Professionals and Qualifications

RICS registered valuers and viability appraisals

6 min readBy PlanScope Editorial Team

Viability work is governed by a mandatory RICS professional statement requiring objectivity whoever instructs. Here is what registration means, how the council's review works and how to survive it.

The viability appraisal author is the first thing a council's reviewer looks at, before any of the numbers. Financial viability work in planning is governed by a mandatory RICS professional statement, and valuations that fall within the Red Book have to be carried out by a registered valuer. An appraisal produced by a development manager in a spreadsheet, however accurate, carries less weight than the same figures signed by someone whose professional body can discipline them for getting it wrong.

That is the point of the regime. Viability arguments reduce what a scheme delivers in public benefit, so the evidence is held to a standard.

Why viability evidence attracts scrutiny

A viability case asks the authority to accept less affordable housing, or a smaller contribution, than adopted policy requires. The policy requirement was tested at plan making across the whole plan area, so the applicant is arguing that this site is different.

Councils have learned to be sceptical, and members more so. The result is that most authorities commission an independent review of any appraisal submitted, and the review is adversarial in substance even when it is polite in tone.

What valuer registration actually requires

RICS operates a valuer registration scheme for members carrying out valuations subject to the RICS valuation standards. Registration involves an annual declaration, monitoring of the firm's valuation practice, and compliance with the standards on competence, independence and reporting.

Not every calculation in an appraisal is a valuation. The gross development value and the benchmark land value are, and they are the two inputs a review concentrates on. So the practical test is whether the person setting those figures is a registered valuer with relevant local market experience, and whether the report says so.

Ask three questions before appointing. Is the individual a registered valuer. Have they valued this asset type in this market in the last year. And will they sign the report in their own name rather than in the firm's.

The professional statement that governs the work

The RICS professional statement on financial viability in planning sets mandatory requirements for members and regulated firms. Its central requirement is objectivity: the author must act with independence, professional scepticism and impartiality regardless of which party instructs them.

That has practical consequences that developers sometimes find uncomfortable. The author cannot adopt an input because the client prefers it. They have to disclose conflicts, including where the same firm is acting as planning agent on the scheme. And they have to report in a way that allows a reader to follow the reasoning from inputs to conclusion.

It cuts the other way too. A council's reviewer is bound by the same duty, and a review that simply adopts the council's preferred figures without reasoning is open to challenge on the same ground. Our note on independence and conflicts of interest in planning evidence covers how this plays out across disciplines.

How councils commission their own review

Most authorities keep a panel of viability consultants, or appoint case by case. The instruction is typically a review rather than a fresh appraisal: check the inputs, report on whether they are reasonable, and state what the outcome would be on the reviewer's own figures.

The review usually arrives as a report to the case officer, often with a confidential annexe. Ask to see it. Ask to respond to it in writing before it goes into the committee report, and ask for a meeting between the two valuers if the gap is wide. Valuer to valuer discussion narrows disputes far faster than correspondence through planning officers.

Stage Who acts Where time is lost
Appraisal submitted Applicant's valuer Inputs without stated sources
Review commissioned Authority, from a panel Fee agreement not in place, so the review has not started
Review reported Authority's valuer Confidential annexe not shared with the applicant
Response Applicant's valuer Responding to conclusions rather than to each input
Valuer meeting Both Arranged too late, after positions have hardened

Who pays for the review and how the fee is agreed

The applicant pays, by agreement with the authority, usually through a short letter agreement or as part of a planning performance agreement. Settle it early, because the authority will not instruct its reviewer until the fee arrangement is signed, and every week of delay there is a week added to the determination period.

Agree the scope as well as the sum. A review of a submitted appraisal is a different exercise from a full independent appraisal, and the difference shows in both the fee and the timetable. Where a second round of review is likely, agree what it will cost before the first round concludes.

Transparency and what gets published

Planning Practice Guidance expects viability assessments to be made publicly available, in an accessible form, with an executive summary. Redaction is limited to commercially sensitive material, and the reasons for withholding anything have to be given.

Plan for that from the outset. Structure the report so that the commercially sensitive material sits in a discrete appendix rather than threaded through the analysis, and write the executive summary as a document intended to be read by objectors and members. An appraisal written on the assumption that nobody outside the council will see it reads badly when it is published, and it will be published.

Preparing an appraisal that survives review

Six habits do most of the work.

  1. State the source and the date of every input, including the cost data, the location factor and the base date used for indexation.
  2. Derive benchmark land value on the basis the Guidance sets out, showing the existing use value calculation and the premium separately with the reasoning for each.
  3. Show the cash flow as well as the summary residual, so the finance cost can be traced.
  4. Justify the developer return by reference to the risk profile of this scheme rather than to a house standard.
  5. Avoid double counting: contingency inside build costs and again as a separate line is the classic error a reviewer finds first.
  6. Include a sensitivity analysis on the two or three inputs that drive the result, so the reader can see how far the conclusion can move.

Illustrative example: an appraisal where the benchmark land value rested on a single comparable transaction from four years earlier. The reviewer discounted it, the gap between the parties widened, and the application stalled. A revised appraisal that derived existing use value from the passing rent, applied a yield supported by three dated transactions, and set out the premium reasoning separately closed most of the gap in one round.

Councils usually expect a suitably qualified author for viability work, and professional review of any draft is strongly advised before submission. A Viability Assessment drafted with AI assistance is a starting point for that professional rather than a substitute for their judgement, and the professional directory is the route to a reviewer. Scoping the instruction properly at the outset is covered in writing a brief for a specialist planning report.

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

Does a viability appraisal have to be written by a registered valuer?

The valuation elements do. Gross development value and benchmark land value are valuations, and valuations falling within the RICS standards must be carried out by a registered valuer. Those two inputs are also where a council's review concentrates, so appoint someone registered with recent experience of the asset type in that local market.

What does the RICS professional statement require?

Objectivity above all. The author must act with independence, professional scepticism and impartiality regardless of which party instructs them, disclose conflicts including where the same firm acts as planning agent, and report so that a reader can follow the reasoning from inputs to conclusion. The council's reviewer is bound by the same duty.

Who pays for the council's viability review?

The applicant, by agreement with the authority, usually through a short letter agreement or within a planning performance agreement. The authority will not instruct its reviewer until that is signed, so settle it early. Agree the scope as well as the sum, and agree in advance what a second round of review would cost.

Will my appraisal be published?

Planning Practice Guidance expects viability assessments to be publicly available in an accessible form with an executive summary, with redaction limited to commercially sensitive material and reasons given. Structure the report so sensitive material sits in a discrete appendix, and write the summary for an audience of objectors and members.

What do reviewers find first?

Inputs with no stated source or date, and double counted contingency sitting inside build costs and again as a separate line. Benchmark land value resting on a single old comparable is the next most common weakness. Showing the cash flow rather than the residual alone, and adding a sensitivity analysis, removes most of the easy criticisms.

Sources and further reading

viabilityricsvaluationprofessionalssection 106affordable housing

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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