With less than four months to go before Simpler Recycling is rolled out to homes across England, concerns are growing that student HMO landlords are not ready for the overhaul.
There are approximately 472,823 Houses of Multiple Occupancy nationwide, housing 1.5 million people, and waste specialists say many landlords and agents need to understand the changes.
From 31st March 2026, councils must deliver a consistent recycling service in every area.
The reforms require four waste streams to be collected: general refuse, food waste which may be combined with garden material, paper and card, plus other dry recyclables.
For most properties, that means four separate containers.
Failure for the tenants in an HMO to comply could see the landlord being handed a £5,000 fine and, potentially, a criminal conviction.
Waste rules cause uncertainty
Similar rules already apply to businesses and extending them to cover mixed-use buildings and multi-tenant homes is creating uncertainty, businesswaste.co.uk.
Student lets, blocks of flats and combined residential and commercial premises that were not previously covered can now fall under the law.
But the firm warns that responsibility for compliance in shared housing is not always clear cut.
Tenants are generally expected to sort waste correctly day to day, yet HMO licensing conditions often place wider duties on owners and managers.
These can include providing sufficient bin storage, supplying the correct containers, issuing clear instructions and arranging suitable collection schedules.
In some districts, a written waste management plan is also required.
HMOs are a grey area
Mark Hall, the firm's landlord waste expert, said: "HMOs and larger rental properties with multiple tenants can fall into a bit of a grey area when it comes to waste, and it's easy to see why managers and landlords may get confused.
"Failing to comply can not only lead to costly fines but could also result in the loss of licenses.
"If you are ever unsure of what your obligations are, speak to an expert."
He added: "An audit of your premises is the best way to ensure you are meeting the needs of your tenants, complying with government guidelines and protecting yourself from any stress as a business owner."
Will councils collect?
Also, waste collections vary between local authorities, and some will continue including HMOs within their standard household collections.
Other councils look set to encourage or insist on the use of licensed private contractors instead.
Landlords who previously relied on council services may now find there are capacity limits or they may be hit with extra charges pushing them towards commercial options.
Failure to meet waste requirements usually starts with a council-issued compliance notice.
Landlords face a rubbish fine
If problems persist, fixed penalty notices of up to £5,000 can follow, alongside the risk of criminal prosecution.
Poorly managed refuse can also raise wider licensing issues where overflowing bins, contamination, pests or odours are reported.
Businesswaste is advising landlords and agents to review their current waste arrangements and assess whether bin numbers and sizes are adequate.
They should also confirm collection frequency and check which containers will be supplied locally.
Clear communication with tenants about new separation rules is also seen as critical.
Student landlords must prepare
Simon Thompson, the managing director of Accommodation for Students, said: "For student landlords, the message is simple.
"Do not assume HMOs will be treated like standard family homes once Simpler Recycling comes into force.
"Student HMOs already generate high volumes of waste, and with four separate streams, poor planning could quickly become a compliance problem rather than a housekeeping issue."
He added: "Local authorities will look to the licence holder when bins overflow or contamination occurs.
"For landlords who prepare now and communicate clearly with student tenants will avoid unnecessary cost and stress later."
