You shouLd cHeck with your council. There are two types of HMO regs - mandatory and discretionary. Under the discretionary scheme Councils have the powers to extend the HMO regs ot cover other situations.
For example, in some parts of London under the discretionary scheme a building that's been converted into flats without planning permission/which don't comply with building regs (which has happened a lot in the past in many areas and continues to happen!) can be classed as a HMO, even if part of the building is owner occupied.
http://www.haringey.gov.uk/hmo-licensing
For example, in some parts of London under the discretionary scheme a building that's been converted into flats without planning permission/which don't comply with building regs (which has happened a lot in the past in many areas and continues to happen!) can be classed as a HMO, even if part of the building is owner occupied.
http://www.haringey.gov.uk/hmo-licensing