Is extractor fan obligatory in kitchen with windows?

I have a 5 person HM0 with a largish kitchen with a big window (and patio doors). There is an extractor fan with filter above the hob (ie it does not connect to the external). The council have been round to look at everything and have told me to put in a regular extractor fan (that goes through wall to the external) but is this a requirement for kitchens with natural ventilation by way of a window/s?

requirement yes Do as they say

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Realistically, are your tenants going to keep the windows fully open during the colder months to properly ventilate the kitchen whilst cooking? Do yourself a favour and get an externally vented extractor.

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That’s an opinion, not an answer, but up to you if you want to spend time giving opinions.

If the local council say you need to fit a fan - then that is what you need to do.

Won’t be hugely expensive and the council get a tick in the right box