Comparison of the planning systems in the four UK countries: 2016 update

This paper describes and compares aspects of the current land use planning systems operating in the four UK countries. In particular, given the changes introduced by the UK Coalition Government (2010-2015) and by the devolved administrations, it compares the extent to which the four planning systems now differ from each other.  It also describes further changes for each country that are in the pipeline. This is an update of a previous version of this paper, of the same title, published in June 2013.

All four countries have a planning system that is ‘plan-led’.   ‘Plan-led’ means that national and local planning policy is set out in formal development plans which describe what developments should and should not get planning permission, how land should be protected and seeks to ensure a balance between development and environmental protection in the public interest.  Decisions on individual planning applications are made on the basis of the policies in these plans, unless there are other considerations that need to be taken into account.  Each country also has definitions of types of development that are permitted without the need for a planning application and defines “use classes” where change of use within a class is normally permitted.  An appeal system to review decisions on applications also operates in each country.  Each country also has a system in place to enforce breaches of planning consent.

Although the basic structures of the four systems are similar there are differences in the detail and in how each system works. Recent changes introduced by the UK Coalition Government (2010-2015) have seen a greater divergence between the system in England and the other three countries in the last couple of years.  England, Scotland, Northern Ireland and Wales now each have their own primary planning legislation.  The system in Northern Ireland has been changed significantly recently with passing of planning functions to local Councils.  The Planning (Wales) Act 2015 received Royal Assent in July 2015, although not all of its provisions are yet in force.

This paper has been prepared as an initiative of the Inter-Parliamentary Research and Information Network (IPRIN) with contributions from research staff working for each of the four UK legislatures and is being published separately by each organisation.