Part 5: caravan sites and certificated recreational sites

Caravan site permitted development is narrower than most landowners hope and wider than most planning officers expect. Part 5 of Schedule 2 to the Town and Country Planning (General Permitted Development) (England) Order 2015 grants planning permission for the use of land, other than a building, as a caravan site, but only in the circumstances set out in paragraphs 2 to 10 of Schedule 1 to the Caravan Sites and Control of Development Act 1960, the cases in which a caravan site licence is not required. The permission tracks the licensing exemptions exactly. If your situation is not one of those exempt cases, Part 5 gives you nothing.

That link between the two statutes is the whole of the rule, and it explains why the question "do I need planning permission for caravans on my land" cannot be answered without first asking whether a site licence would be required.

The exempt circumstances in the 1960 Act schedule

Schedule 1 lists the cases where no site licence is needed. Set aside the first, which deals with use within the curtilage of a dwellinghouse incidental to its enjoyment, because Part 5 picks up from the second. The remainder cover, in substance:

• a person travelling with a caravan who stops for one or two nights, with a limit on the number of caravans and a restriction where the land has already been used for caravans in the preceding twelve months
• land forming part of a holding of five acres or more, used for not more than 28 days in any twelve month period, with not more than three caravans on the land at any time
• land occupied by an organisation holding an exemption certificate from the Secretary of State, used for the purposes of that organisation
• land certificated by such an organisation for the use of its members, limited to five caravans at a time
• a meeting organised by an exempted organisation
• seasonal accommodation of agricultural and forestry workers employed on land in the same occupation
• building and engineering sites, for people employed there
• land occupied by travelling showmen during the winter months
• land occupied by a local authority

Each of those has conditions attached in the schedule itself, and the conditions are where claims fail. The five acre case is the one most often misread. It allows three caravans for 28 days, not three caravans permanently and not an unlimited number for 28 days, and the 28 days are counted across the whole twelve month period rather than per visit.

Certificated sites and the five caravan limit

The certificated location is the route that interests most farms and smallholdings. An organisation with an exemption certificate can certify land for the use of its members, and while that certificate is in force up to five caravans may stand on the land without a site licence. Part 5 then supplies the planning permission for that use.

What the certificate does not do is turn the land into a caravan site for any other purpose. Admit a sixth caravan, let non-members stay, or keep taking bookings after the certificate lapses, and both the licensing exemption and the planning permission fall away on the same day. The use becomes a material change of use requiring an application, and because there was never a permission to breach, enforcement can follow directly.

Certificates are issued for a period and to a specified piece of land. Keep the paperwork, the site plan the organisation approved, and the booking records. When an enforcement officer visits following a neighbour complaint about a row of units in a field, the certificate and the occupancy log are the only two documents that matter.

Limits on numbers, duration and who may occupy

Three limits recur across the schedule and are worth treating as a single discipline.

Numbers are counted as caravans present at one time, not pitches marked out. Duration is counted in days of use, and a part day counts. Occupancy is restricted by status in several of the cases, whether that is members of an organisation, workers employed on the holding, or people employed on a building site.

Part 4 Class B of the same Order, the familiar 28 day temporary use right, does not help here: it expressly excludes the use of land as a caravan site. So a landowner cannot stack a Part 4 Class B 28 days on top of the five acre exemption's 28 days to reach 56. The guidance on the 50 per cent curtilage rule for garden outbuildings shows the same pattern in a different part of the Order, where one right cannot be used to extend another.

What is a caravan is also a statutory question. Section 29 of the 1960 Act defines it, and section 13 of the Caravan Sites Act 1968, as amended, sets the dimensions for twin-unit structures brought onto the land in sections: 20 metres in length, 6.8 metres in width and 3.05 metres of internal height. Exceed those and the structure is not a caravan. It is likely to be a building, which takes the proposal out of Part 5 altogether and into an application for a new dwelling or holiday unit.

Works, services and hardstanding that Part 5 does not cover

Part 5 Class A permits a use. It does not permit operational development.

Forming a new vehicular access, laying hardstanding or an internal road, installing a package treatment plant, erecting an amenity block, putting up a reception hut, running in services and installing lighting columns are all building or engineering operations. Each needs its own planning permission unless another class in Schedule 2 covers it, and on a greenfield site in open countryside most will not be covered. This is where otherwise lawful certificated sites run into trouble, because the use is permitted and the infrastructure around it is not.

Part 5 Class B does permit works on land already used as a caravan site where those works are required by a condition of a site licence. That is a narrow power. It applies only where a licence exists, so it does nothing for an exempt site that has no licence at all.

Article 4 directions can withdraw Part 5 rights, and a few authorities have made them over sensitive landscapes. Check the authority's register of directions before relying on the Order, in the same way you would for householder rights.

Site licensing where the exemption does not apply

If the exemption does not apply, you need both planning permission and a site licence, and the order of operations is fixed by statute rather than by preference. A local authority may not issue a site licence to an applicant who is not entitled to the benefit of a planning permission for the use of the land as a caravan site, and a permission granted by a development order does not count for that purpose. Permitted development under Part 5 will not support a licence application.

So the sequence is: planning application, permission, then licence application, then licence conditions drawn from the model standards for caravan sites in England that the Ministry of Housing, Communities and Local Government publishes. Those standards govern spacing between units, which is where the number of pitches you can actually fit gets settled. Design the layout against them before you fix the figure in your planning application.

Where a full application is the only route

Any of the following takes you out of Part 5 and into an application: more than five caravans on a certificated site, year round occupation, occupation by people with no qualifying connection to the land or an organisation, static units that exceed the twin-unit dimensions, a holiday park with reception and amenity buildings, or a change from touring pitches to residential occupation.

The application needs a Planning Statement that addresses the principle of the use in a countryside location, the local plan policy on rural tourism or rural workers, and the landscape and highway effects. Where the land is in a National Landscape or a Green Belt, the landscape and openness arguments do most of the work, and the same discipline applies as in a barn conversion under Class Q or a vacancy-tested Class MA conversion: evidence the factual preconditions before you argue the policy.

One honest uncertainty: authorities take different views on whether repeated use of the five acre exemption in consecutive years, on the same patch of a field, amounts to a material change of use through intensification. The schedule sets a 28 day limit per twelve months and says nothing about how many years in a row you may do it. If the pattern is becoming permanent in substance, a certificate of lawful existing use or an application is the safer route.

Enter your postcode on PlanScope to see which reports a caravan or holiday site at that location is likely to need, including the landscape and drainage documents rural applications usually turn on. Start from the home page.

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