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Planning Law

Prior Approval UK — Converting Commercial Buildings and Agricultural Barns to Residential

The prior approval procedure under the GPDO 2015 — Class MA (office to residential), Class Q (barn conversion), the 56-day default, and other classes relevant to residential landlords and developers.

15 min readUpdated 8 June 2026Last reviewed: 17 May 2026planningprior-approvalclass-maclass-q

Class MA — Commercial to Residential Prior Approval

Part 3, Class MA of the GPDO 2015 permits the change of use from Use Class E (commercial, business and service) to Use Class C3 (dwellinghouse) without full planning permission. Eligibility: the building must have been in Use Class E use continuously for at least 2 years immediately before the application, and vacant for at least 3 months. A single application covers up to 1,500 sq m of commercial floorspace. The LPA can only consider: transport and highways; contamination; flood risk; noise; natural light; and the provision of local services. The LPA cannot refuse on grounds of loss of employment space or affordable housing requirements.

  • 2-year Use Class E use and 3-month vacancy: hard eligibility conditions; evidence the vacation date
  • 1,500 sq m cap per application: above this limit, a full planning application is required
  • LPA cannot refuse on general planning grounds (loss of jobs, design, affordable housing)
  • 56-day default: LPA failure to decide within 56 days of valid application = deemed prior approval granted
  • Article 4 Directions can remove Class MA in City of London, Canary Wharf, and other commercial districts

Class Q — Agricultural Buildings to Residential (Barn Conversions)

Part 3, Class Q of the GPDO 2015 permits the change of use of agricultural buildings to residential use (Class C3). The agricultural building must have been in agricultural use (or the agricultural unit last used for agriculture) on or before 20 March 2013. Up to 5 dwellings can be created from a single agricultural unit; total floorspace must not exceed 1,000 sq m; individual dwellings cannot exceed 465 sq m. The building must be capable of conversion in its existing structure — Class Q only permits conversion, not demolition and rebuild (Hirose Electrical UK Ltd v Secretary of State [2021]).

  • Agricultural use before 20 March 2013: new barns built after that date do not qualify
  • 5-dwelling limit per agricultural unit: cumulative across all Class Q applications on the unit
  • 1,000 sq m total residential floorspace: individual dwellings capped at 465 sq m each
  • Conversion not rebuild: the existing structure must be capable of functioning as a dwelling — wholesale demolition and reconstruction is outside Class Q
  • LPA can consider design and external appearance: unlike Class MA, conditions on materials and fenestration are permitted

The Prior Approval Application Procedure and the 56-Day Default

Prior approval applications are submitted to the LPA via the Planning Portal. The application must include: a site plan; floor plans; and evidence addressing each specified matter (transport statement; contamination report; flood risk assessment; noise assessment; natural light calculations; structural survey for Class Q). The LPA has 56 days from the valid application date to grant, refuse, or conditionally approve. If the LPA does not decide within 56 days, the prior approval is automatically deemed granted. The 56-day clock only runs from the valid application date — the LPA can declare an application invalid to reset the clock. Once granted, the development must commence within 3 years.

  • 56-day default: deemed prior approval if the LPA fails to decide within 56 days of a valid application
  • Valid application required: ensure all supporting documents are complete at submission — an invalid application resets the clock
  • Conditions limited to specified matters: internal design, room sizes, and affordable housing cannot be conditioned
  • 3-year implementation period: prior approval lapses if development does not commence within 3 years
  • External works beyond the conversion may need separate planning permission

Other Prior Approval Classes for Landlords

Additional prior approval classes relevant to residential landlords: (a) Class AA — addition of up to 2 storeys to a detached house or 1 storey to a terrace or semi, subject to LPA assessment of amenity, external appearance, and natural light; (b) Class AB — up to 2 new flats above an existing Use Class E or F2 (local community) building without full planning permission; (c) Class P — change of use from B8 (storage or distribution) to C3 residential via prior approval, covering warehouse-to-residential conversions not eligible under Class MA; (d) Class N — change of use from casinos or amusement centres to C3 residential via prior approval.

  • Class AA: adds storeys to existing houses without full planning permission; LPA assesses amenity and appearance
  • Class AB: creates new flats above shops and offices; a cost-effective route to residential units from commercial airspace
  • Class P: storage/distribution (B8) to residential — for warehouse conversions where the building is not in Use Class E
  • Prior approval is property-specific: always confirm the current and historical use class before relying on any route
  • Local planning policies apply if a full planning application becomes necessary (e.g. floorspace exceeds the cap)

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