What a validation officer checks that AI cannot know

An AI planning statement validation failure is almost never about the prose. Applications get returned because the ownership certificate is wrong, the fee is short by £120, the red line omits the access strip, or a local list item was missed. None of those are drafting problems. They are administrative facts about a specific site, a specific owner and a specific council, and a drafting tool has no way of knowing any of them.

That matters for how you use a draft. The document arrives structured, policy-aware and internally consistent, and it will still fail validation if the surrounding paperwork is wrong. Separating the two jobs is the fastest way to get an application registered first time.

Validation is a procedural gate, not an assessment

Article 11 of the Town and Country Planning (Development Management Procedure) (England) Order 2015 sets out when an application is valid. In substance it requires the correct form and particulars, the plans and drawings necessary to describe the development, the right certificate, the fee, and any document on the authority's published local list.

A validation officer is checking presence and completeness. They are not judging whether the design is good, whether the policy analysis convinces, or whether the heritage argument holds. If a required document is present and addresses the required matters, it passes the gate even if the case officer later disagrees with every word of it.

The converse is the part that costs time. An excellent statement does not cure a missing agricultural holdings certificate, and no amount of policy citation compensates for a site plan without a north point.

The national information requirements

These apply everywhere and do not vary by council.

• The completed application form, with the description of development, the site address and the applicant and agent details.
• A plan identifying the land to which the application relates, with the application site edged in red and any other land in the applicant's control edged in blue.
• The ownership certificate, together with the agricultural holdings certificate.
• The correct fee.
• A design and access statement where one is required.
• The plans and drawings needed to describe the development, numbered and to a stated scale.

Each of those has a failure mode a draft cannot anticipate. The description of development has to match what the drawings show, and a draft written from an outline brief may describe a two-storey extension where the drawings now show a single storey. The red line has to include everything needed to carry out the development, which on a new access means the land up to the highway boundary.

Local list items and the two-year rule

Beyond the national requirements, each authority publishes a local list of information it requires. This is where practice diverges most, and where an architect working across several authorities loses time.

The constraint is useful to know. A local requirement only bites if it appeared on a list published within the two years before the application was made. So a council asking for a document that is not on its current published list, or whose list has not been refreshed, is not entitled to invalidate the application for its absence. Download the list on the day you submit and keep the dated copy.

Local lists typically pick up items such as a drainage strategy below the national threshold, a parking survey, an arboricultural report where trees are within influencing distance, a contaminated land screening questionnaire, a biodiversity checklist, a construction management plan, or a heritage statement for anything in a conservation area.

The document a drafting tool can produce is the report. The fact that this particular council wants it, in this format, for this size of development, lives on a web page the tool has not read. Our note on why planning applications are returned as invalid sets out the pattern in more detail.

Certificates and notices

The ownership certificate is the single commonest cause of invalidity, and it is pure fact.

Certificate A says the applicant owns the whole of the application site and there are no agricultural tenants. Certificate B says other owners exist and have been served notice. Certificate C and Certificate D deal with owners who are partly or wholly unknown, which brings a newspaper notice requirement with it. The underlying duty comes from section 65 of the Town and Country Planning Act 1990, with the procedure in the Order.

Owner has a specific meaning here, covering freeholders and lessees with a long unexpired term, so a site with a 30-year lease over part of it is not a Certificate A case. Highway verge in council ownership, a shared driveway, a strip belonging to a neighbour that the red line crosses: each converts an A into a B and requires a dated notice.

No drafting process can establish this. It needs the title register, the lease and, in practice, a conversation with the client about what they actually own.

The fee, and why it is not a drafting question

Fees are set by regulations and have been subject to annual indexation since April 2025, so the figure changes. The calculation depends on the application category, the floorspace created, the site area or the number of dwellings, and it is affected by concessions, exemptions and the free resubmission entitlement.

Work it out on the Planning Portal fee calculator for the specific application and keep the printout. Then check three things that catch people: whether the proposal crosses a floorspace band, whether a previous application on the same site makes this a free go, and whether any part of the proposal is a separate application attracting its own fee.

A short fee underpayment stops the clock as effectively as a missing report, and it is the error most likely to be discovered three weeks in.

Plans, scales and north points

Drawing conventions are dull and they invalidate applications weekly.

Every plan needs a unique number, a revision, a stated scale and a scale bar, because documents are printed and scaled from on screen. A site location plan should normally be at 1:1250 or 1:2500 and show at least two named roads, with a north point. Existing and proposed need to be separable, and existing has to match what is on the ground rather than what was there before the last extension.

Levels, boundary treatments and drainage positions are facts from a measured survey. Where a draft refers to them, it should flag the gap rather than estimate, which is the behaviour described in what drafts get right about structure and wrong about evidence.

What to verify in a drafted document before submitting

Treat the draft as the narrative and run a separate factual pass. Six checks cover most of it.

1. Does the description of development in the statement match the form and the drawings word for word.
2. Are the local plan policies cited from the adopted plan, with the right numbers and the right adoption date.
3. Have all the site-specific placeholders been closed with surveyed or searched facts rather than deleted.
4. Does the red line include the access, the visibility splay land and anything needed for drainage.
5. Is the certificate right, and have the notices been served and dated.
6. Is every document on the council's current local list present.

Where judgement about the site itself is involved, the draft cannot replace a visit, as set out in where site judgement cannot be drafted. And where the submission needs an author with specific competence, the professional directory is the route to a reviewer who can sign it off.

PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval or validation. For practices submitting across several authorities, PlanScope pricing covers unlimited reports on the Professional tier at £150 per month or £600 per year.