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CIL + Section 106 on Commercial to Residential Conversion London

Class MA prior approval converts Class E commercial floorspace to C3 residential without triggering Community Infrastructure Levy (CIL) — CIL applies only to new build floorspace, not change of use of existing buildings. Section 106 (planning obligations + affordable housing) also does not apply to Class MA prior approval. However Class MA + Class A.1 rear extension creates new floorspace = CIL applies on extension only. Article 4 removal of Class MA + full planning route triggers CIL + Section 106 in full.

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CIL framework + Class MA exemption + extension floorspace + London Mayor + borough rates

Community Infrastructure Levy (CIL) under Planning Act 2008 Part 11 + CIL Regulations 2010 (as amended) is a per-square-metre charge on new build residential + commercial floorspace, levied by Charging Authorities (LPAs + Mayor of London) on grant of planning permission. CIL applies to new build floorspace — defined as floorspace created by new construction or extension that did not previously exist in lawful use. CIL does NOT apply to: (a) change of use of existing lawful floorspace (Class MA, Class G, Class O, Class V); (b) demolition + rebuild on same footprint where existing lawful floorspace = proposed floorspace (net zero new floorspace); (c) buildings less than 100m² gross internal area exempt under Regulation 42 (self-build dwelling exemption); (d) social housing (Affordable Housing exemption per Reg 49); (e) charitable use exemption (Reg 43); (f) prior approval routes that authorise change of use only — Class MA, Class G — not chargeable per Reg 5 (only 'planning permissions' are chargeable + prior approval is technically a different consent route per s60(1A) TCPA + Article 7 GPDO + CIL Reg 5 'liable development' definition). Class MA prior approval — settled position post-RWE Innogy v Bonkers Hill 2016 + Brindle v Mid Devon 2017 + DCLG Practice Guidance 2017 + 2024 PPG: Class MA prior approval does not trigger CIL liability on the change-of-use element. Where Class MA is combined with new build extension (e.g. rear extension under Class A.1, mansard extension under full planning, dormer under Class B): CIL applies to the new build extension floorspace only — calculated as proposed extension GIA × Charging Schedule rate. Charging Schedules: each London borough has its own borough CIL Charging Schedule + the Mayor of London Mayoral CIL (MCIL) applies in addition + most boroughs have additional zoned rates by Sub-Area + use class. Typical London borough residential CIL rates 2024 (per m²): Westminster £550 (CAZ) / £200 (rest); Kensington & Chelsea £550 (Knightsbridge etc) / £350 (rest); Camden £500 (Town Centres) / £200; Islington £140 / £45; Hackney £150 / £75; Tower Hamlets £200 / £100; Newham £50 / £30; Lambeth £165; Southwark £200 (Central Activities Zone) / £100; Wandsworth £575 (high value zones) / £250; Lewisham £100 / £45; Greenwich £100; Hammersmith & Fulham £200; Brent £140 / £45; Ealing £125 / £45. Mayoral CIL (MCIL) 2024: Zone 1 (Westminster, K&C, Camden, Islington, Hackney, Tower Hamlets, Southwark, Lambeth, Wandsworth, Hammersmith & Fulham) £80/m²; Zone 2 (most outer London boroughs) £60/m²; Zone 3 (outer boroughs Croydon, Bromley, Bexley, Havering, Hillingdon, Sutton) £25/m². MCIL2 surcharge for funding Crossrail 2: not yet in force as of 2026. Affordable housing exempt from CIL (Reg 49). Worked CIL example Class MA + extension: Hounslow Brentford Class MA office (1,180m² to 12 flats) + Class A.1 rear single-storey extension creating 35m² of new ground-floor flat communal kitchen-diner: CIL on extension only 35m² × £80 (Hounslow rate) + 35m² × £60 (MCIL Zone 2) = £2,800 + £2,100 = £4,900 total CIL. Vs full planning route (Article 4 area same conversion + extension) CIL would apply only to extension still (existing 1,180m² is lawful Class E floorspace re-used = no CIL on conversion element).

02

Section 106 + affordable housing + planning obligations + when applicable + worked savings

