Why I’m backing ELA’s challenge to Norwich’s licensing plans

I have prepared a detailed report to help the Eastern Landlords Association scrutinise Norwich City Council’s proposed licensing schemes. Having worked through the supporting papers, I believe there are specific questions the council needs to answer before requiring thousands of landlords to pay for a new licensing regime.

Norfolk matters to me personally. My family, property interests and the roots of Property118 are there, so I am keen to support an initiative that gives local landlords a properly informed voice.

According to ELA’s account of the Cabinet decision, Norwich approved consultation on 9 September 2026. That was approval to consult, and the schemes themselves have yet to receive final approval.

The proposals include selective licensing for around 6,300 privately rented properties in Nelson, Mile Cross, Sewell and Town Close, alongside a separate citywide additional licensing scheme covering around 1,100 HMOs. The proposed standard fees are £700 and £1,000 respectively, with licences normally lasting up to five years. The council’s proposed fee document, available through ELA, provides for payment in two stages and some discounts.

Those charges deserve scrutiny, together with the time and administration involved. Landlords and tenants should be able to understand what improvement the scheme is expected to deliver, how that improvement will be measured and why the chosen approach is justified.

The evidence needs to withstand examination. One example in my review concerns the comparison between housing hazards in Norwich and the national picture.

The council’s stock condition report compares a national figure of 10% for privately rented homes with Category 1 hazards against a Norwich estimate of 11.2% that includes both Category 1 and higher-scoring Category 2 hazards. Those figures measure different things. The comparison appears on page 39 of the stock condition report in ELA’s council document collection.

There is also an apparent mismatch in the anti-social behaviour figures. For Nelson, the narrative describes 160 ASB cases, while Table 8 of the stock report lists 160 HMO notices and nine HMO ASB incidents. Norwich should explain the source of the narrative figure and whether the categories have been confused.

These HMO figures also need to be distinguished from the evidence supporting selective licensing of other rented homes. A discrepancy deserves an answer, but its effect on the justification for each scheme must be established.

The law requires more than a worthwhile objective. Under section 81 of the Housing Act 2004, a council must consider other available ways of achieving its objectives and consider that designation will significantly assist. Norwich’s papers do discuss alternatives; the question is whether the comparison adequately explains the additional benefit licensing would provide.

I would like to see a clear comparison with a properly resourced programme of targeted inspections, enforcement against persistent offenders, landlord education and coordinated work on anti-social behaviour. What would each approach achieve, what would it cost, and how would tenants benefit?

The proposed licence conditions also merit examination. In Brown v Hyndburn Borough Council [2018] EWCA Civ 242, the Court of Appeal identified limits on using general selective licensing powers to regulate property condition. That provides a reason to question the breadth of Norwich’s proposed general hazard condition, while recognising that specific statutory safety requirements continue to apply.

My report sets out the arguments, their limitations and the further evidence needed. It also explains consultation, information requests, councillor scrutiny and the circumstances in which a court challenge might become appropriate.

The immediate opportunity is to put precise questions to Norwich, seek corrections where necessary and test whether the proposals remain justified. The council can correct its evidence and still reach a lawful decision; our objections need to show why any unresolved problems matter to that decision.

Local experience can make this work stronger. ELA is inviting help from people with relevant evidence, experience of other licensing schemes and practical knowledge of the rental market. Property118 can help bring that invitation to a wider audience and contribute research to support an informed response.

If you own or manage affected properties, useful material could include inspection histories, records of problems already resolved, experience of existing enforcement and evidence about the likely effect on your business and tenants. Please keep tenants’ personal information private and distinguish documented facts from predictions.

You can read ELA’s statement and the council papers here, or contact ELA directly if you can contribute. Its website also provides information about membership and its wider work supporting landlords.

Property118 was founded to facilitate the sharing of best practice within the UK private rented sector. Bringing together local knowledge, careful research and a clear public voice is a practical way to put that purpose to work.