Comparisons

Class M or Class MA for a shop to homes conversion

8 min readBy PlanScope Editorial Team

Class MA takes a Class E shop to flats subject to a 1,500 m2 cap, two years of prior use and three months of vacancy. Class M is now a narrow residual right, but it does permit building work.

If the unit you are converting was an ordinary shop, the class M or class MA prior approval question has a short answer: use Class MA. Class M is the older right, and the 2021 reforms left it covering a narrow list of specified uses that no longer takes in ordinary retail. Shops moved into Class E of the Use Classes Order in September 2020, and Class MA of Schedule 2 Part 3 to the GPDO 2015 is the right that takes a Class E building to Class C3 dwellinghouses. The two rights set different floorspace caps, different vacancy tests and different rules about building work, so choosing the wrong one costs you 56 days.

What each right permits

Class MA came into force on 1 August 2021. It permits a change of use from Class E (commercial, business and service) to Class C3 (dwellinghouses), and nothing else. No building operations are authorised. If you need to cut a new window, form a separate entrance, add a bin store enclosure or alter the shopfront, that is a separate planning application running alongside the prior approval.

Class M is the residual retail to residential permitted development right. After the Use Classes Order was recast, the references to the old shops and financial services classes fell away, because those uses now sit inside Class E and Class MA deals with them. What is left is a short list of uses named in the Order, such as a betting office, a pay day loan shop and a launderette, together with mixed uses combining one of those with a dwellinghouse. Read the current text of Class M before you rely on it, because the list has been amended more than once.

Class M does one thing Class MA does not. It permits the building operations reasonably necessary to convert the building, so window openings and internal works sit inside the same prior approval rather than needing a parallel application. For the narrow set of uses it still covers, that makes it the better right by some distance.

Floorspace and vacancy conditions

This is where the two diverge most sharply.

Condition Class MA Class M
Starting use Class E The specified uses named in the Order
Floorspace limit 1,500 m² changing use 150 m² changing use
Prior use period Class E use for two continuous years before the application In the specified use on 20 March 2013, or when last in use
Vacancy Vacant for three continuous months immediately before the application No vacancy requirement
Building operations Not permitted Permitted where reasonably necessary
Space standard Dwellings must meet the nationally described space standard Check the current conditions

The three-month vacancy condition under Class MA catches people out. It is measured immediately before the date of the application, so a tenant who stays on while you prepare the submission restarts the clock. Sitting tenants and short licences both count as occupation.

The 1,500 m² cap applies to the floorspace changing use, not to the building. A larger building can be converted in part, with the remainder staying in Class E, which is often the sensible answer on a parade where the ground floor still trades.

Both rights are switched off for listed buildings and land within their curtilage, for scheduled monuments and for a set of designated and hazard areas set out in the Order. The exclusion lists are not identical between the two classes, so check the text against your site rather than working from memory. Whether your units meet the nationally described space standard or a stricter local figure is worth resolving before you draw the layout, because a failed space standard under Class MA is fatal rather than negotiable.

Matters for prior approval under each

The authority cannot refuse a prior approval application on any ground it likes. It may only consider the matters the Order lists for that class.

Under Class MA the matters are transport impacts of the development, contamination risks on the site, flooding risks, the impact of noise from commercial premises on the future residents, the provision of adequate natural light in all habitable rooms, and fire safety where the building is of the relevant kind. Where the building sits in a conservation area, the authority may also consider the impact of losing the ground floor use on the character or sustainability of that area.

Under Class M the list covers transport and highways, contamination, flood risk, the design and external appearance of the building operations, and whether residential use of the building is undesirable given the sustainability of a shopping area. That last limb gives a town centre authority a genuine hook, and it is the one refusals tend to turn on.

Natural light is the matter that fails most conversions of deep retail units. A rear room lit only by a light well or a rooflight over a 12 metre plan depth will not satisfy it, whatever the daylight factor calculation says about the front room. Test the plan depth first, then commission the drawings.

Article 4 areas and their effect

An article 4 direction withdraws a permitted development right across a defined area. Many authorities have made directions over Class MA in their town and district centres, and over Class M before that. A direction can cover a single street, a frontage, a whole centre or the entire district.

National policy has for several years told authorities to limit directions removing Class MA to cases where they are necessary to avoid wholly unacceptable adverse impacts, and to apply them to the smallest geographical area possible. Check the current wording in the Framework, which was re-issued on 17 August 2026 with policy-coded chapters, rather than quoting a paragraph number from an older copy.

Two practical points. A direction has a date on which it takes effect, and some are made with 12 months notice so that compensation is not payable, which gives a window to submit. And a direction that removes Class MA does not remove your ability to apply for planning permission in the ordinary way, it simply removes the shortcut.

Conditions that follow approval

Class MA development must be completed within three years of the date of prior approval. That is a hard stop, not a commencement deadline, and on a scheme needing a separate permission for external alterations the two programmes have to be sequenced deliberately.

