Validation checklist: national and local requirements

A planning validation checklist has two halves. The national requirements are set by the Development Management Procedure Order 2015 and apply everywhere. The local list is published by each authority under its own power, has to be reviewed regularly, and is the reason a submission that validated in one district gets returned in the next.

Most invalidations are administrative. Wrong fee, missing certificate, a location plan without a north point. The frustrating ones are the requests for technical reports that the scale of the development does not justify, and those can be challenged.

The national requirements

Every application for planning permission has to include the standard application form, a plan identifying the land, any other plans and drawings necessary to describe the development, the fee, and the certificates relating to ownership and agricultural holdings. A design and access statement is required for the categories of development the Order specifies, which include major development and certain development in conservation areas and World Heritage Sites, and for listed building consent applications.

Two further national items have joined that list in recent years. Applications for development caught by the biodiversity gain regime must include the information the legislation requires about whether the biodiversity gain condition applies, and applications for relevant buildings must include a fire statement under the fire safety provisions of the Order.

The national requirements are not negotiable. An authority cannot waive them, and an application missing one of them is invalid whatever the case officer has said informally.

How a local list is adopted

Local planning authorities may publish a list of further information they require with applications. The legislation places conditions on that power. The list must be published, it must have been published or reviewed within the period the Act specifies, and each item must be reasonable having regard to the nature and scale of the development proposed and must relate to a matter it is reasonable to think will be a material consideration in determining the application.

That last phrase carries the weight. A request has to be about something material to the decision, and it has to be proportionate to the application in front of the officer.

Lists are usually organised by application type with triggers attached, and the good ones state the threshold. The ones that cause arguments are written as a list of documents with no trigger, which invites a validation officer to request everything.

Why a local list cannot ask for anything it likes

Three limits apply in practice.

1. The item must be on the published list. A requirement invented at the counter is not a validation requirement.
2. The list must be current. A list published years ago and never reviewed cannot be relied on.
3. The request must be reasonable for the development proposed. A full transport assessment for a two dwelling infill scheme is not.

The Order provides a route for an applicant who disagrees. Where an authority declines to validate because of a local list item, the applicant may give written notice setting out why the request is not reasonable, and the authority has to respond within a set period. Check the current text of the Order for the wording and the timescales before relying on it, because the procedure has been amended.

Used sparingly, that route works. Used on every application, it makes an enemy of the person who validates your submissions for the next ten years.

The commonest reasons applications are made invalid

In rough order of frequency:

• The fee is wrong, usually because the floorspace calculation or the number of dwellings was misread.
• The ownership certificate is unsigned, undated, or the wrong certificate for the ownership position.
• The location plan is at the wrong scale, has no north point, or the red line does not include the access.
• Existing drawings are missing, because only proposed drawings were issued.
• Drawings are unscaled or lack a scale bar, so they cannot be checked when printed.
• The design and access statement is absent on a scheme that needed one.
• Biodiversity gain information is missing or incomplete.
• The site area or the description of development on the form does not match the drawings.

Most of those cost a week. Together they account for the large majority of returns, and none of them requires a consultant to fix.

The fee is worth a paragraph on its own. Fees are set nationally and are indexed, so the figure in a template from last year will be wrong. Householder, full, outline, reserved matters, prior approval and lawful development certificate applications all sit on different scales, and an outline application is charged on site area while a full application for dwellings is charged per unit. Where an application is for a mix of uses, the fee is calculated on the relevant components rather than on the headline description.

Underpaying stops the application dead. Overpaying is refunded eventually, so if the calculation is finely balanced, pay the higher figure and explain the calculation in the covering letter.

Building a submission that validates first time

Work from the authority's own list, not from a generic template.

1. Download the current local list from the authority's website on the day you assemble the pack.
2. Work through it line by line, recording against each item either the document that satisfies it or the reason it does not apply.
3. Check the fee against the current national fee schedule, and remember fees are indexed, so use the current figures.
4. Check the drawing schedule against the form, so every drawing referenced exists and every drawing submitted is referenced.
5. Include a short covering letter listing the documents and explaining any local list item you have not provided.

That covering letter is the single most useful item in the pack. A validation officer who can see why an item is absent will usually accept the reasoning, where the same officer faced with a silent omission will return the application.

Where an application does come back, the route to fixing and resubmitting is straightforward, though the clock restarts.

Keeping a checklist current across authorities

Practices working across several authorities need a system rather than a memory. Keep a table of the authorities you submit to, the date of their current local list, the triggers that matter for your typical projects, and the items they enforce strictly.

Review it when a list is republished. Authorities announce changes on their planning policy pages, and the review cycle is a good prompt to check the whole table at once.

The supporting documents themselves follow from the list. A Design and Access Statement and a Biodiversity Net Gain Assessment are the two most often requested beyond the drawings, and the biodiversity metric has to be completed by a competent person under the Environment Act 2021 regime, with any draft used as their starting point.

To see the document types an application of a given kind usually needs, browse the report types on PlanScope.

PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval. This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it.