additional criterion that the building was three or more storeys. Landlords of large HMOs must apply for a licence and must comply with certain standards and obligations. HMOs do not need to be licensed if they are managed or owned by a housing association or co-operative, a council, a further education institute or student housing provider, a health service or a police or fire authority. Where an Article 4 direction has been applied by a local authority, planning permission is required for the change of use of a dwelling house to HMO accommodation in the area designated. This is usually to protect the housing mix in particular areas of a city; for example in Newcastle upon Tyne article 4 directives have come into force in parts of Heaton, Jesmond, South Gosforth, Sandyford and Spital Tongues. Local authorities Local authorities, manage and enforce the licensing of HMOs in England and Wales. Depending on the region of the authority, they have some or all of the following powers, to vary: the minimum size of a property requiring a licence the licence fee and the conditions of the licence. Penalties in England and Wales Failure to apply for or comply with the terms of a licence for an HMO constitutes a criminal offence. Tenants may be able to recover up to 12 months' rent from an unlicensed HMO landlord. Since the Housing and Planning Act 2016 (HaPA), tenants can make a Rent Repayment Order (RRO) application directly against the landlord and without waiting for the council to prosecute first (the situation under the Housing Act 2004 (HA)). Some tenants have been successful in recovering rent from landlords of unlicensed HMOs. Northern Ireland Northern Ireland is a separate legal jurisdiction within the UK and all HMOs must be registered and must comply with certain standards and obligations. In Northern ireland a property is an HMO if three or more people live in it, these people form at least three separate families or households and at least one person is paying some form of rent to live in the property. New regulations came in to force in April 2019 and a new licensing scheme managed by local councils has replaced the centralised registration scheme. Landlords must pass a fit and proper persons test, fixed penalties have been introduced HMO managers have to adhere to a Code of Practice. Scotland Scotland is a separate legal jurisdiction