A prior approval is not a planning permission, which has a consequence people miss when they want to change the scheme later. The section 73 and section 96A routes for varying conditions or making a non-material amendment to an approved scheme operate on planning permissions. A material change to a Class MA scheme usually means a fresh prior approval application.

On the levy, a change of use that creates no new floorspace normally attracts no Community Infrastructure Levy, and existing floorspace can be offset where the building has been in lawful use for at least six continuous months within the three years before permission first permits development. The three-month vacancy condition under Class MA does not by itself break that test, but the arithmetic is tight and the current Regulations should be checked against the dates in your own file.

Evidence to submit

For a Class MA application, assemble the following before you fill in the form.

  1. Floor plans of the existing and proposed layouts with a floorspace schedule showing the area changing use against the 1,500 m² cap.
  2. Evidence that the building was in Class E use for two continuous years, such as leases, licences, business rates records or accounts.
  3. Evidence of three continuous months of vacancy immediately before the application date.
  4. A note on transport and parking, with a servicing and refuse strategy for the new units.
  5. A contamination screening note, and a flood risk position where the site sits in Flood Zone 2 or 3.
  6. A noise note where the building adjoins or contains commercial premises, addressing plant and delivery hours.
  7. Room-by-room daylight information demonstrating adequate natural light to every habitable room.
  8. Room areas against the nationally described space standard.

An illustrative example. A 1930s parade unit of 210 m² on the ground floor, previously a hardware shop, closed in January and marketed empty since. The owner applies under Class MA in June for two flats totalling 190 m² of converted floorspace, keeps a 20 m² store in Class E use, and runs a separate householder-style application for a rear door and a bin enclosure. The vacancy and two-year use tests are met, the cap is nowhere near reached, and the fight is about the daylight to the back bedroom. That is a typical shape for these schemes.

Choosing the route

Work through it in this order. Establish the lawful use and its date, because that decides which class is even available. Check whether an article 4 direction covers the site. Measure the floorspace changing use against the relevant cap. Test plan depth and natural light before you spend money on drawings. Then ask whether you need building operations, since needing them pushes a Class E building towards a full application rather than a prior approval plus a second permission.

Where the prior approval route is closed or marginal, a full application is often the cleaner answer. It costs more and takes longer, but it puts the whole scheme, including the external works, into one decision, and it lets you argue the merits rather than a closed list of matters. If a prior approval is refused, the appeal is made under section 78 of the Town and Country Planning Act 1990, and the choice between appealing and resubmitting turns on the same considerations that apply to a householder appeal or the faster commercial route.

Either way, the supporting documents are much the same, and you can see the full set of report types by category to work out what your scheme will need. Enter your postcode on PlanScope to see which reports the site is likely to require.

This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it, and remember that a Lawful Development Certificate is the only formal way to confirm that works or a use are lawful. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.

Frequently asked questions

Can I use Class M to convert a shop to flats?

Not usually. Ordinary shops moved into Class E of the Use Classes Order in September 2020, and Class MA is the right that covers Class E to Class C3. Class M now applies to a short list of specified uses named in the Order, such as a betting office, a pay day loan shop or a launderette. Check the current text of Class M against your lawful use before you rely on it.

How long must the building have been empty for Class MA?

Three continuous months immediately before the date of the prior approval application. Any occupation in that window restarts the clock, including a sitting tenant on a short licence. Keep dated evidence such as marketing particulars, rates correspondence and utility readings, because the authority will ask for it and a gap in the record is the easiest reason to refuse.

Does Class MA allow me to alter the shopfront?

No. Class MA authorises the change of use alone, so external alterations such as a new entrance, replacement shopfront, new window openings or a bin store enclosure need a separate planning application. Plan the two together, because the Class MA approval carries a three-year completion deadline and the alterations permission has its own timetable.

What can the council refuse a Class MA application on?

Only the matters the Order lists: transport impacts, contamination, flooding, noise from commercial premises affecting future residents, adequate natural light to all habitable rooms, fire safety where relevant, and in a conservation area the effect of losing the ground floor use. Natural light to deep rear rooms is the most common sticking point on retail conversions.

How do I check whether an article 4 direction applies?

Ask the local planning authority for the direction, its map and the date it took effect, and read the wording rather than a summary. Directions vary from a single frontage to a whole district, and some are made with twelve months notice. A direction removes the shortcut, not your right to apply for planning permission in the ordinary way.

Is a prior approval the same as planning permission?

No, and the difference matters when you want to change the scheme. Section 73 and section 96A apply to planning permissions, so a material change to an approved Class MA scheme normally needs a fresh prior approval application rather than an amendment. Refusals are still appealable under section 78 of the Town and Country Planning Act 1990.

Sources and further reading

class mapermitted developmentchange of useprior approvalshop to residentialgpdo

This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.

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