The Housing Act 2004 gives local authorities the power to impose additional licensing on HMOs beyond the mandatory regime. Local authorities can extend licensing to include all HMOs in an area which currently excluded from compulsory licensing.
Additional licencing is becoming more and more common as local authorities can then enforce licensing conditions on much smaller properties. A local authority does not need government approval to bring in additional licencing, just a 10-week consultation period.
This type of licencing can pose the highest risk to landlords as they might now realise that a smaller HMO requires a licence. Have the right letting agent to keep you compliant is highly recommended.
Currently no additional licencing is in place by Plymouth City Council.