Hostels, aparthotels and the Class C1 boundary

Aparthotel use class questions almost always come down to one line in the Use Classes Order. Class C1 covers use as a hotel or as a boarding or guest house where no significant element of care is provided. It says nothing about self-contained units, nothing about kitchens, nothing about length of stay and nothing about whether there is a reception desk. Those features matter because of what they say about the real character of the use, and that is what a planning officer assesses, rather than because the Order mentions them.

What Class C1 includes and excludes

The class covers hotels, boarding houses and guest houses. The defining features in practice are transient occupation, the absence of security of tenure, and a business that provides accommodation as a service rather than letting a dwelling.

Three uses sit outside it and are often confused with it.

Class C2, residential institutions, covers residential care homes, nursing homes, hospitals and residential schools and training centres. The dividing line from C1 is care.

Class C3, dwellinghouses, covers use as a dwelling by a single household. A self-contained unit occupied as somebody's home is C3 whoever owns it and however the owner describes the business.

Hostels fall into neither class. They are a use of their own, which has consequences for every application involving one.

Hostels sit outside the classes altogether

A hostel is sui generis. There is no permitted change into or out of it, so every proposal involving a hostel needs a full planning application, and the authority has a free hand on conditions because it is not constrained by any class description.

That cuts both ways. Converting a hostel to flats is a material change of use requiring permission, and the authority may resist it where the hostel provides accommodation the local plan protects. Converting a building into a hostel is equally a material change, and the application will be assessed on amenity, management, noise and the effect on the surrounding area rather than against any class test.

The word itself is not decisive. A backpacker hostel with dormitory rooms, communal kitchens and nightly bookings and a supported accommodation hostel with keyworker support and residents staying for months are both called hostels and are very different planning animals. The second looks closer to C2 in substance if care is provided, and the authority will look at what is actually offered rather than at the label on the sign.

Describe the operation, not the category. An application for "change of use to hostel" invites the officer to pick whichever version of the word fits their concerns.

Serviced apartments between C1 and C3

Serviced apartments and aparthotels are where most of the argument happens, because the physical product looks like a flat and the business model looks like a hotel.

No class mentions them, so the question is which existing class the use most closely resembles. Officers look at a consistent set of indicators.

A development that scores on the left of that table is likely to be assessed as C1. One that scores on the right is a block of flats with a concierge, and the authority will apply its housing policies to it, including affordable housing requirements and space standards.

The mixed model is the difficult one. Where some units run nightly and some are let for six months, the authority may conclude there are two uses in the same building, which has implications for policy compliance and for the description of development.

In Greater London there is an additional layer. Use of residential premises as temporary sleeping accommodation is treated as a material change of use, subject to the exception introduced by the Deregulation Act 2015 that allows letting for up to 90 nights in a calendar year where the person liable for council tax conditions are met. Outside London that statutory framework does not apply, although a change of use can still arise on ordinary principles.

The care test that divides C1 from C2

That phrase about care is the boundary between C1 and C2, and it does more work than people expect.

Care means personal care. Help with washing, dressing, medication, mobility and daily living. It does not mean housekeeping, meals, a concierge or a night porter. A hotel that serves breakfast and changes towels provides a service, not care.

A guest house that takes placements from a local authority and provides support workers on site has moved towards C2, whatever its original planning history, and an officer dealing with an enforcement complaint will look at the support arrangements rather than at the building. The question is whether the care is substantial in relation to the accommodation, which is a matter of degree and fact.

The practical consequence for an occupier is that a change in the support model can change the use class without any building work at all. Where a business expects to take supported placements, say so in the application and seek a description that covers it.

Conditions preventing permanent residential occupation

Where permission is granted for a C1 or aparthotel use in a location the authority would not accept for housing, or vice versa, the permission almost always carries occupancy conditions.

Common wording restricts occupation of each unit to a maximum continuous period, requires that no unit is occupied as a person's sole or main residence, and requires a register of occupiers to be kept and made available to the authority on request. Some authorities add a requirement that units are not sold off individually.

Read those conditions before signing a lease on a unit. A serviced apartment bought as an investment and then occupied permanently puts the owner in breach, and an occupancy condition is enforceable against the occupier as well as the applicant.

Where the conditions no longer suit the business, a section 73 application to vary them is the route, and it is decided on the planning merits of the change rather than on the commercial pressure behind it. Conversions that began as temporary or meanwhile arrangements carry the same risk, and temporary uses and the risk of permanence is worth understanding before relying on a time-limited consent.

Council tax, business rates and what they signal

The tax treatment follows the use rather than deciding it, but it is evidence an officer will reach for.

In England a self-catering property moves from council tax to non-domestic rating only where it meets availability and actual letting thresholds in the previous year, currently expressed as being available for short-term letting for at least 140 days and actually let for at least 70. A property paying council tax while the applicant describes it as a hotel use is a contradiction the authority will notice.

Licensing adds another signal. A hostel occupied by several households sharing facilities may be a house in multiple occupation for the purposes of Part 2 of the Housing Act 2004 and need a licence, which is a separate regime from planning and does not confirm the lawfulness of the use.

A new use class for short-term lets in England has been announced but was not in force at the time of writing, so check the current position before relying on any class structure for that purpose.

Evidencing the operating model in the application

The application succeeds or fails on how clearly the operation is described. Vague descriptions get restrictive conditions.

Include the minimum and maximum stay, the booking mechanism, the services provided and their frequency, whether there is staffed reception and for what hours, how arrivals outside those hours are handled, the housekeeping arrangements, how refuse is managed, and the proposed management of noise and arrivals late at night. Where the building has other occupiers, deal with the interface directly, particularly where the upper floors sit over a commercial unit and the question of whether they are a separate planning unit has to be settled first.

Transport evidence is usually light for these uses, but it is not nothing. A Transport Statement covering servicing, taxi drop-off, luggage and staff parking answers the highway officer's questions, and a short Planning Statement should set the operating model against the class analysis rather than asserting a class and moving on.

Enter the postcode on PlanScope to see which supporting documents a change of use at your address 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. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.