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General information, not advice. Written for general guidance and drawing on external sources as well as our own experience. It isn't a personal recommendation and doesn't take account of your circumstances — full disclaimer and sources.

Block of flats with several dark, empty windows, showing vacant flats that affect the building's block insurance

Block Insurance With Empty Flats, HMOs or Short Lets

October 12, 2026

Published: 12 October 2026 | Reading time: 8 minutes | Category: Property | Author: John Miller, Miller & Partner

Last reviewed by John Miller, Director & Principal Broker — 12 October 2026
FS Register FRN 1029698 13+ years specialist commercial broking Lloyd's & specialist MGA market access Independent UK broker

A block of flats insurance policy is priced on how the flats are occupied, so empty flats and unusual occupancies need to be declared. Insurers ask how many flats are owner-occupied, let on standard tenancies, let as HMOs, used for short lets or serviced accommodation, let to local authorities or housing providers, or empty. Vacant flats raise the risk of undetected leaks, break-ins and arson, and many policies restrict cover once a flat has been empty beyond a set period. HMO flats and short lets bring higher turnover and fire risk. None of these makes a block uninsurable, but a mainstream block policy may not accept them. The fix is an accurate occupancy schedule placed with a market that accepts it. Miller & Partner places blocks with vacant units, HMO flats, short lets and housing-provider lets through Lloyd's syndicates and specialist MGAs.

Empty flats, HMOs or short lets in your block? Send us the occupancy schedule and we'll place the block with a market that accepts it.

Key facts at a glance

  1. Block insurance is priced on occupancy. The insurer needs to know how every flat is used.
  2. Vacant flats often trigger unoccupancy conditions, commonly after 30 to 60 consecutive days.
  3. HMO flats and short lets are the occupancies most often excluded or loaded.
  4. Occupancy changes during the year may need to be notified, depending on the policy wording.
  5. A large share of empty flats, such as during refurbishment, can change the whole building's terms.
  6. Specialist markets accept occupancy mixes that standard block schemes decline.

Why does occupancy matter for block insurance?

Who lives in each flat, and whether anyone does, changes the chance of a claim. Owner-occupiers and long-term tenants are seen as lower risk. Empty flats, high-turnover lets and shared houses raise the risk of leaks, fire and damage that affects the whole building.

Most block policies ask for an occupancy breakdown at inception and renewal. Getting it wrong, or letting it drift out of date, is one of the main reasons block claims are challenged. See our guide to policies voided for non-disclosure.

Which occupancies do block insurers ask about?

Owner-occupied flats, standard residential tenancies, HMO flats, short lets and serviced accommodation, lets to local authorities or housing providers including temporary accommodation, and vacant flats. Each is rated differently, and some standard schemes exclude certain types.
OccupancyWhy insurers askWhat helps
Vacant flatsUndetected leaks, break-ins, arson and squattingRegular inspections, services isolated, doors secured
HMO flatsMore occupants, more cooking and more fire riskHMO licence, fire doors, interlinked alarms. See large HMO insurance
Short lets and serviced accommodationHigh turnover, guests unfamiliar with the buildingLease consent, house rules, minimum stays. See short lets in leasehold flats
Housing provider and temporary accommodation letsTurnover and how the flats are managedManagement agreement, inspection regime, provider's own cover
Flats under refurbishmentContractors on site, hot works, empty unitsContract works cover, hot work permits, site security

What happens when a flat in the block is empty?

Many block policies apply unoccupancy conditions once a flat has been empty for a set period, often 30 to 60 consecutive days. Typical conditions include regular inspections, isolating water and gas, and securing doors. Cover for that flat may be restricted to fewer perils until it is reoccupied.

Check the unoccupancy clause in your policy and keep a simple log of empty flats and inspections. When a large share of the block is empty, for example during a refurbishment or before a sale, tell the insurer straight away, because terms for the whole building may change. See our guide to unoccupied property insurance.

Do we need to tell the insurer when occupancy changes?

It depends on the policy wording, but significant changes, such as a flat becoming an HMO, starting short lets, being let to a housing provider or standing empty, should be notified. Updating the occupancy schedule at every renewal is the minimum.

The practical difficulty is that freeholders and managing agents often don't know how individual leaseholders use their flats. Ask leaseholders to confirm their occupancy each year, and make consent for subletting, HMO use or short letting conditional on telling the managing agent.

This is where the Insurability Framework™ helps: an accurate, evidenced occupancy schedule lets us place the block on its real profile rather than a guess, which protects every leaseholder's claim.

