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The Chartered Institute of Housing is the independent voice for housing and the home of professional standards

CIH Scotland responds to consultation on HMOs


The Scottish Government has consulted on whether new categories should be added to the definition of a house in multiple occupation (HMO) to protect contract and transient workers from poor housing conditions.

Accommodation is considered to be an HMO if three or more people from three or more unrelated households are living there as their only or main residence. In these cases, landlords are required to apply for an HMO licence and ensure that the accommodation meets safety standards. It is suggested that under the current rules, some landlords who provide accommodation for workers are avoiding the licencing regime by arguing that the accommodation is not the workers’ main residence.

Transient or contract workers often have little say over where they are housed and while some landlords are avoiding the standards set by HMO licensing, workers may be at risk from overcrowding and less stringent fire safety measures.

CIH Scotland has welcomed the proposals but raised some concerns with the practicalities of the draft regulations.

Ashley Campbell, Policy and Practice Manager at CIH Scotland said:

“We welcome any proposals that intend to raise the standard of accommodation. However, the draft regulations make it clear that the rules would only apply to workers where special arrangements had been made to accommodate them and are not available to tourists or other visitors.”

“We would argue that If the accommodation is not suitable or safe for workers, it is not suitable or safe for anyone. We want to make sure that all accommodation meets basic standards regardless of tenure, who is staying there or for how long. It is also unclear how the new rules would be monitored and enforced.”



Notes to Editors

1. The Chartered Institute of Housing (CIH) is the independent voice for housing and the home of professional standards. Our goal is simple – to provide housing professionals with the advice, support and knowledge they need to be brilliant. CIH is a registered charity and not-for-profit organisation. This means that the money we make is put back into the organisation and funds the activities we carry out to support the housing sector. We have a diverse membership of people who work in both the public and private sectors, in 20 countries on five continents across the world. Further information is available at

2. Read CIH Scotland’s response to the consultation here:

3. For further information, please contact Ashley Campbell, policy and practice manager at CIH Scotland at

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