RICS registered valuers and viability assessments in planning
Viability turns on valuations, and valuation is regulated. Here is what registration means, what the standard requires, and how to brief a viability consultant.
A viability assessment submitted with a planning application should be prepared by an RICS registered valuer, because the numbers that decide it are valuations and valuation is a regulated activity. Ask about RICS registered valuer viability requirements and the answer has two parts: the author needs the right registration and competence, and the assessment has to follow the professional standard that governs viability work in planning. Councils increasingly refuse to engage with appraisals that fail either test, and they charge you for the review that establishes it.
Why the valuer's status matters to the council
Viability turns on three valuations: the gross development value of the completed scheme, the benchmark land value of the site, and the cost of construction. Two of those are valuations in the professional sense and the third depends on cost data applied with judgement.
RICS operates a valuer registration scheme, under which members carrying out valuations that fall within the scope of its valuation standards are registered and monitored. Registration is a quality assurance mechanism: it confirms the individual is subject to the standards, the monitoring regime and the disciplinary process.
For a council, that is the difference between a document it can test and a document it can only disbelieve. An appraisal produced by a developer's in-house team is not worthless, and it does not carry the same weight as one signed by a registered valuer who has to defend it professionally.
What the professional standard expects of the author
RICS publishes a professional standard on assessing viability in planning in England, which sits alongside the valuation standards. It sets expectations about objectivity, the treatment of inputs, and the way the assessment is presented.
Three of those expectations matter most in practice.
The author has to act with objectivity and independence, even though the applicant pays the fee. Advocacy is the job of the planning consultant, not of the valuer.
Inputs have to be evidenced and stated, not embedded. Sales values need comparable evidence, build costs need a stated source and base date, and the developer return has to be justified as a return appropriate to the risk.
The assessment has to be prepared on the basis that it will be published. National planning practice guidance is explicit that viability assessments should be made publicly available, other than in exceptional circumstances, and that they should be presented in a way that is simple, standardised and transparent.
How councils commission their own review
Most authorities do not assess viability in house. They appoint a reviewer, usually a valuation practice on a framework, and recover the cost from the applicant under a fee agreement signed before the review starts.
That review will test the benchmark land value first, because it is the input with the widest range of defensible answers. National guidance sets the approach as existing use value plus a premium to the landowner, with the premium justified by evidence rather than asserted, and it warns against benchmark land values based on prices that assume policy compliance is not required.
The reviewer will then work through sales values against comparables, build costs against published cost data and any scheme-specific abnormals, professional fees, finance assumptions, the programme and the developer return. Where the numbers disagree, the argument usually narrows to two or three inputs and it can be resolved in a meeting.
Budget for it. And build the review into the programme rather than treating it as a contingency. On a scheme of any size, expect the review fee, a round of questions, and a revised appraisal. Building three or four weeks into the programme for that exchange is more realistic than assuming the first submission stands.
One point worth settling at the outset is who the reviewer will be. Where the authority has a framework, ask which practice is likely to be appointed and whether it has advised on the council's own local plan viability evidence. That is not an attempt to influence the appointment. It tells you which assumptions the reviewer already holds, and it saves an argument about cost data that has already been settled elsewhere in the borough.
Transparency and publication of viability evidence
Publication changed behaviour when it came in. An appraisal written in the knowledge that objectors, the parish council and the local press will read it is a different document from one written for the case officer alone.
Requests for confidentiality are still made, and they are granted rarely. If real commercial sensitivity exists, identify the specific figures, explain the harm disclosure would cause, and accept that the substance of the assessment will be published regardless.
The practical consequence for the author is that the assessment has to be readable. A model dumped into an appendix with no narrative explaining the inputs invites the reviewer, and then the objectors, to fill the gap with their own assumptions.
Where assumptions are challenged
The same handful of inputs generate almost all viability disputes.
| Input | Common challenge |
|---|---|
| Benchmark land value | Based on an offer or an actual price paid rather than existing use value plus a justified premium |
| Sales values | Comparables from a different location, product type or date, without adjustment |
| Build costs | Published cost data used without a stated base date, or abnormals asserted without a quantified basis |
| Developer return | A single figure applied to the whole scheme regardless of tenure or risk profile |
| Finance and programme | Interest and holding costs modelled on a programme longer than the scheme needs |
National guidance indicates a range of return on gross development value that may be considered appropriate for market housing, with a lower return generally appropriate for affordable housing where the risk is lower. Use the guidance range, state the figure, and justify any departure from it with scheme-specific reasoning.
Where a scheme cannot support the policy requirement, say so with the evidence and propose a review mechanism. Early and late stage review clauses in a section 106 agreement are a normal answer to uncertainty, and offering one voluntarily is often more persuasive than arguing for a lower contribution outright.
Selecting and briefing a viability consultant
Ask for six things before appointment.
- Confirmation that the individual signing the report is an RICS registered valuer.
- Experience of viability work in planning, and specifically of the authority's own viability evidence base for its local plan.
- Confirmation that they will work to the current RICS professional standard on viability in planning.
- Acceptance that the assessment will be published.
- Professional indemnity cover appropriate to the scheme value.
- A fee that includes responding to the council's reviewer, with a stated number of rounds.
Give the valuer the planning position clearly: the policy requirement for affordable housing and the tenure split, the anticipated section 106 heads of terms, the levy position, and the programme. A viability assessment prepared without knowing what obligations are being tested against is a number without a question.
A Viability Assessment is a report type where councils expect a suitably qualified author and professional review is strongly advised. The same applies to the Affordable Housing Statement that sits alongside it, since the two documents have to describe the same scheme, the same tenure mix and the same unit numbers. Where you need a reviewer to check and sign off a draft, the professional directory is the route PlanScope provides.
This is general guidance, not legal advice, and viability policy and professional standards are updated periodically, so check the current RICS standard and national guidance 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 assessment have to be written by an RICS registered valuer?
It is not a statutory requirement, but the assessment rests on valuations of gross development value and benchmark land value, which fall within the RICS valuation standards. Councils and their reviewers give far more weight to a report signed by a registered valuer who is subject to monitoring and a disciplinary process.
Will my viability assessment be published?
Almost certainly. National planning practice guidance says viability assessments should be made publicly available other than in exceptional circumstances, and should be simple, standardised and transparent. If specific figures are commercially sensitive, identify them and explain the harm, but expect the substance to be published.
How is benchmark land value supposed to be calculated?
As existing use value plus a premium to the landowner, with the premium justified by evidence rather than asserted. National guidance warns against benchmark values derived from a price paid that assumed policy requirements would not apply. It is the input reviewers test first because it has the widest defensible range.
Who pays for the council's review?
The applicant, under a fee agreement signed before the review begins. Most authorities appoint a valuation practice from a framework rather than assessing viability in house. Allow programme time for the reviewer's questions and a revised appraisal, since a first submission rarely stands unamended.
What developer return is acceptable?
National guidance indicates a range expressed as a percentage of gross development value for market housing, with a lower return generally appropriate for affordable housing where risk is lower. State the figure used, apply it consistently by tenure, and justify any departure with scheme-specific reasoning.
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.