Validation: why councils return applications unregistered

Validation is the check a council runs before your application becomes a live application. Until it passes, nothing happens: the eight-week clock has not started, no case officer has been assigned, and no consultation has gone out. Planning application validation is administrative rather than a judgement on the merits, which is why the reasons for return are so often small. A missing signature on an ownership certificate stops a scheme as effectively as a bad design.

What validation is and who does it

A validation officer, not a planning officer, checks the submission against two lists: the national information requirements set by legislation and the local list published by that authority. The check is mechanical. Is the fee correct, is the certificate signed, is there a scale bar on the block plan, is the document the local list asks for present.

Section 62 of the Town and Country Planning Act 1990 gives councils the power to require particulars and evidence with an application. Article 7 of the Development Management Procedure Order 2015 sets out the national requirements: a completed form, a plan identifying the land, the certificates required by the Act, a design and access statement where one is needed, and the fee.

The officer doing this work has no discretion to waive a requirement they think is unnecessary. If you want a requirement disapplied, you have to argue it with the team leader, and you need a reason better than inconvenience.

The national list and the local list

The national list applies everywhere. Since 2024 it also includes a biodiversity gain statement, so an application for planning permission has to say whether the applicant believes the biodiversity gain condition applies, and give the pre-development biodiversity value information the regulations require. Applications for relevant tall buildings must include a fire statement under article 9A of the same Order.

The local list is where authorities differ, and it is the source of most disputes. Councils publish a document setting out the additional information they require, usually with thresholds attached: a tree survey where trees are within a stated distance, a contamination assessment for a list of former uses, a parking survey above a stated number of units.

Two rules constrain that list. The requirement has to be published, and the legislation requires local lists to be kept current, with authorities reviewing and republishing them at intervals set by the Act. A requirement that appears only in an officer's email, or that sits in a list nobody has refreshed for years, is on weak ground. Ask for the published list and the date it was adopted.

The other constraint is proportionality. National guidance is clear that authorities should only request supporting information that is necessary, relevant to the application and proportionate to its scale. A full transport assessment for a two-bedroom extension does not meet that test, and saying so politely, in writing, usually resolves it.

The reasons applications come back

The pattern is consistent across authorities. In rough order of frequency:

• The fee is wrong. Fees are indexed and change, and the category is easy to misread on mixed proposals. Check the current fee schedule on the day you submit.
• The site location plan is not to a recognised scale, has no north point, or the red line does not include the access to a public highway.
• An ownership certificate is unsigned, undated, or the wrong certificate has been used because the applicant forgot a shared driveway or a ransom strip.
• The agricultural holdings certificate has been left blank.
• Existing drawings are missing. People submit proposed elevations and forget that the council needs the existing ones to compare.
• Drawings have no scale bar, no drawing number or no revision, so the decision notice cannot list them.
• The biodiversity gain statement is absent or the exemption claimed is not explained.
• A local list document is missing, most often a heritage statement, a tree survey, a drainage strategy or a contamination desk study.
• The community infrastructure levy additional information form has not been submitted in a charging authority.

That last one catches self-builders constantly. The levy form is a validation requirement in charging authorities, and it is separate from the exemption claim you make later, so understanding how levy liability arises before you submit avoids both a validation delay and a much more expensive mistake after permission.

Heritage is the other recurring gap. Where a site sits near a listed building or in a conservation area, the local list will require an assessment of the effect on significance, and that includes effects on the setting of a heritage asset rather than only on the asset itself. Applications get returned because the submitted statement addressed the building and ignored the setting.

How long an invalid application sits in limbo

Longer than people expect. The council writes to say what is missing, usually within a week or two of submission, and then waits. Nothing is chased. If you supply the missing item three weeks later, the application is validated from the date the last item arrived, not from the original submission date.

Many councils operate a policy of disposing of applications that remain invalid for a set period, commonly a few weeks, and returning the fee less an administrative charge. Read the letter for that deadline, because a disposed application means resubmitting from scratch.

There is no statutory appeal against a refusal to validate. The practical escalation is to reply in writing, quoting the published local list, explaining why the requested document is not necessary or proportionate for this proposal, and asking for the application to be registered. Where you are still stuck, supplying the document under protest is usually faster than winning the argument, and you can note in the covering letter that you consider it unnecessary.

Illustrative example

An illustrative case: a self-builder submits for a single dwelling on a garden plot. The fee is right, the drawings are complete. The application comes back twice. First, because the red line excluded the last two metres of the driveway where it meets the adopted highway, so the site did not have a shown access. Second, because Certificate A was used although the driveway is jointly owned with the neighbour, and Certificate B with notice served on the neighbour was needed. Five weeks lost on two lines of a form.

Pre-empting the validation officer

The discipline that works is to validate your own application before you send it.

1. Download the authority's current local validation list and read it against your proposal, marking each item as required, not required with a reason, or supplied.
2. Confirm the fee from the current schedule, and where the proposal is mixed, ring the council and record who told you which category applies.
3. Check ownership. Pull the title, identify every owner of every part of the red line, and pick the certificate that matches. Serve notice early, because Certificate B needs 21 days.
4. Draw the red line to include the access to the public highway, and use a blue line for other land in the applicant's control.
5. Give every drawing a number, a revision, a scale and a scale bar, and list them in the covering letter exactly as they should appear on the decision notice.
6. Write a short covering letter mapping each local list item to the document that answers it.

That covering letter is the single highest-value item in the pack. A validation officer with a mapped list has no reason to guess, and applications with one tend to register first time.

Where the local list calls for technical documents, scope them early against the full list of report types rather than waiting for the council to tell you. Survey seasons for ecology and the lead time on a drainage strategy are measured in weeks, and finding out at validation costs a season.

Where each council publishes its checklist

Every English authority publishes its local validation requirements on its own website, usually under planning applications, "before you apply" or "validation". The document is often called a local list, a validation checklist or local information requirements.

Check three things when you open it. The adoption or review date, because a stale list is contestable. Any thresholds attached to each requirement, because most items only apply above a size or within a distance. And whether the authority publishes a separate householder checklist, which is normally much shorter and is the one you want for an extension.

Where you cannot find it, the planning support inbox will send it, and it is worth asking for the fee schedule at the same time. Both documents change, and both are the council's own published material, which makes them the only reliable source for what that authority will require.

This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it.

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