Use Classes and Change of Use

Co-living and large scale shared living proposals

6 min readBy PlanScope Editorial Team

Large-scale shared living is sui generis, so every change needs permission and the standards come from local policy. Here is what councils look for and what to submit.

Large-scale purpose-built shared living does not fit the residential use classes, and that is the starting point for every application. A co-living scheme provides private rooms without full self-contained facilities, alongside substantial shared kitchens, lounges, workspaces and amenities, under single management. It is neither Class C3, which covers dwellinghouses, nor Class C4, which covers small houses in multiple occupation for between three and six people. It is sui generis, so every proposal needs planning permission and there is no permitted change into or out of it.

That also means there is no national policy telling a council what to require. The standards come from the local plan, from supplementary guidance, and in London from the London Plan.

Why co-living sits outside the residential classes

Class C3 covers use as a dwellinghouse, which in planning terms means a unit with the facilities for day-to-day private domestic existence. A co-living room with a bed, a bathroom and a kitchenette but no proper kitchen does not meet that description, and the communal provision is not incidental to it.

Class C4 covers houses in multiple occupation occupied by between three and six unrelated individuals sharing basic amenities. A scheme of several hundred rooms is plainly outside it. Larger houses in multiple occupation are themselves sui generis.

The consequence is procedural as much as policy. A sui generis use cannot be reached by permitted development, cannot be switched to or from Class E, and any later change, including to conventional flats, needs a fresh permission. Conditions attached to the original consent can restrict the use further, and conditions that remove Class E flexibility shows how durable that restriction is once imposed.

Article 4 directions have no bearing here, since there are no permitted development rights to remove, although they do affect the small houses in multiple occupation that co-living schemes are often compared against. Article 4 directions that restrict changes of use covers that ground.

Amenity space and unit size expectations

The nationally described space standard applies to Class C3 dwellings and does not apply here, which is why councils write their own expectations. Those expectations cluster around a few measures.

  • Private room size, including the bathroom and any kitchenette
  • Communal internal amenity space per resident, and what it contains
  • External amenity space, terraces or gardens, and whether it is usable
  • Daylight and outlook to every habitable room, with single-aspect rooms scrutinised
  • Ceiling heights, storage, and provision for cycle parking
  • Accessible room provision

The daylight question is where schemes most often struggle, because co-living layouts tend towards deep plans and long corridors with single-aspect rooms. A Daylight and Sunlight Assessment reporting the internal condition of rooms, not just the effect on neighbours, is worth commissioning at design stage rather than at submission.

Communal space quality matters more than quantity in committee. A large lounge that is actually the lobby, or a workspace that is a corridor widening, will be identified as such.

Management and the role of conditions

Single management is part of what defines the use, and councils secure it. Expect conditions or obligations covering the unified ownership or management of the building, a minimum tenancy length, the provision and retention of the communal facilities, and a management plan dealing with anti-social behaviour, waste, deliveries and moving-in days.

Minimum tenancy length is the one to focus on, because it distinguishes co-living from short-term letting and it affects the investment case. London policy has used a minimum tenancy period for this purpose, and authorities outside London frequently copy it.

Submit the management plan with the application rather than offering it as a condition. It is the document that answers most of the objections a resident association will raise, and offering it late suggests it has not been thought through.

Affordable housing and how policy treats it

This is the commercial question. Because co-living rooms are not conventional homes, they do not count towards housing delivery in the same way, and policy generally requires a contribution towards conventional affordable housing rather than on-site provision.

In London the approach has been a cash in lieu contribution towards conventional affordable housing, calculated by a published formula. Outside London the position varies: some authorities apply their standard affordable housing policy by analogy, some negotiate, and some have no policy at all, which is its own problem because it leaves the figure to be argued at committee.

Two documents carry the weight. An Affordable Housing Statement setting out the approach and the calculation, and where the offer falls short of policy, a Viability Assessment prepared to the recognised professional standard and submitted on the basis that it will be published.

Do not assume the council will accept a comparison with student accommodation. The tenure, the occupier and the policy basis are different, and officers say so.

Comparison with houses in multiple occupation

The comparison comes up at every committee, usually from objectors, and it is worth answering directly rather than dismissing it.

Feature Small HMO (Class C4) Large-scale shared living
Use class C4 Sui generis
Occupancy Three to six sharing Typically fifty rooms or more
Management Often absentee landlord Single on-site management required
Communal provision Shared kitchen and bathroom Purpose-designed amenity space
Planning control Permitted change from C3 unless removed by Article 4 Permission required in every case

The useful point for an applicant is that the planning control is tighter, not looser: every aspect of the scheme is conditioned because nothing about it is permitted development.

Local policy variation

Outside London and a handful of large cities, many local plans say nothing about shared living at all. That is not an advantage. A scheme assessed against no policy is assessed against the general design, amenity and housing policies, and the officer has no framework for saying yes.

Where there is no adopted policy, pre-application engagement matters more than usual, and so does evidence of need. Set out the local rental market, the household types the scheme is aimed at, and why conventional flats would not meet that need on this site. Emerging local plan policy, where it exists, should be addressed even at low weight.

Evidence to submit

  1. A Planning Statement that names the use as sui generis and explains why, with the policy basis for assessment set out.
  2. A schedule of rooms and communal areas with floor areas per resident.
  3. A management plan, including tenancy length, staffing and house rules.
  4. Daylight and outlook assessment of the internal environment.
  5. The affordable housing approach and calculation, with viability evidence where the offer is below policy.
  6. Transport, servicing and waste strategies scaled to the resident numbers, including cycle parking and move-in logistics.
  7. Need evidence, particularly where local policy is silent.

Where the authority has no adopted standard, propose one in the application and justify it. An applicant who sets out the measures against which the scheme should be judged usually gets judged against them.

This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.

Frequently asked questions

What use class is co-living?

None. Large-scale purpose-built shared living falls outside Class C3, which covers dwellinghouses, and Class C4, which covers small houses in multiple occupation for three to six people. It is sui generis, so planning permission is required for the use and for any later change out of it, including to conventional flats.

Does the nationally described space standard apply?

No. That standard applies to Class C3 dwellings. Councils therefore set their own expectations for co-living room sizes and communal amenity provision through local plan policy or supplementary guidance, and in London through the London Plan. Where no local standard exists, propose one in the application and justify it.

How is affordable housing handled on a co-living scheme?

Usually through a contribution towards conventional affordable housing rather than on-site provision, because the rooms are not conventional homes. London policy has used a cash in lieu contribution calculated by formula. Outside London approaches vary, and where the offer falls below policy a viability assessment prepared to professional standards will be expected.

Will the council impose a minimum tenancy length?

Commonly, yes, by condition or obligation, to distinguish the use from short-term letting. Expect conditions on unified management, retention of the communal facilities and an approved management plan as well. Submit the management plan with the application rather than offering it as something to be agreed later.

Is co-living treated like student accommodation?

Not automatically, and officers usually resist the comparison. The occupier, the tenure and the policy basis differ, and purpose-built student accommodation is often covered by its own local plan policy. Argue the scheme on its own terms, with local need evidence, rather than by analogy.

Sources and further reading

co-livingsui generisuse classesshared livingaffordable housing

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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