London

Large scale purpose built shared living in London

8 min readBy PlanScope Editorial Team

Shared living is not C3, not C4 and not an HMO, so the permission's own wording defines it. The H16 criteria, the contribution mechanism, and what boroughs actually test on room and communal space quality.

Shared living london planning policy sits in Policy H16 of the London Plan 2021, and the first thing to understand is that large-scale purpose-built shared living is a sui generis use. It is not Class C3 housing, not Class C4, and not a house in multiple occupation in the way a converted terrace is. Nothing in the use classes order describes it, so the description of development, the conditions and the section 106 obligations define what has been permitted and what it can become later.

That status drives everything else in the policy: why the affordable housing requirement arrives as a cash contribution rather than as units, why single management is a criterion rather than a preference, and why a borough will scrutinise whether the site should have delivered conventional homes instead.

What the policy treats as shared living

The policy addresses large-scale schemes of private rooms with substantial shared facilities, under one operator, let on a single agreement covering the room and access to the communal provision. The scale is what distinguishes it from a converted house in multiple occupation, and it is the scale that brings it within H16 rather than within the HMO policies boroughs apply elsewhere.

Three features define the product in policy terms. Occupiers rent a private room or studio rather than a self-contained flat with full facilities. Substantial communal space, usually kitchens, dining, lounge, workspace and sometimes gym and laundry, replaces what would otherwise be inside each unit. And the building is operated as a single entity with on-site management rather than being sold off room by room.

Because the units are not self-contained homes, the Plan treats the accommodation as non-self-contained for housing supply purposes, counting towards housing targets on a stated ratio basis rather than one for one. Check the current ratio in the Plan and in the borough's monitoring before making any claim about housing delivery.

The criteria a scheme has to meet

H16 is a list of criteria that have to be satisfied together, and schemes typically satisfy most and treat the awkward ones as negotiable. The awkward ones are where applications fail.

Criterion What the borough tests
Contributes to a mixed and inclusive neighbourhood Whether the scheme is a single-use block in an area already dominated by one tenure
Good quality space and layout Private unit size, daylight, aspect and the usability of communal space
Sufficient communal facilities and services Area per occupier, the range of facilities and whether they are actually accessible
Single management One operator, on-site, with a management plan
Minimum tenancy length Lettings of no less than three months, secured by obligation
Affordable housing A cash in lieu contribution towards conventional affordable housing
No loss of conventional housing capacity Whether the site could and should deliver Class C3 homes
Connectivity Walking, cycling and public transport access to services and jobs

The minimum tenancy length matters more than it looks. It is the line between shared living and short-term letting, and it is the provision that stops the building operating as serviced apartments. Boroughs secure it by obligation and expect compliance reporting.

Room sizes and shared amenity provision

The Plan does not set unit sizes in the policy text. The Mayor's published guidance on large-scale purpose-built shared living gives reference figures for private unit area and for communal space per occupier, and that guidance has been revised, so work from the current version rather than from a scheme approved three years ago.

What officers assess in practice, whatever the figures say:

  • Whether the private unit works as a place to live rather than as a hotel room, including storage, a study position and somewhere to prepare a simple meal.
  • Daylight and aspect. Single aspect rooms facing a light well are where these schemes get refused, and in a dense London context the modelling approach matters, as set out in applying BRE 209 daylight guidance in dense London.
  • Whether the communal space is distributed through the building or concentrated on one floor that residents on the ninth storey will never use.
  • Whether the communal kitchens can realistically serve the number of occupiers at the same time of evening.
  • External amenity space, which is often the weakest element and is usually a roof terrace competing with plant and photovoltaics.

The design-led capacity work that reconciles unit numbers with quality is the same exercise described in optimising site capacity under London Plan Policy D3.

Management and tenancy expectations

The management plan is a planning document here, not an operational afterthought, and boroughs condition it.

It should cover the letting policy and how the minimum tenancy is enforced, the staffing model including whether management is present overnight, cleaning and maintenance of communal areas, waste arrangements sized for the occupancy rather than for a notional dwelling count, a complaints procedure with a contact for neighbours, and the arrangements at turnover periods when many moves happen at once.

Two things to deal with explicitly because objectors raise them. Noise from communal areas and roof terraces, with a curfew and a management response. And the absence of allocated parking, which means a car-free obligation with occupiers excluded from residents parking permits where a controlled zone exists.

