matters because Article 4 shifts a conversion from an operational decision into a planning risk. In areas where local authorities are tightening HMO policy, a property that once looked straightforward on paper can suddenly involve added cost, delay and uncertainty.
Landlords already dealing with licensing pressure can see the broader direction of travel in Harrow’s latest compliance deadline and Telford’s own low-response Article 4 consultation. Medway’s next step sits firmly in that same pattern.
Low response does not mean low impact
Council officers have reportedly rejected the idea of a narrower approach, arguing that a more targeted policy would simply displace HMO concentrations into nearby streets. The underlying legal framework for Article 4 directions is set out in Medway Council’s published Article 4 legal notice.
That argument will not reassure every landlord. A low consultation turnout can still produce a high operational impact once a direction is in force, especially for investors relying on smaller shared houses to make numbers work. Planning approval can become the deciding factor on whether a purchase still stacks up.
This follows Landlord Knowledge’s report on Gloucester’s planned HMO licensing and Article 4 controls, which showed councils using planning and licensing together to limit concentrations of shared housing. Medway’s proposals suggest that approach is spreading rather than slowing.
What this means for landlords
- If you’re buying in Medway: check whether a target property sits inside one of the affected wards before assuming HMO conversion rights still apply.
- Watch for: the 5 May cabinet decision, which will show whether councillors back a permanent direction.
- Bottom line: landlords using HMO strategy in tighter local markets need planning due diligence earlier in the deal.
Editor’s view
Article 4 policy keeps spreading because it gives councils a cleaner way to control HMO growth without waiting for wider national reform. For landlords, the lesson is simple: planning risk now sits much closer to the centre of HMO investing than it did a few years ago.
Author: Editorial Team – UK landlord & buy-to-let news, policy, and finance
Published: 29 April 2026
Sources: Medway Council Article 4 legal notice
Related reading: Telford confirms HMO controls despite low consultation response
