Design code compliance or a design and access statement
One is a statutory document under Article 9 of the DMPO 2015, the other an audit against an adopted code. Where a code covers your site you need both, doing different jobs.
A design and access statement is a statutory document with a prescribed purpose. A design code compliance statement is not: it exists because an adopted code, or the authority's local validation list, asks for it. So the choice between a design code or design and access statement is usually no choice at all. Where a code covers your site you will be writing both, and the skill is in making them do different jobs rather than saying the same thing twice at different lengths.
What a design and access statement has to cover
Article 9 of the Town and Country Planning (Development Management Procedure) (England) Order 2015 sets out when a Design and Access Statement is required and what it must contain. It is needed for major development, and for development in a conservation area or World Heritage Site that involves one or more dwellings or 100 m2 or more of floor space. Applications for listed building consent need one too.
The prescribed content is narrower than most statements suggest. The document has to explain the design principles and concepts that have been applied, and how issues relating to access have been dealt with. Working through that means stating the policy adopted as to design, how the context of the site and its surroundings was taken into account, what consultation was carried out and how its outcome shaped the proposal, and the policy adopted as to access, including how relevant inclusive access considerations were taken into account.
Note what is absent. There is no statutory requirement to reproduce the site history, no requirement for a page of policy quotation, and no requirement to argue planning merits. That belongs in the Planning Statement. A design and access statement that opens with four pages of local plan extracts is a statement that has borrowed someone else's job.
What a design code compliance statement has to cover
A design code sets measurable, often illustrated requirements: street widths and hierarchy, building lines and setbacks, plot coverage, storey heights and roof forms, boundary treatments, material palettes, parking arrangement, tree and planting standards.
A compliance statement works through the code requirement by requirement and says, for each one, whether the scheme meets it, and where it does not, why the departure is justified. The structure that works is a table with the code reference, the requirement as written, the scheme's response, and a compliance position. Then a short narrative on the departures only.
This is an auditing document, not a persuasive one. Its value to the case officer is that it removes the need to check the code against the drawings personally. Write it so that someone can verify each row against a specific drawing number, and say which drawing.
Where codes come from and how far they bind
The National Design Guide and the National Model Design Code are national documents that set out what good design means and how a local code should be structured. Neither is a development plan document, so neither binds a decision directly, though the Framework expects them to inform local codes and design policies.
The binding force comes from adoption. A code adopted as part of a local plan or neighbourhood plan is part of the development plan, and section 38(6) of the Planning and Compulsory Purchase Act 2004 requires the determination to be made in accordance with it unless material considerations indicate otherwise. A code adopted as a supplementary planning document is a material consideration with real weight but not the same status. A code produced by a masterplan developer and endorsed by the authority sits lower still, and its force may come from a condition or a section 106 obligation instead.
The Levelling-up and Regeneration Act 2023 pushed authorities towards preparing design codes covering their whole area. Coverage is uneven as that programme works through, so the first question on any site is what code applies and how it was adopted. The answer changes how much argument you can win about a departure.
Design review panels and where their comments land
Design review is a separate exercise from both documents. A panel gives advice, usually pre-application, and its report is a material consideration the officer will weigh. It has no decision-making power.
Panels tend to interrogate the design and access statement's reasoning rather than the code compliance table, because they are interested in whether the design principles hold up, not whether the window head heights match a specification. Where a panel has reviewed a scheme, say so in the design and access statement, set out what it said, and explain what changed as a result. Silence on an unfavourable panel report is noticed.
Which applications need which
| Application | Design and access statement | Code compliance statement |
|---|---|---|
| Householder extension, no designation | No | Only if a code covers the site and the validation list asks |
| Householder extension in a conservation area, 100 m2 or more | Yes | If a code applies |
| One or more dwellings in a conservation area or World Heritage Site | Yes | If a code applies |
| Major development, 10 or more dwellings or 1,000 m2 | Yes | Usually, where a code is adopted |
| Listed building consent | Yes | Rarely relevant |
| Reserved matters following outline | Often required by condition | Yes, where the outline was granted against a code |
The local validation list is the document that settles borderline cases, because authorities may require documents beyond the national list where the requirement is published and reasonable. Check it before assuming that the statutory trigger in Article 9 is the whole answer.
Drawing conventions the officer expects
Both statements depend on drawings, and both fail when the drawings are inconsistent with the text.
- Scale bars and a north point on every plan, with paper size stated, because a drawing labelled 1:100 and printed at A3 from an A1 original is not at 1:100.
- Existing and proposed elevations at the same scale, side by side, with the ridge and eaves heights dimensioned.
- A contextual street elevation covering enough of the frontage to show the rhythm the code or the design statement is talking about.
- A materials schedule keyed to the elevations, with manufacturer references where the code specifies a palette.
- Boundary treatments drawn, not described. Codes almost always fix these, and they are the commonest source of a compliance failure that only surfaces at condition discharge.
Producing both without repetition
Write the design and access statement first, because its design principles section is the argument from which the code responses follow. Keep it to the statutory content plus the drawings that carry it. Then write the compliance statement as a table that cross-refers to that argument rather than restating it.
The one section that does appear in both is access. The statutory statement covers the policy adopted as to access and inclusive access; a code will usually set street widths, footway dimensions and parking arrangement. Deal with the policy reasoning once, in the design and access statement, and let the compliance table point to it.
And resist the urge to pad. A 12-page design and access statement that answers Article 9 precisely, with a separate compliance table, gets read. A 60-page hybrid document does not.
Draft your Design and Access Statement in minutes and then send it for professional review, or browse the full report index to see what else the application will need. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval. This is general guidance rather than legal advice, so check the position with your local planning authority or a qualified professional before relying on it.
Frequently asked questions
When is a design and access statement legally required?
Article 9 of the Development Management Procedure Order 2015 requires one for major development, and for development in a conservation area or World Heritage Site involving one or more dwellings or 100 m2 or more of floor space. Listed building consent applications need one as well. Authorities can also ask for one through a published local validation list.
Does a design code override the local plan?
No. A code adopted as part of the local plan is part of the development plan and carries the weight section 38(6) of the 2004 Act gives it. A code adopted as a supplementary planning document is a material consideration with less status. A developer-produced code endorsed by the authority usually binds through a condition or obligation instead.
Can one document serve as both statements?
It can, but it usually reads badly. The statutory statement is an argument about design principles and access, and the compliance statement is a row-by-row audit against a code. Combining them buries the argument in a table. Two short documents that cross-refer are easier for a case officer to check and quicker to update after a revision.
What happens if the scheme departs from the adopted code?
A departure is not fatal, but it has to be justified on its own terms in the compliance statement. Say which requirement is not met, by how much, and what design reason supports the departure. Where the code is part of the development plan, the departure engages section 38(6) and the officer will need a material consideration that outweighs it.
Does design review panel advice have to be followed?
No. A panel's report is advice and a material consideration, not a decision. It carries real weight with officers and at appeal, so a scheme that ignores a critical report without explanation is exposed. Record what the panel said in the design and access statement and set out what changed in response to it.
Sources and further reading
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.