The financial contribution and how it is calculated

Because the accommodation is not conventional housing, affordable units cannot sensibly be provided within it. H16 therefore requires a cash in lieu contribution towards conventional affordable housing elsewhere, paid to the borough.

The calculation methodology sits in the Mayor's guidance rather than in the policy text, and it has been revised since the Plan was published. Establish the current method at pre-application, because the figure is large enough to determine whether the scheme is viable and it goes straight into the section 106 obligation.

Three practical points. Agree the floorspace basis for the calculation early, since definitions of what counts vary and a dispute late in the process costs weeks. Expect the borough to seek indexation and a payment trigger tied to implementation rather than to occupation. And where the contribution is said to make the scheme unviable, a Viability Assessment will face the same difficulty that student accommodation appraisals face, namely that shared living values rest on operational income and operator covenant rather than on residential sales comparables. Say so rather than presenting a conventional residual appraisal as though the inputs were equivalent.

Why the sui generis status matters

A sui generis permission is defined entirely by its own terms, which cuts both ways.

For the borough it means there is no automatic right to change to another use, because shared living is not within a class that permits movement. Every change needs permission, which is why conditions restricting the use to large-scale shared living as defined in the application are standard.

For the applicant it means the description of development has to be drafted with care. A loose description risks consenting something broader than intended, and a description that is too tight can prevent sensible operational flexibility later. Agree the wording with the case officer rather than importing it from another scheme.

It also means permitted development rights that apply to C3 housing do not apply here, and the office to residential route under the prior approval classes is not a way to deliver shared living. Where a site is being promoted on the back of an office conversion story, that is worth checking at the outset, and the position in London is complicated by the directions discussed in Article 4 directions in London and office to residential.

Evidencing the case to the borough

A submission that answers the policy criterion by criterion is far more persuasive than one organised by document type. Structure the planning statement around H16, with a heading per criterion and the evidence under it.

Five items carry the most weight. A demonstration that the site is not required for conventional housing, referencing the development plan allocation and the borough's housing trajectory. The design evidence on unit quality, daylight and communal provision. The draft management plan, submitted with the application rather than deferred. The heads of terms for the contribution, the minimum tenancy obligation and the car-free obligation. And the transport evidence showing the connectivity criterion is met.

Where the building reaches 18 metres or seven storeys it falls within the higher-risk building regime, so a Fire Statement is required at Planning Gateway One and must be prepared by someone with the necessary fire engineering competence. PlanScope's draft is a starting point for that professional, not a substitute for them.

One honest uncertainty. Shared living policy is less settled than the rest of the housing chapter, boroughs apply it with varying enthusiasm, and the Mayor's guidance has moved. Build the case on the policy text and the current guidance, and expect to argue it rather than to cite it.

Enter your postcode on PlanScope to see which reports a London shared living scheme 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.

Frequently asked questions

What use class is large scale shared living in?

None. It is sui generis, so the description of development, the conditions and the section 106 obligations define what has been permitted. There is no automatic right to change to another use, and permitted development rights that apply to Class C3 housing do not apply, including the office to residential prior approval route.

How is affordable housing provided in a shared living scheme?

As a cash in lieu contribution towards conventional affordable housing elsewhere in the borough, because affordable units cannot sensibly be provided within non-self-contained accommodation. The calculation method sits in the Mayor's guidance rather than in the policy text and has been revised, so establish the current approach at pre-application.

Is there a minimum tenancy length for shared living?

Yes. Policy H16 expects lettings of no less than three months, secured by a section 106 obligation with compliance reporting. It is the provision that separates shared living from short-term letting and stops a scheme operating as serviced apartments, so boroughs enforce it closely.

Does shared living count towards housing targets?

Not one for one. Because the units are not self-contained, the Plan treats the accommodation as non-self-contained and counts it towards housing targets on a stated ratio basis. Check the current ratio in the Plan and the borough's monitoring before making any claim about housing delivery in a planning statement.

What should a shared living management plan cover?

The letting policy and how the minimum tenancy is enforced, the staffing model including overnight presence, cleaning and maintenance of communal areas, waste sized for the actual occupancy, a complaints procedure with a neighbour contact, arrangements for turnover periods, and noise management for communal areas and roof terraces.

Sources and further reading

shared livingco-livinglondon planpolicy h16sui generislondon

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.

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