Farm workers' caravans and the site licence exemptions

An agricultural workers caravan sited on the land where those workers are employed can be exempt from caravan site licensing under Schedule 1 to the Caravan Sites and Control of Development Act 1960, and where the exemption applies, planning permission is granted by Part 5 of the General Permitted Development Order 2015. Two separate regimes, one answer. The difficulty is that the exemption is narrower than most farmers assume, and stepping outside it loses both the licence exemption and the planning permission at the same moment.

The exemptions for caravans occupied by agricultural workers

Section 1 of the 1960 Act makes it an offence to use land as a caravan site without a site licence. Schedule 1 then lists the cases where no licence is needed, and the agricultural and forestry exemption is one of them.

The exemption covers the use of land occupied for agriculture or forestry as a caravan site, where the caravans accommodate a person employed in farming or forestry operations on that land. Read those words carefully. The land has to be occupied for agriculture, the occupier's own land, and the worker has to be employed in operations on that land rather than somewhere else in the business.

Other paragraphs of Schedule 1 cover different situations that farmers sometimes confuse with this one: a caravan within the curtilage of a dwelling house used for purposes incidental to that house, building and engineering site accommodation, and the five acre and 28 day arrangements used for holiday caravans. They have different conditions and different consequences.

Part 5 Class A of the General Permitted Development Order then grants planning permission for the use of land as a caravan site in circumstances where a licence is not required under those paragraphs. That is the neat part of the arrangement. Lose the exemption and you lose the permitted development right with it.

What the exemption covers and what it does not

It covers the caravan as accommodation. It does not turn the land into a residential planning unit, and it does not authorise the permanent siting of a mobile home as a dwelling with a garden, fences, a driveway and an oil tank.

It does not cover workers employed elsewhere. A contractor working across six holdings, or a worker in the farm shop rather than in farming operations, falls outside it. Nor does it cover letting the caravan to anyone else, even seasonally, and holiday letting a caravan on the same field is a different use needing its own permission.

Check the unit is a caravan in law. Section 29 of the 1960 Act defines it, and section 13 of the Caravan Sites Act 1968 allows twin units assembled on site within maximum dimensions of 20 metres in length, 6.8 metres in width and 3.05 metres of internal height. A structure larger than that, or built rather than assembled from pre-made sections, is a building and needs planning permission as operational development.

Then check whether an Article 4 direction has removed the Part 5 rights, which some National Park authorities and rural districts have done.

Whether planning permission is still required

Often yes, and the honest answer depends on three things.

The first is whether the exemption really applies on your facts. If it does, Part 5 Class A covers the use and no application is needed, although a lawful development certificate under section 191 or 192 is the only way to confirm it formally.

The second is whether anything else on the site amounts to development. Hardstanding, a new access, a septic tank, a day room or a welfare block are operational development in their own right and are not covered by the caravan permission.

The third is duration and character. A caravan on the same spot for years, with a garden and domestic paraphernalia around it, starts to look like a dwelling. Enforcement officers assess what is actually happening rather than what the exemption says, and the immunity periods under the Levelling-up and Regeneration Act 2023 are longer than the four and ten year rules practitioners remember.

Where a permanent dwelling is what the business really needs, that is a different application entirely, turning on the national policy test for rural workers' dwellings and an essential need for a worker to live at or near their place of work.

Seasonal worker accommodation at scale

A dozen caravans for a soft fruit harvest is a different proposition from one caravan for a stockman. Scale pushes schemes out of the exemption in practice even where the words might be argued to fit, because the authority looks at the whole operation.

Larger seasonal accommodation normally needs planning permission for the use, a site licence with conditions drawn from the model standards, and separate consideration of welfare provision. Applications are commonly made for a temporary permission covering the picking season each year, with conditions requiring removal outside those months and tying occupation to workers employed on the holding.

Expect the authority to ask about transport to and from the fields, foul drainage capacity, water supply, waste collection, fire separation between units, and management arrangements. Where a labour provider is involved, its licensing obligations sit outside planning but the officer will ask.

Set the case out in a Planning Statement that explains the crop calendar, the labour requirement and why accommodation on the holding is necessary rather than convenient. Vague references to a shortage of local labour do not carry an application.

Services, drainage and welfare provision

Remote fields rarely have services. Foul drainage for a caravan cluster means a package treatment plant or a cesspool, both of which need an environmental permit or an exemption, and both of which need somewhere to discharge. The sequencing of water supply and foul drainage on remote rural sites is worth settling before the siting is fixed, because the drainage solution often dictates where the units can stand.

Water supply from a private borehole brings its own regulatory requirements for testing and treatment. Where a mains connection is available, get a budget estimate early.

Fire safety between units, access for an appliance and a water supply for firefighting are all raised by the fire and rescue service on larger sites. Spacing between caravans is covered by the model standards used in site licence conditions, and designing to those standards from the start avoids a licence that cannot be complied with.

Conditions and occupancy restrictions

Where permission is granted rather than relied on under the exemption, expect conditions tying occupation to people employed in agriculture on the holding, limiting the number of units, restricting the period of the year, requiring removal of the caravans and reinstatement of the land at the end of a temporary permission, and controlling external lighting.

Occupancy conditions are enforceable and they run with the land. They also affect value and mortgageability, which is a conversation to have with the client before the application rather than after the sale falls through.

Ask for wording you can live with. A condition tying occupation to workers employed "on the holding" is workable; one tying it to a named individual is not.

Evidence of the agricultural connection

Whether you are relying on the exemption or applying for permission, the evidence is the same, and it is documentary rather than descriptive.

Keep the contracts of employment, payroll records showing the work done, the holding number and land registry plan showing the land in your occupation, the cropping or livestock records for the relevant season, and a plan showing where the caravans stand in relation to the land being farmed. If an enforcement officer asks in three years, that file is the answer.

An illustrative example. A 60 hectare mixed holding sites one twin-unit caravan beside an existing yard for a stockman employed full time on that land, with services run from the farmhouse. The exemption applies, Part 5 covers the use, and a certificate of lawfulness makes the position secure. The same holding placing eight caravans in a field for pickers employed by an agency across three farms is outside the exemption, needs permission and a site licence, and should be presented as a temporary seasonal proposal. The difference between letting a rural building for holidays and housing your own workers is the same distinction in another form.

PlanScope drafts the Planning Statement and supporting documents for rural applications like these, structured to UK planning policy, with the facts it cannot verify flagged for you to complete. Enter your postcode on PlanScope to see which reports your site is likely to need.

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