How to read a council validation checklist before you apply

A local validation checklist (some councils call it the local list or local information requirements) is the set of documents an English local planning authority can lawfully insist on before it registers your application. It sits on top of the national requirements set out in statute. Article 11 of the Town and Country Planning (Development Management Procedure) (England) Order 2015 sets out what makes an application valid, and section 327A of the Town and Country Planning Act 1990 means the authority must not entertain one that falls short. Read both lists before you draw anything, because the local one is where the unbilled hours go.

What validation is under the DMPO 2015

Validation is a clerical test carried out by a registration officer, usually against a tick-box matrix. Nobody is assessing whether the scheme is acceptable at this stage. They are checking that the form, the plans, the certificates, the fee and the listed local items are present.

That distinction matters when you are told your application is invalid. An invalid application has no determination period running, no consultation, no case officer and no statutory clock. It simply sits there. An application refused on its merits at least gives you an appeal.

Local requirements are made under section 62(3) of the 1990 Act, and Article 11 puts three conditions on them. The requirement must be published on the authority's website, it must have been published within the two years before the application is made, and it must be reasonable having regard in particular to the nature and scale of the proposed development and to whether the information is material to the determination. All three, not one of them.

So a local list adopted in 2019 and never republished is vulnerable. A demand for a Transport Assessment on a two-bedroom rear extension is vulnerable on reasonableness. And an item that is not on the published list at all cannot be a validation requirement, whatever the officer says in an email.

The national requirements that apply everywhere in England

These come from the Order and the Act rather than from the council, so there is no arguing with them:

• the standard application form, completed, with the correct application type
• a plan identifying the land, normally at 1:1250 or 1:2500 with a north point and the site edged red, other land in the same ownership edged blue
• the relevant ownership certificate (A, B, C or D) and the agricultural holdings certificate under section 65
• the correct fee, which is indexed annually, so check the current schedule rather than last year's spreadsheet
• a Design and Access Statement where Article 9 requires one
• a fire statement under Article 9A where the application involves a relevant high-rise residential building, which is the Planning Gateway One consultation with the Building Safety Regulator
• biodiversity gain information, required since the statutory net gain regime came into force in February 2024 for majors and April 2024 for small sites

Article 9 is narrower than most people assume. A Design and Access Statement is required for major development, and for development in a conservation area or World Heritage Site that involves one or more dwellings or a building of 100 m² or more of floorspace. Engineering and mining operations and material changes of use are excluded. A single-storey rear extension in a conservation area usually needs no DAS as a matter of national law, which is why so many councils put design statements on their local list instead.

The biodiversity gain fields are the newest source of invalid applications. The form asks whether you believe the gain condition applies, and if it does not, why not. Getting that answer wrong, or leaving the pre-development biodiversity value blank, stops registration even on schemes that are genuinely exempt.

Finding and dating the local list

Search the council's site for "validation checklist", "local list" or "local information requirements" rather than browsing the planning pages. The document is usually a PDF matrix with application types across the top and documents down the side, and it is often filed under "planning policy" rather than "apply for planning permission".

Check three things on the front page. The adoption or publication date, because of the two-year rule. Whether the list distinguishes "always required" from "required where triggered". And whether it cross-refers to a separate Supplementary Planning Document, a parking standards annexe or a drainage proforma that you also need to download.

The Planning Portal's application service prompts you for national items only. It does not know what a particular authority has added, which is why an application can pass every field on the form and still be rejected the next morning.

The local items that most often stall registration

These are the recurring ones across English local lists. Nothing here is universal, so read your authority's own matrix.

The tree and ecology rows are the expensive ones, because they are seasonal. A tree survey can be done in most conditions, but bat emergence surveys run roughly May to September and great crested newt eDNA sampling sits between 15 April and 30 June. Discovering the requirement at validation in October can cost a scheme most of a year.

Heritage is the one where drafting quality shows. A Heritage Statement that does not identify significance and then weigh harm against public benefit will be accepted at validation and then quoted back at you in the officer's report.

Challenging a requirement you think is unreasonable

Do it in writing, quickly, and against the Article 11 test rather than on general unfairness.

1. Confirm the item is on the published list and note the publication date. If the list is more than two years old, say so.
2. Set out why the item is not material to the determination of this application, referring to the nature and scale of the development.
3. Offer the alternative: a condition, a Grampian condition for off-site works, or submission of the detail at discharge stage.
4. Ask for the decision to be reviewed by a team leader, and ask for the reasons in writing.
5. If the authority holds its position, your practical choices are to supply the document, use the council's complaints procedure, or in rare cases seek judicial review. There is no appeal to the Planning Inspectorate against a refusal to validate.

The cheaper route is to settle scope at pre-application stage and get the officer's list in an email. That email is worth more than any argument after submission, because the registration team will usually defer to it.

Building one pack against two checklists

Run both lists as a single schedule from day one.

1. Download the national requirements and the authority's current local list, and date-stamp both in the project file.
2. Screen the site for constraints before you scope documents: flood zone, conservation area, listed buildings, TPOs, Article 4 directions, air quality management area.
3. Build a document schedule with one row per required item, the trigger, the author, the lead time and the cost.
4. Separate the narrative documents you can draft yourself from the survey-based reports that need a competent or licensed author.
5. Book the seasonal surveys first and write the statements while you wait.
6. Cross-check drawing numbers and revisions against the schedule of plans on the form. Mismatched revision letters are one of the most common reasons a pack bounces.

If you want a starting point for the scoping step, the full index of report types by category is organised the way local lists tend to be, and it flags which reports need a qualified professional rather than a well-written draft.

An illustrative example

A five-dwelling infill scheme on a former builder's yard in a conservation area, with a mature lime on the boundary. National requirements: form, location plan, certificates, fee, DAS (major threshold not met, but the conservation area and dwelling trigger applies), biodiversity gain information. Local list adds a heritage statement, a tree survey and tree protection plan to BS 5837:2012, a drainage proforma, a contaminated land questionnaire because of the previous yard use, parking and bin storage details, and the CIL Additional Information form. Nine documents, three of which need specialist authors, and one of which sets the programme. Figures and triggers here are illustrative; check your own authority's list.

When the officer asks for more after validation

A request after registration is not a validation matter. The application is valid, the clock is running (eight weeks for minor development, 13 for majors, 16 where EIA development is involved), and the officer is now gathering evidence to determine it.

You have four options. Supply the information. Agree an extension of time in writing so the authority does not refuse for lack of evidence. Argue that the point can be conditioned. Or decline, accept a refusal, and appeal on the merits with the evidence in hand.

Silence is the worst of the four. Authorities do refuse for insufficient information, and an appeal against that refusal is slower than a fortnight spent producing the report.

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

Enter your postcode on PlanScope to see which reports your site is likely to need before you open the council's checklist.