Article 4 Directions: The End of Class E to Residential Permitted Development?

The Changing Landscape of Permitted Development Rights

Local Authorities across the UK are taking action to restrict Class E to Residential conversions by introducing Article 4 Directions, effectively removing the permitted development rights that previously allowed these changes without full planning permission.

For developers and investors, this marks a significant shift in how commercial-to-residential conversions will be approached moving forward.

What is Class E to Residential Permitted Development?

Under Class MA (Mercantile to Abode) of the General Permitted Development Order (GPDO), properties within Use Class E—which includes shops, offices, restaurants, and other business spaces—can be converted into residential use (Class C3) without requiring full planning permission. Instead, applicants only need prior approval from the Local Planning Authority (LPA), making the process faster and less restrictive.

The introduction of this right was intended to tackle the housing crisis by making it easier to repurpose commercial buildings into homes.

Why Are Local Authorities Introducing Article 4 Directions?

Despite the benefits of streamlining conversions, many Local Authorities are now resisting these changes. By issuing Article 4 Directions, councils can withdraw permitted development rights in specific areas, requiring all Class E to Residential conversions to go through the standard planning application process.

Local Authorities argue that unrestricted conversions could:

• Reduce essential commercial space, harming local economies and high streets.

• Lead to poor housing quality, as some conversions result in cramped, poorly lit, and substandard living conditions.

• Strain local infrastructure, such as schools, transport, and healthcare services.

• Bypass affordable housing requirements, as permitted development schemes are not subject to the same affordable housing contributions as full planning applications.

Where Are These Restrictions Being Implemented?

Several Local Authorities have now published consultations on their Article 4 Directions, with key locations including:

• London Boroughs (Westminster, Camden, Islington, Hackney, etc.)

• Manchester

• Birmingham

• Bristol

• Brighton & Hove

These councils aim to protect business districts, high streets, and employment zones from being eroded by unchecked residential conversions.

It is important to note that this is not a full list, and other Local Authorities can introduce Article 4 Directions at any time. Before commencing any development or conversion it is always best to check the current planning policies for your location with a chartered town planner or your local planning authority. 

Article 4 Directions and HMOs

In addition to commercial-to-residential conversions, many London boroughs have introduced Article 4 Directions specifically targeting Houses in Multiple Occupation (HMOs). These directions are designed to address concerns around the growing number of HMOs, which can sometimes lead to overcrowded areas, pressure on local services, and a reduction in the availability of family-sized homes.

The restrictions require developers and investors seeking to create or convert properties into HMOs to apply for full planning permission, rather than relying on permitted development rights. The goal is to ensure that HMO developments are appropriately located and of sufficient quality, and to mitigate the impact on communities.

It’s important to note that planning permission for an HMO is separate from a HMO license, which is required for properties to be legally rented as HMOs. As with other Article 4 Directions, it is essential to check whether your proposed HMO project is within an area affected by these restrictions before starting development.

How to Find Out if Article 4 Will Affect Your Development?

If you’re considering a Class E to Residential conversion, it’s essential to determine whether an Article 4 Direction applies to your area. Local Authorities regularly review and update planning policies, meaning new restrictions can be introduced at any time.

To find out if your development is affected:

• Check your Local Authority’s website for any active or proposed Article 4 Directions.

• Consult planning professionals who can assess your site’s potential constraints and provide tailored advice.

• Act swiftly—if no Article 4 is in place yet, submitting a prior approval application now may allow you to proceed before restrictions take effect.

Not sure where to start? Contact our expert planning team for a free, no-obligation consultation today.

What This Means for Developers and Property Owners

• For those involved in commercial-to-residential conversions, the introduction of Article 4 Directions means: Existing approved conversions are not affected.

• Future projects in affected areas will require full planning permission after the Article 4 comes into force.

• Timing is crucial—prior approval applications should be submitted before an Article 4 takes effect to benefit from existing permitted development rights.

Next Steps: How to Navigate These Changes

If you’re a property developer, investor, or business owner considering a conversion, here’s what you need to do:

1. Check Your Local Authority’s Stance – Visit your council’s website to see if an Article 4 consultation or direction is in place.

2. Act Quickly if You Plan a Conversion – If no Article 4 is in effect yet, submitting a prior approval application now may allow you to proceed under current rules.

3. Explore Alternative Planning Routes – If PDR is removed, you’ll need to apply for full planning permission and comply with local policies.

4. Seek Professional Advice – Consulting a planning expert can help you navigate these changes and explore alternative development strategies.

5. Follow Planning by Design on Facebook, LinkedIn and Youtube for all the latest news and updates.

Expert Insight on Article 4 Directions

Silas Willoughby, Chartered Town Planner at Planning by Design, states:

“The introduction of Article 4 Directions is a clear signal that Local Authorities want greater control over the quality and location of residential conversions. While this change does create new challenges for developers, it also presents opportunities to work collaboratively with planning teams to create well-designed, sustainable housing. The key takeaway is that early planning and professional guidance are more crucial than ever.”

Our  team are here to help you navigate these changes. If you have any questions or need assistance with your planning application, please get in touch with us.

Conclusion

With the growing number of Article 4 Directions across the UK, developers and property owners must stay informed and act strategically. While Class E to Residential conversions remain a viable route for creating new housing, these restrictions mean that planning applications will now be a more prominent part of the process.

Want to discuss how these changes affect your plans? Contact our expert planning team today. We’re here to help you make sense of the legislation and ensure that your next project runs smoothly.