Change of use
Change of use applications are among the most policy-sensitive planning applications you can make. Unlike a householder extension — which turns primarily on design and amenity — a change of use engages questions about the development plan's approach to land use, the sequential test, economic impact, and housing policy. A well-prepared supporting statement is not optional for most change of use applications: it is the document that makes the policy case.
This guide explains what a change of use planning supporting statement needs to cover, which NPPF policies are most relevant, and how to structure the argument for different types of use change.
Not always. The Use Classes Order 1987 (as amended) groups uses into classes, and changes within the same class are generally permitted without planning permission. Since the 2020 reforms, Class E consolidates commercial, business, and service uses — meaning a restaurant can become a gym, or an office can become a retail unit, without a planning application.
However, the following changes almost always require a full planning application:
Note: Even where a change of use is permitted development (e.g. Class MA office-to-residential), a prior approval application is usually required. Prior approval requires a supporting statement addressing specific matters — transport, contamination, flooding, and noise.
Where the proposed use is a main town centre use — retail, leisure, entertainment, offices, hotels — and the site is not in a town centre, NPPF paragraphs 88 and 89 require a sequential assessment demonstrating that no sequentially preferable sites (in-centre, then edge-of-centre, then out-of-centre) are available. Your supporting statement must address this if it applies.
For proposals above the threshold set in the development plan (typically 2,500 sq m of retail or leisure floorspace), an impact assessment is required demonstrating that the development would not have a significant adverse impact on town centre vitality and viability. Below the threshold, impact should still be addressed briefly.
Most development plans contain policies protecting specific uses in specific locations — employment land policies, primary shopping frontage policies, hot food takeaway policies, and so on. Your statement must identify the relevant policies and demonstrate either compliance or a material justification for departing from them.
Where the proposed change introduces residential use — converting a commercial building, a house in multiple occupation, or an agricultural building — housing policies apply. These include the development plan's approach to housing delivery, housing mix, and affordable housing, as well as design standards for residential accommodation.
The most relevant NPPF 2023 paragraphs for change of use applications are:
For changes of use involving the loss of community facilities (pubs, community centres, local shops), Para 100 of the NPPF is also relevant — it requires that planning policies and decisions guard against the unnecessary loss of valued facilities.
Establish the existing lawful use of the building and its use class. If the existing use has changed informally over time, the statement may need to address whether the current use has been established by a certificate of lawful use or by continuous use for more than four years (for a dwelling) or ten years (for other uses).
Describe the proposed use clearly — hours of operation, customer numbers, delivery arrangements, staffing — and identify its use class. Explain the planning context: is the site in a defined zone (primary shopping frontage, employment area, town centre boundary) that affects the acceptability of the proposed use?
Identify every development plan policy that applies to the proposed use change and assess compliance with each. Where a policy protects the existing use (e.g. a primary shopping frontage policy that resists changes away from retail), the statement must address it directly — either demonstrating compliance or arguing that the policy does not apply, is out of date, or is outweighed by material considerations.
If the proposed use is a main town centre use and the site is edge-of-centre or out-of-centre, include a sequential assessment. This should identify in-centre and edge-of-centre sites, explain why each is not available, suitable, or viable, and conclude that the application site is the only sequentially acceptable option.
Address the impact of the proposed use change on the vitality and viability of the nearest town centre, on local employment, and on community facilities. Even where a formal impact assessment is not required, a brief assessment demonstrates engagement with the policy tests and pre-empts officer objections.
A change of use that introduces new activity — particularly a food and drink use, a takeaway, or a leisure use — will raise amenity questions about noise, odour, hours of operation, and litter. Address these proactively with proposed mitigation measures.
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