Repurposing a former bank branch within Class E

A former bank branch change of use is usually easier than it looks, because financial and professional services moved from Class A2 into Class E(c) of the Town and Country Planning (Use Classes) Order 1987 on 1 September 2020. A change from the former bank use to a shop, a cafe or restaurant, a gym, a clinic, a nursery or an office is a change within Class E and is not development, so no planning permission is needed for the use itself. What still needs consent is almost everything you want to do to the building.

And one thing can undo all of it: a condition on an earlier permission restricting the unit to Class A2.

Where former financial services uses now sit

Class E(c) covers the provision of financial services, professional services other than health or medical services, and other services appropriate in a commercial, business or service locality. A bank branch is squarely within the first limb.

Because the whole of Class E is one class, movement between its limbs is not a material change of use.

The last four rows are where applicants come unstuck. A bank converting to a bar or a takeaway is a change out of Class E and needs a full application, with the usual arguments about noise, odour, hours and cumulative impact in a town centre.

Changes that need no permission for the use

If the proposed use sits inside Class E, you can occupy and trade without a planning application, subject to there being no condition or Article 4 direction to the contrary.

Check three things before you rely on that. Pull the planning history for the unit from the authority's online register. Check whether an Article 4 direction has removed any relevant permitted development right in the area. And confirm the lawful use is what you think it is, since a branch that closed in 2012 and has been used as a charity shop since may have a different lawful use.

If the answer matters commercially, a Lawful Development Certificate under section 192 of the Town and Country Planning Act 1990 for the proposed use is the only formal confirmation available. It is not expensive relative to a fit-out.

Conditions left over from the original permission

Banks were often built or converted under permissions carrying tight conditions, because authorities wanted to control the loss of retail frontage. A condition restricting the premises to use "as a bank within Class A2" continues to have effect and is read against the use classes as they stood when it was imposed.

That condition overrides the freedom within Class E. While it stands, a change to a cafe needs either a section 73 application to vary it or a fresh application for the new use, with full consultation and a determination period of eight weeks or more.

Other conditions to look for: restrictions on opening hours, on servicing times, on the installation of plant, on the use of the forecourt, and conditions removing permitted development rights for alterations. Our note on varying an opening hours condition sets out the section 73 route, and the same approach applies to a use class condition.

A planning statement addressing the frontage policy and the reasons the original condition is no longer necessary is what a variation application turns on.

Shopfront alterations and signage

Bank frontages are distinctive and often protected. Stone surrounds, deep reveals, bronze or timber joinery and large plate glass panels are typical, and a good proportion of branch buildings are listed or sit in a conservation area.

External alterations materially affecting the appearance of the building need planning permission in their own right, regardless of the use class position. On a listed building, listed building consent is needed for works affecting character, including internal works, and that is a separate application with its own test.

Signage needs advertisement consent where it is not covered by deemed consent, and illuminated signage almost always does. Removing an existing bank fascia and replacing it with an internally illuminated box is the single most common enforcement issue on these conversions.

Cash machine apertures left in the facade are development when they are filled or altered, and the surround is often an advertisement in its own right. Deal with them on the drawings.

Vaults, strongrooms and internal fabric

The vault is the surprise in the programme. Reinforced concrete walls of 300 millimetres or more, a steel door weighing several tonnes and no realistic removal route through the shopfront are the normal conditions.

Internal works to a building that is not listed generally do not need planning permission, because works affecting only the interior and not materially affecting the external appearance fall outside the definition of development in section 55 of the Town and Country Planning Act 1990. Removing a vault is therefore usually a structural and party wall question rather than a planning one.

It is still a question. The vault may be carrying load, and in a terrace the party wall is likely to be involved, which brings in the Party Wall etc. Act 1996 and a notice to the adjoining owner. A structural survey is the document to commission before you price the strip-out, and councils usually expect a suitably qualified author for structural work.

Where the building is listed, the vault may itself be of interest as evidence of the building's historic function, and consent to remove it is not a formality.

Step-free access and the frontage

Bank entrances commonly sit two or three steps above the pavement, with a deep threshold and a heavy door. Making the unit accessible is where planning, highways and the Equality Act 2010 meet.

A ramp inside the building loses floor area and may not achieve the gradient. A ramp outside usually means working on the public footway, which needs the highway authority's agreement under the Highways Act 1980 and may need permission where it materially affects appearance. A platform lift is often the practical answer and needs a pit, which brings the ground floor slab and any basement into play.

Design reference is BS 8300 for accessible buildings. Planning will not enforce it, but a nursery, clinic or gym that cannot be reached by a wheelchair user has a problem that will surface eventually.

Residential above the branch

Upper floors over a branch were frequently used as storage, staff accommodation or nothing at all, and converting them is often the value in the deal.

Two routes exist. Prior approval under Class MA of Part 3 of the General Permitted Development Order 2015 allows a change from Class E use to residential, subject to the building having been in Class E use for a continuous period before the application and to a list of exclusions covering listed buildings, scheduled monuments, sites of special scientific interest and safety hazard areas among others. Class MA has been amended more than once, so read the current text rather than a summary. The alternative is a full planning application, which gives more design freedom and no prior approval conditions to satisfy.

The practical obstacle is access. A separate entrance from the street for the upper floors is usually essential, and on a mid-terrace branch with the full width given to the banking hall there may be nowhere to put one. Resolve that on a sketch before you model the scheme, and look at whether splitting the ground floor creates the hallway you need, as our note on splitting a commercial unit into two discusses.

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.