EV charging: Approved Document S and local policy

Electric vehicle charging in new development is set by Part S of the Building Regulations, not by planning, unless the local plan says otherwise. That distinction decides who you argue with and when. Approved Document S has applied to building work in England since June 2022, and it sets minimum provision for new residential and non-residential buildings and for certain major renovations. A local plan policy can require more, and in London it routinely does.

The practical consequence is that a planning application usually needs to show the provision on a drawing, while the enforcement of the standard happens through building control.

What the Building Regulations require

Approved Document S works through a small number of cases.

A new residential building with associated parking needs a charge point for each dwelling that has a parking space. Where a residential building has more parking spaces than dwellings, the surplus spaces need cable routes so that charge points can be added later.

A residential building undergoing major renovation, where the works include the parking or the electrical infrastructure and there will be more than ten spaces afterwards, needs a charge point for each dwelling with a space and cable routes for the rest.

A new non-residential building with more than ten parking spaces needs at least one charge point and cable routes to a proportion of the remaining spaces. The same applies to a major renovation of a non-residential building that leaves more than ten spaces.

Charge points have to be capable of a minimum power rating, positioned to serve the space they belong to, and provided with the electrical capacity to work at the same time as everything else in the building.

There are exemptions, and they matter on tight sites. Where the cost of connecting a charge point to the existing electricity supply exceeds a cap set in the Approved Document, the requirement is to install as many points as the cap allows rather than the full number. Listed buildings and buildings in conservation areas have their own position. Check the current edition of the document before relying on any of this, because the figures are reviewed.

Active and passive provision

The vocabulary matters because policies use it loosely.

Active provision means an installed, working charge point. Passive provision means the physical route and the electrical capacity to add one, without digging up the car park or upgrading the incoming supply. Cable route is the Approved Document's own term and sits within the passive category.

Passive provision that stops at a duct is not passive provision. If the substation, the incoming supply or the distribution board has no headroom, adding the charge point later means a new connection, which is the expensive part. Where a policy or a condition asks for passive provision, say in the submission what electrical capacity has been reserved and where the spare ways sit in the board.

Where local plan policy goes further

Development plan policy can and does set a higher standard, and it is the policy rather than the Approved Document that a planning officer will apply at determination.

The most common uplift is a proportion of spaces with active provision and the remainder passive. In London, the London Plan sets an active provision proportion for residential parking with passive provision for the balance, and boroughs apply their own standards on top for particular uses. Elsewhere, standards appear in parking standards supplementary planning documents as often as in the plan itself, which is why they get missed.

Check three documents before fixing the layout: the adopted local plan, any parking standards guidance the authority has adopted, and the validation checklist, which sometimes asks for an EV provision plan as a submission requirement in its own right. Our note on electric vehicle charging standards in local plans goes through how those standards are usually expressed.

Communal and unallocated parking

Flats with a shared car park are the hardest case, and the one where schemes are most often conditioned badly.

Allocating one charge point to one flat works only if the space is allocated too. Where parking is unallocated, the workable arrangement is a smaller number of shared charge points, sited where they can serve any resident, with load management so that the supply is shared rather than sized for every point at full output at once. Load management is a legitimate engineering answer and is worth stating explicitly, because a naive capacity calculation will otherwise conclude the site needs a new substation.

Management company arrangements need thinking about at application stage. Who owns the points, who bills for the electricity, who maintains them, and what happens when a resident wants a point at their space. None of that is a planning matter, and all of it determines whether the provision survives. A car park with four points that nobody maintains is worse than one with two that work.

Electrical capacity and the network operator

Talk to the distribution network operator early, and do it before the layout is fixed rather than after the condition is imposed.

The question to ask is what capacity is available at the existing connection and what a reinforcement would cost and take. On a constrained network the answer shapes the scheme. It may mean load management, on-site generation, battery storage, or a phased provision agreed with the authority.

Where the application is for a larger scheme, this sits naturally alongside a Utilities Assessment covering the other connections, and the energy strategy in the Energy Statement should be consistent with it. A scheme that proposes all-electric heating and full active charging provision on an unreinforced supply will not survive technical review.

Drawing provision that survives a condition

Put it on the parking layout, not in the text.

1. Number every space on the drawing.
2. Mark each one as active, passive with cable route, or neither.
3. Show the charge point positions and the route from the board or substation.
4. Add a schedule stating the power rating, the number of points and the assumed diversity or load management strategy.
5. Cross-reference accessible bays and state how charging is provided for them.

That last point is the one most often forgotten. Accessible bays need space alongside for transfer, and a charge point with a fixed tethered cable at the wrong height defeats it. Standards for accessible parking and for accessible charging both exist and should be named in the schedule rather than left to the contractor.

A drawing in that form discharges a condition on its own. A paragraph promising compliance with Approved Document S does not, and produces a request for further information that costs weeks. The same discipline applies to the travel plan measures the same policy often sits beside, which our note on electric vehicle charging requirements in planning covers alongside the wider parking position.

This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it.

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