Planning Process

The local validation list and its two year review cycle

6 min readBy PlanScope Editorial Team

Article 11 limits validation requirements to a local list published within the preceding two years, with each item reasonable in scale and material to the decision.

A local planning authority can require documents beyond the national list only if those documents appear on a local list published on its website within the two years before the date of your application. That publication date is a hard requirement in article 11 of the Development Management Procedure Order 2015, and it is the single most useful fact an architect can hold when an officer asks for a survey the project plainly does not need. Each item on the list also has to be reasonable having regard to the nature and scale of the development, and about a matter it is reasonable to think will be material to the decision.

Two tests and a date. Most validation disputes are resolved by checking all three.

Where the power to set a local list comes from

The national requirements are fixed. The application form, the plans and drawings the form requires, the relevant ownership certificate, the agricultural holdings certificate, a design and access statement where one is required, the fee, and since 2024 the statements about whether the biodiversity gain condition applies.

Beyond that, article 11 allows the authority to require particulars or evidence it could reasonably have asked for, provided it has set them out in a published local list. The list is therefore the complete statement of what the authority can insist on at validation. Anything not on it is a request, not a requirement.

The distinction matters in practice. An officer can ask for a daylight study at any point during determination and can refuse the application if the absence of evidence means harm cannot be ruled out. What the officer cannot do is refuse to register the application for the want of a document that is not on the local list.

The tests a local requirement must meet

The Planning Practice Guidance on making an application sets out the two tests. A local list requirement should be reasonable having regard to the nature and scale of the proposed development, and it should be about a matter it is reasonable to think will be a material consideration in the determination of that application.

Read the second test carefully. It asks whether the matter will be material to this application, not whether the topic is sometimes material. A contaminated land assessment is clearly material on a former industrial site and clearly not material on a rear extension to a 1930s semi on a greenfield plot, even though the local list names it.

Challenge What to say
The item is not on the published list Article 11 limits requirements to the published list
The list was published more than two years ago The requirement cannot be enforced at validation
The item is disproportionate to a small scheme The first test, nature and scale
The topic cannot be material here The second test, with the site facts
The item duplicates another regime The requirement adds nothing to the decision

The review period and republication

The two year period runs from publication, so an authority that reviews and republishes its list keeps it enforceable, and one that does not loses the ability to insist on its local items. Checking the date is the first thing to do when a validation request looks wrong.

Ask directly. A polite email asking for the publication date of the current local list, and for the version in force on the date of the application, usually settles the matter either way. Authorities that have reviewed recently will say so, and the ones that have not will often drop the request.

Reviewing a list properly takes work, which is why some lists carry items that have drifted. So treat the date as a factual question rather than an accusation, and keep the correspondence.

Requirements that have fallen out of date

Old lists are easy to spot once you know the markers.

  • References to National Planning Policy Framework paragraph numbers, which were renumbered in December 2024 and replaced with policy codes in the August 2026 edition
  • Site waste management plans, required by regulations that were revoked in 2013
  • Requirements framed around superseded British Standards or guidance editions
  • Items that predate mandatory biodiversity net gain and sit awkwardly beside it
  • Energy statements written around an earlier Part L edition

An out of date reference does not by itself make a requirement unenforceable, but it is strong evidence that the list has not been reviewed within the period, and it gives you a specific thing to ask about rather than a general complaint.

Finding and reading the current list

Go to the source rather than a summary. The authority's planning pages carry the local list, usually as a table of requirements against application types, and the useful version is the full document rather than the web page summary.

Read it the way you would read a specification:

  1. Identify your application type, because requirements differ between householder, minor, major and listed building consent
  2. Note which items are triggered by a constraint, such as a flood zone, a conservation area or a tree, rather than applying to all applications
  3. Note which items are triggered by a threshold, such as floorspace or unit numbers
  4. Check the publication date and the review date on the document itself
  5. Where a trigger is ambiguous, ask the authority to confirm in writing which items apply to your scheme

That last step is worth the day it takes. A written list of the documents the authority expects, obtained before submission, converts validation from a risk into an administrative step. A planning statement that addresses each listed item by name also makes the validation officer's job quick, which helps more than it should.

Proportionality on small applications

Householder applications are where lists cause most friction. A requirement for a full transport statement, a biodiversity survey and a heritage appraisal on a single storey rear extension fails the first test, and the right response is to say which test the item fails and why, not to supply the document under protest.

Where a design and access statement is required nationally, provide one, and keep it proportionate: the national requirement attaches to major development and to development in a conservation area or World Heritage Site above defined thresholds, and a short, specific statement serves a small scheme better than twenty pages of context.

Fee reductions and exemptions are a separate matter from validation documents, and our note on planning fee exemptions and reductions covers where they apply.

Raising an item that should not be there

Do it in writing, politely, and at the right level.

Start with the case officer, setting out the item, the test it fails and the site facts. If that does not resolve it, escalate to the development management team leader or the validation team manager. Keep the exchange factual, because the next step is a formal complaint through the authority's corporate process, and ultimately to the Local Government and Social Care Ombudsman on grounds of maladministration.

An appeal is not usually the answer to a validation dispute, because an appeal against non-determination depends on there being a valid application in the first place. That asymmetry is why the written confirmation before submission matters so much.

One honest caveat: challenging a list item costs time, and on a small job the document sometimes costs less than the argument. Make that judgement commercially. But raise the point anyway, in writing, because lists get reviewed when enough applicants ask.

Browse the report types to see which documents a local list is likely to ask for on your application type.

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

How recent must a local validation list be?

It must have been published on the authority's website within the two years before the date of the application. Where the list is older than that, the local items cannot be enforced at validation. Ask the authority in writing for the publication date and for the version in force on your application date.

What tests does a local list item have to meet?

Two. It must be reasonable having regard to the nature and scale of the proposed development, and it must be about a matter it is reasonable to think will be a material consideration in determining that application. The second test asks about this application, not whether the topic is sometimes material.

Can an officer ask for a document that is not on the local list?

An officer can ask for anything during determination and can refuse the application if missing evidence means harm cannot be ruled out. What the authority cannot do is refuse to register the application for the want of a document that does not appear on the published local list.

How do I tell that a local list is out of date?

Look for references to superseded Framework paragraph numbers, site waste management plans required under regulations revoked in 2013, requirements framed around old British Standards editions, and items that predate mandatory biodiversity net gain. Those markers are evidence the list has not been reviewed within the period.

Can I appeal against a refusal to validate?

Not usefully. An appeal against non-determination depends on there being a valid application, so a validation dispute is not resolved that way. The practical route is written challenge to the case officer, escalation within the authority, then the corporate complaints process and the Local Government and Social Care Ombudsman.

Sources and further reading

validationlocal listdmpoplanning processarchitects

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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