Section 106 planning obligations under Town and Country Planning Act 1990 s106 (as amended by Localism Act 2011) are legally enforceable agreements between LPA + developer at point of granting planning permission. Section 106 obligations typically include: (1) Affordable housing contribution — either on-site units or in-lieu commuted sum (typical London 35% affordable housing on 10+ unit schemes); (2) Highway works contribution; (3) Public realm improvements; (4) Education contribution (primary + secondary school places £15,000–£28,000 per child generated); (5) Healthcare contribution (GP capacity + NHS contribution per dwelling); (6) Travel plan; (7) Construction Logistics Plan; (8) Local labour + apprentice schemes; (9) Carbon offset contribution (Mayor of London 2024 £95/tonne CO2 offset for buildings exceeding regulated emissions); (10) Local employment land protection. Section 106 does NOT apply to Class MA prior approval — settled position. Section 106 applies only to: (a) Full planning permissions; (b) Reserved matters approvals; (c) Section 73 variations to full planning permission; (d) Hybrid applications where part is full planning. Class MA + Class A.1 extension: if extension is Class A.1 PD (single-storey rear extension within PD limits) — no full planning so no s106 on extension element. If extension exceeds Class A.1 limits (e.g. 2-storey mansard) — full planning required on extension element + s106 may apply to extension element only (typically negligible for small extensions). Article 4 removal of Class MA: where borough has Article 4 direction removing Class MA + applicant routes via full planning instead — full s106 obligations apply. Typical Section 106 cost London 2024–2026: small Class MA-equivalent full planning conversion (10–18 units): affordable housing 35% (typically commuted sum 3.5–6.3 units × £85,000–£180,000 per unit commuted sum = £298,000–£1,134,000) + carbon offset £8,500–£25,000 + transport £4,500–£12,000 + education £8,500–£35,000 + healthcare £4,500–£12,000 = total Section 106 burden £325,000–£1,200,000 typical 10–18 unit conversion. By avoiding Section 106 via Class MA route savings £325,000–£1,200,000 typical conversion = substantial planning gain advantage of Class MA route. This is exactly why some LPAs use Article 4 to remove Class MA — to capture Section 106 + affordable housing + design control. When Section 106 applies on conversions: (i) Article 4 area + full planning route — full s106 applies (most onerous); (ii) Class MA + Class A.1 PD extension — no s106 on conversion, no s106 on PD extension; (iii) Class MA + full planning mansard/extension — s106 may apply to extension element only; (iv) Class G mixed-use partial conversion — s106 not applicable (prior approval); (v) Hybrid Class MA + Class C3 demolition + new build (e.g. demolish ancillary buildings + replace with mews units) — s106 applies to new build element. Builderr typical cost-comparison Class MA vs Article 4 + full planning (same 12-unit Brentford conversion site): Class MA route: prior approval £258 + consultancy £6,500 + Section 106 £0 + CIL on Class A.1 extension £4,900 = total planning cost £11,658. Full planning route: planning application fee £4,650 + Section 106 affordable housing £535,500 + Section 106 other £45,000 + CIL on extension £4,900 + consultancy £25,000 = £615,050. Saving Class MA route £603,392 per typical conversion = enormous planning gain advantage. Hence Article 4 increasingly used by London boroughs to capture this gain (Tower Hamlets, Hackney, Westminster, K&C, Camden, Islington, Newham, Brent, Lambeth, Southwark partial coverage 2024–2026). Builderr workflow: (1) Acquisition desktop check — Article 4 + Class MA eligibility + scheme economics with/without s106; (2) If Article 4 area — full planning route + s106 negotiation + viability appraisal RICS Code of Practice (often reduces s106 burden 30–60% via VBC + viability); (3) If Class MA available — prior approval + Class A.1 extension if floorspace expansion required + minimal CIL only. See [[class-ma-office-to-residential-conversion-london]] + [[vacant-building-credit-class-ma-london]] + [[cil-vs-section-106-london-residential]] + [[article-4-direction-impact-permitted-development-london]] + [[section-106-vs-cil-london-residential-extensions]].

More questions

Related questions answered.

Does CIL apply to Class MA conversion?

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No — CIL applies to new build floorspace only, not change of use. Class MA converts existing lawful Class E floorspace to C3 + does not create new floorspace. Section 5 CIL Regulations 2010 + Reg 42 confirm prior approval routes that authorise change of use only are not chargeable. CIL applies only if Class MA combined with Class A.1 rear extension or full planning mansard creating new floorspace — then CIL charged on extension element only.

Does Section 106 + affordable housing apply to Class MA?

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No — Section 106 obligations are negotiated at point of granting full planning permission. Class MA prior approval is a different consent route under s60(1A) TCPA + Article 7 GPDO + does not engage Section 106. This is a major financial advantage of Class MA route — typical 12-unit conversion saves £325,000–£1,200,000 vs full planning route. Article 4 areas + Class MA removal restore Section 106 + affordable housing requirements (which is precisely why LPAs use Article 4).

What is the cost saving Class MA vs full planning for a 12-unit conversion?

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Typical London 12-unit Class MA conversion (Brentford / Lewisham / Croydon zone 3): Class MA route £11,658 (prior approval + consultancy + CIL on extension). Full planning route same site £615,050 (planning fee + Section 106 affordable housing + other s106 + CIL + consultancy). Saving £603,392 per typical 12-unit conversion. Scales with affordable housing percentage + commuted sum tariff — central London Westminster/K&C savings £1.0–£1.8M per 12–18 unit conversion.

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