Scope: England, with a note on Wales at the end. Licence conditions are set council by council, so this explains the power and its limits rather than promising what any one scheme will say.
Most landlords meet "training" as a discount — take an accredited course, pay less for your licence. A smaller number of councils do something different: they make the course a condition of the licence itself. Miss it and you are not a landlord who saved less money, you are a landlord in breach of a licence condition, which is a criminal offence.
Bolton is the reason this is worth writing about now.
Bolton, 17 August 2026
Bolton's Cabinet approved a borough-wide additional HMO licensing scheme. The shape of it:
- Every ward. Not a designated pocket — the whole borough.
- Small HMOs under section 254 of the Housing Act 2004: three or four people forming two or more households. These are the properties that fall below the national mandatory threshold of five.
- Section 257 converted blocks — buildings converted into self-contained flats where the conversion did not meet the 1991 Building Regulations and fewer than two-thirds are owner-occupied.
- Around 720 HMOs expected to be caught.
- £1,211 for a five-year licence, split Part A £760 on application and Part B £451 before issue.
- Fully operational early 2027.
- Licence conditions include a training requirement and fit-and-proper duties.
- Enforcement up to £40,000 as a civil penalty.
One caveat, and we would rather state it than let you find out later: the exact wording of the final conditions is per the council's published conditions document, and the adopted Cabinet text was still pending when this was written. What course counts, how long you have, and whether it binds the licence holder or the manager are all questions the conditions document answers and a committee report does not. Read it before you book anything.
Where the power comes from
A council does not invent licence conditions. Two sections carry them:
- Section 67 of the Housing Act 2004 — conditions on an HMO licence, mandatory and additional.
- Section 90 — the equivalent for a Part 3 selective licence.
Both are broadly drawn. A council may impose conditions it considers appropriate for regulating the management, use and occupation of the house, and its condition and contents. That is wide enough to reach training, and several councils have read it that way.
The limit that actually bites: s.67(1A)
The power is not unbounded. Section 67(1A) requires conditions to relate to matters within the licence holder's control. That is the line worth knowing, because it is the line a challenge runs along.
A condition requiring you to complete a course is squarely within your control — you can book it and sit it. A condition requiring an outcome you cannot deliver is a different matter. The distinction is not academic: it is the reason conditions tend to be written as "the licence holder shall complete…" rather than as a guarantee about someone else's behaviour.
Fit and proper is a separate test, and it is not training
Sections 66 (HMOs) and 89 (selective) require the council to be satisfied the licence holder is a fit and proper person. Landlords routinely conflate this with training. They are different: fit and proper is about who you are and what you have done, and training is about what you have learned.
On what a council may look at, Hussain v Waltham Forest LBC [2020] EWCA Civ 1539 matters. The Court of Appeal held that where a conviction is spent, the underlying conduct may still be considered in the fit-and-proper assessment. A spent conviction does not erase the facts behind it for these purposes. If you are relying on rehabilitation periods to keep something out of a licensing decision, that is the case to read first.
Requirements and incentives are not the same thing
This is where most writing on the subject goes wrong, so we are keeping them apart deliberately.
A genuine requirement
Nottingham imposes a real mandatory training condition: complete an approved course within twelve months of the licence being granted. It is a condition of the licence. Not doing it is a breach, and breach of a licence condition is an offence under section 72(3) carrying an unlimited fine on conviction or a civil penalty of up to £40,000 as an alternative — see the three ways an HMO licence goes criminal.
Bolton's new scheme carries a training requirement in the same family, subject to the conditions document.
An incentive, which most schemes actually are
Far more councils discount the fee for accreditation and require nothing:
- LLAS — the London Landlord Accreditation Scheme, recognised for fee discounts across a large number of London boroughs.
- DASH and the Unipol Nottingham Standard — recognised in and around Nottingham.
- NRLA accreditation, recognised by various councils.
The practical difference is what happens when you do nothing. Under an incentive you pay the full fee, which is annoying. Under a requirement you are in breach of a licence condition, which is an offence. Do not let a blog post about "landlord training requirements" flatten those into one thing — check whether your own council's conditions say shall or say discount.
What to actually do
- Read the conditions document, not the committee report. The Cabinet paper tells you a scheme is coming. The conditions tell you what you must do, and only the conditions are enforceable against you.
- Diarise from the grant date, not the application date. A twelve-month training condition runs from when the licence is granted. Applications can sit for months, and the clock people miss is the one that started after they had stopped thinking about it.
- Check who the condition binds. Licence holder, manager, or both. Where an agent manages the property, a condition on the licence holder does not become the agent's problem because the agent does the day-to-day work.
- Keep the certificate with the licence. Compliance you cannot evidence is compliance you may have to argue about at renewal.
- Check whether an existing accreditation already satisfies it. Where a council recognises a scheme for fee discounts it will often accept the same course against a training condition — but that is a question for the council, not an assumption.
Wales is a different regime entirely
Everything above is England. In Wales, training is nationally mandatory and has nothing to do with individual licence conditions: under the Housing (Wales) Act 2014, a landlord who carries out letting or management activities must be licensed through Rent Smart Wales, and that licence requires completing approved training. A Welsh landlord asking "does my council require training?" is asking the wrong question — the requirement is national and applies wherever the property is.
The wider direction
Training conditions are still the minority. But borough-wide additional licensing is spreading — Bolton is one of a run of 2025-26 designations — and conditions attached to those schemes reach every small HMO in a borough at once rather than a handful of streets. A landlord with properties in several boroughs should expect the conditions to differ between them, because they are set locally and there is no national template.
The related point, easy to miss: a licence from one council never covers a property in another, and neither do its conditions. Check each council separately.
Check your own council. Our council licensing pages record each scheme, its fees in the council's own wording, and the dates it runs — each with the page and day we read it.
Information tool, not legal advice.