Commentary on Sections Part 3: Enforcement of Licensing Requirements Section 30: Unlicensed HMO
This section creates a number of criminal offences relating to HMO licensing. An owner of a licensable HMO without a licence is committing an offence (unless the owner has a reasonable excuse).  A person who acts as an agent for an HMO which is not licensed also commits an offence.  And where the owner of an unlicensed HMO instructs an agent to act in relation to that house, the owner commits an offence.