A close relative has been living in a student house-share for the past year on a shorthold tenancy agreement. It ends soon and the tenants are moving out, and another group of students will be moving in. The house had an HMO license at the beginning of the tenancy, but it expired a few months ago. We know this because the local authority sent the tenants a letter to inform them. The letter advised them of their rights, said they had requested proof from the landlord that an HMO renewal was no longer needed, and also included information about how to apply for rent repayment order
The landlord advertises his properties directly to tenants, and according to the HMO registry the HMOs for his other two properties in the same block have expired too - one of them recently, the other more than a year ago. One is occupied by students and the other is currently being advertised at students.
(For context - the landlord has always seemed inexperienced and rather rude - he inherited the properties, so although they've been in his family for years, he has only been managing them himself for a couple of years, and doesn't like spending money on them, so not renewing the HMOs fits with a pattern of behaviour).
My questions are:
What level of "proof" do local authorities request from landlords that renewal isn't needed? They can obviously see from the council tax records who is living there.
Do local authorities rely on people applying for RROs as a deterrent, instead of prosecuting unlicensed landlords?
If my relative and his flatmates apply for a RRO for the last few months, will the landlord just be allowed to pay up then continue operating? What, if anything, will happen to his existing tenants?