Class MA and Operational Works: How London Boroughs Are Managing Tandem Permissions

Since the introduction of Class MA permitted development rights in 2021, allowing the change of use from Class E (commercial) to Class C3 (residential) via prior approval, local authorities have faced a procedural challenge: how to deal with the operational works often required to make these conversions acceptable.

Class MA grants permission for change of use only. Any physical alterations, such as new windows, entrances, balconies or extensions require separate full planning permission. In response, several London boroughs have adopted a pragmatic approach: approving Class MA prior approvals in tandem with full planning applications for the necessary operational works, which also have the same time period for determination, and using various mechanisms to ensure the two consents are implemented in unison.

A clear example is the City of Westminster’s handling of a scheme at 153–157 Cleveland Street, where an office-to-residential Class MA application (for 13 flats) was submitted alongside a full application for basement excavation and façade alterations. Both were approved within the same decision cycle. The council’s decision notice for the Class MA application included an informative making clear that the prior approval related only to the change of use, and that any development required implementation of the full planning permission. This ensured that the residential use could only proceed once the enabling works were carried out.

In Camden, a small-scale conversion involving minor external alterations was similarly handled via concurrent applications. However, Camden went further by requiring a Section 106 agreement to ensure the resulting development would be car-free, which is a policy objective that cannot be secured via prior approval conditions alone. By linking the full application to a legal agreement and referencing it in the prior approval, Camden effectively bound the two permissions together.

Lewisham took a slightly different approach in 2024 when it approved both a Class MA prior approval and a full planning application for the same site on Speedwell Street: one for a flat conversion, the other for redevelopment with nine houses. The approvals were treated as mutually exclusive, with informatives clarifying that implementing one would negate the other. While not strictly a case of supporting works, it demonstrates how councils use decision wording to manage overlapping permissions.

Other boroughs, including Richmond and Haringey, have also approved tandem applications with mechanisms such as informatives, cross-referenced decision notices, and occupancy conditions. These ensure that operational works required to make Class MA conversions acceptable are delivered, while maintaining clarity about what each consent allows.

What emerges is a growing practice across London: where operational works are needed alongside Class MA conversions, councils are willing to determine both types of application in tandem provided that the permissions are carefully linked. This enables councils to uphold design standards and policy goals, while allowing developers to rely on permitted development rights where appropriate.

Practitioners should consider submitting full applications in parallel with Class MA proposals, and expect councils to use conditions, informatives, and sometimes legal agreements to ensure the two consents operate in concert.

Writer: Tara Fitzpatrick, Associate