Reserved matters fees and how the outline stage affects them
A reserved matters submission is charged as though it were a full application for the whole scheme, until the total paid reaches that amount. Grouping and phasing decide your cash flow.
The fee for an application to approve reserved matters is calculated as though it were an application for full planning permission for the whole of the development that the outline permission allowed. That is the rule that surprises people, because it means a submission dealing only with landscaping can attract the same fee as a full application for the entire scheme.
There is a counterweight. Once the total paid across reserved matters submissions reaches the amount that would have been payable for a full application for the whole development, later submissions attract only the flat minimum fee. So the order and the grouping of your submissions decides what you pay, and on a phased consent that difference runs into real money.
How the outline fee is calculated
An outline application is charged on site area rather than on unit numbers. The national fee schedule sets an amount per 0.1 hectare up to a threshold area, then a reduced rate above it, with an overall cap. The area used is the application site area, which is the area inside the red line, so a red line drawn generously around a scheme costs money at the outline stage and keeps costing it later.
Fees are revised, and since the change to indexed uprating they move more often than they used to. Use the current schedule rather than a figure from a previous project, and check whether your authority's online calculator has been updated, because it lags.
Two practical points at outline stage. Reserved matters are limited to access, appearance, landscaping, layout and scale, and anything not reserved is fixed by the outline permission. And the more you reserve, the more submissions you make later, which is a fee and programme decision rather than only a design one.
The reserved matters fee basis and the minimum charge
| Situation | Fee basis |
|---|---|
| First reserved matters submission | As if a full application for the whole development permitted by the outline |
| Later submissions, total paid still below that amount | The balance, calculated on the same basis |
| Later submissions, total already paid reaches that amount | The flat minimum fee |
| A further submission on a matter already approved | Charged as a new application, subject to the same running total |
| Discharge of a condition that is not a reserved matter | The separate flat fee per request |
The running total is the mechanism worth understanding. It is calculated against the fee that a full application for the whole development would have attracted, not against the outline fee you paid, and the two are usually very different because one is area based and the other is unit based.
A worked illustration. An outline permission for 40 dwellings on 1.6 hectares reserves all five matters. If layout, scale and appearance are submitted together for the whole site, that one submission carries the full-application-equivalent fee, and the later landscaping and access submissions cost the minimum. If instead each matter is submitted separately for each of four phases, the first few submissions absorb the full amount in instalments and the rest are at the minimum. The total is broadly similar. What differs is cash flow and the number of eight week determination periods you have to programme. This example is illustrative only.
Submitting reserved matters in phases
Phased submission is normal on anything larger than a single parcel, and the fee rules accommodate it, but two conditions have to be right.
The outline permission must permit phasing. If the conditions require all reserved matters to be submitted together, or require approval of a phasing plan first, a phased submission is invalid regardless of the fee. Read the conditions before the fee schedule.
And each submission must cover a coherent parcel. A submission for the layout of phase 2 that depends on an access arrangement not yet approved in phase 1 leaves the officer unable to determine it, and that is a practical problem the fee rules do not solve.
Where phasing is permitted, the useful pattern is to group layout, scale and appearance for each phase into a single submission, and to keep landscaping separate because it is usually the matter that takes longest to agree and the one you least want holding up the rest.
Where a further submission on the same matter is charged
Coming back on a matter already approved, whether because the design has moved or because the approval has lapsed, is a fresh application for approval of reserved matters and is charged accordingly, subject to the same running total. The free resubmission concession that applies to applications for planning permission does not translate neatly here, so confirm the position with the authority in writing before assuming it.
Where the change is to something already approved, the alternative routes are a non-material amendment under section 96A of the Town and Country Planning Act 1990, which is quick and carries a small fee, or a variation of condition under section 73, which is a full application with its own fee. Section 73 cannot be used to extend the time limits on the permission, so it is no answer to a lapsing consent.
Time limits that govern the whole exercise
Section 92 of the Town and Country Planning Act 1990 sets the default framework. An application for approval of reserved matters must be made within three years of the grant of outline permission unless a condition provides otherwise, and the development must be begun within two years of the final approval of the last reserved matter.
Authorities frequently vary those periods by condition, and on large sites a longer outline period is common. Read the condition rather than the default, diarise both dates, and remember that a reserved matters application made one day late is not a late application, it is no application at all.
That is the cost risk that dwarfs the fees. A lapsed outline permission on a site with a fresh plan policy position can be unrecoverable.
Conditions discharged alongside reserved matters
Most outline permissions carry a dozen or more conditions requiring details before work starts, and those are not reserved matters. They are discharged through a separate request, each attracting the flat per-request fee, and a single request can cover several conditions.
Two savings. Group conditions into one request where they relate to the same phase and the same discipline, because the fee is per request rather than per condition. And check whether any condition duplicates a reserved matter, because a condition requiring landscaping details where landscaping is already a reserved matter is arguably unnecessary and can be dealt with in the reserved matters submission.
Budget the condition discharge fees explicitly. On a phased site they routinely exceed the reserved matters fees in total, and they arrive at the worst point in the cash flow.
Programming fees across a phased consent
- Read the outline conditions and list every submission the permission requires, with its deadline.
- Calculate the full-application-equivalent fee for the whole development, because that figure is your reserved matters ceiling.
- Decide the grouping of matters and phases, then model the cash flow rather than the total.
- Add the condition discharge requests, grouped by phase and discipline.
- Diarise the three year submission deadline and the two year implementation deadline.
- Recheck the current fee schedule at each submission, since indexation moves the figures.
Where the authority then fails to determine within the statutory period, the position on a fee refund for non-determination is worth knowing, because it applies to reserved matters submissions too. And on a phased site the other budget line that is habitually understated is infrastructure, so read this alongside utility connection costs in a development budget.
This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it.
Drafting the supporting documents for each phase is the other recurring cost. See PlanScope pricing: one free report, £50 per report, or Professional for unlimited reports. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.
Frequently asked questions
How is a reserved matters fee calculated?
As though the submission were an application for full planning permission for the whole of the development the outline permission allowed. Once the total paid across reserved matters submissions reaches that amount, later submissions attract only the flat minimum fee. The running total is measured against the full application equivalent, not against the outline fee paid.
Is the outline fee based on units or site area?
Site area. The national schedule charges an amount per 0.1 hectare up to a threshold, a reduced rate above it, and an overall cap. The area used is the area inside the red line, so a generously drawn application boundary costs money at outline stage. Fees are indexed, so use the current schedule rather than an earlier figure.
Can reserved matters be submitted in phases?
Usually, provided the outline conditions permit it and each submission covers a coherent parcel that can actually be determined on its own. Some permissions require all matters together, or require a phasing plan to be approved first. Read the conditions before the fee schedule, because an invalid submission wastes both.
What are the time limits for reserved matters?
Section 92 of the Town and Country Planning Act 1990 sets a default of three years from the grant of outline permission to make the reserved matters application, and two years from final approval of the last matter to begin development. Conditions often vary both, so read the condition. A late submission is no submission at all.
Do condition discharge requests carry the same fee?
No. Discharging a condition that is not a reserved matter attracts a separate flat fee per request, and one request can cover several conditions. Group conditions by phase and discipline to reduce the number of requests. On a phased site these fees often exceed the reserved matters fees in total.
Can section 73 be used to extend an outline permission?
No. Section 73 allows variation of conditions but cannot be used to extend the time limits for implementation, so it is no remedy for a permission about to lapse. For a small change to something already approved, a non-material amendment under section 96A is quicker and costs less than a fresh application.
Sources and further reading
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.