How do I insure a block with vacant flats or mixed occupancy?

  1. Build an occupancy schedule. Each flat, how it is used, and whether it is empty.
  2. Survey the leaseholders. Confirm subletting, HMO use and short lets, and check them against the leases.
  3. Set an empty-flat routine. Inspections, services isolated and a log the insurer can see.
  4. Gather the fire evidence. Fire risk assessment for common parts, and HMO licences where relevant.
  5. Place it with the right market. A specialist broker presents the occupancy mix to underwriters who accept it.

Frequently asked questions

Usually, but often with conditions once a flat has been empty beyond a set period, commonly 30 to 60 days. Conditions may include inspections, isolating services and restricted perils. Check the unoccupancy clause.

Yes, though some standard block schemes exclude or load HMO flats. Specialist markets will accept them with evidence of licensing, fire doors and alarm systems.

Yes. Short lets increase turnover and are often excluded unless declared. The leases may also restrict them. Tell the insurer and check the lease position.

Ask the leaseholders. Annual occupancy confirmations and consent conditions for subletting help keep the schedule accurate. An out-of-date schedule is a common reason claims are challenged.

Yes. Some insurers ask specifically about lets to local authorities, housing associations or temporary accommodation providers. Declare them, together with the management and inspection arrangements.

Tell the insurer before works start. Terms for the whole building may change, and the contractors will need their own contract works and liability cover.

It can. Higher-risk occupancies can raise the block premium for everyone. Some leases allow extra costs caused by one flat's use to be recovered from that leaseholder; check the wording.

Yes. Lloyd's syndicates and specialist MGAs write blocks with vacant units, HMOs, short lets and housing-provider lets when the occupancy and controls are presented accurately.

Related guides from Miller & Partner

Whatever the mix of flats, an accurate schedule and the right market keep the whole block covered.

John Miller, Director and Principal Broker at Miller & Partner, specialist broker for blocks of flats
Written and reviewed by John Miller Director & Principal Broker, Miller & Partner Over 13 years of specialist commercial insurance experience, formerly with Brown & Brown and AXA. Places hard-to-place property risks through Lloyd's syndicates and specialist MGAs, including blocks of flats with vacant units, HMOs and mixed occupancies.
Our regulatory status Miller & Partner Limited (FRN 1029698) is an Appointed Representative of Gauntlet Risk Management Ltd (FRN 308081), which is authorised and regulated by the Financial Conduct Authority. Miller & Partner Limited is registered in England and Wales (company number 16206282) and trades from Vivian House, Roman Bridge Close, Mumbles, Swansea SA3 5BG. This article is general information, not a personal recommendation or an offer of cover. Cover is subject to insurer acceptance and the full terms, conditions and exclusions of the policy issued.
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About this article General information, not advice. Published for general guidance and drawing on external sources as well as our own experience. It is not a personal recommendation, a quotation, or an offer of cover, and it doesn't take account of your circumstances. Read more + Close −

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Our articles are compiled from a range of sources: regulators and public bodies such as the FCA, the Civil Aviation Authority, the Health and Safety Executive and Companies House; government publications and legislation; industry and trade bodies; insurer and market documentation; and published research and news reporting. Not everything stated originates from Miller & Partner. Where information comes from a third party we believe it to be accurate at the date of publication, but we haven't independently verified every external source and we don't warrant its accuracy or completeness. Where a point matters to a decision you're making, go to the original source and check it.

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Our regulatory status

Miller & Partner Ltd is an Appointed Representative of Gauntlet Risk Management Ltd, which is authorised and regulated by the Financial Conduct Authority (FRN 308081). Miller & Partner Ltd is entered on the FCA Register under reference 1029698. Registered in England and Wales, company number 16206282. Registered office: Vivian House, Roman Bridge Close, Mumbles, Swansea, SA3 5BG.

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Office: Vivian House, Roman Bridge Close, Mumbles, Swansea, SA3 5BG

Miller & Partner Ltd is an Appointed Representative of Gauntlet Risk Management Ltd, which is authorised and regulated by the Financial Conduct Authority (FRN 308081). Miller & Partner Ltd is entered on the Financial Services Register under firm reference number 1029698. You may check this on the Financial Services Register by visiting the FCA website at https://www.fca.org.uk/firms/financial-services-register or by contacting the FCA on 0800 111 6768. Miller & Partner Ltd is registered in England & Wales, company number 16206282. Registered office: 20 Vivian House, Roman Bridge Close, Swansea, SA3 5BG.