The UK has four planning systems, not one. England, Wales, Scotland and Northern Ireland each make their own planning law, so the rules on what needs permission, how long a permission lasts and how to appeal all change at the border.
This guide sets out what is different in each nation. It links to a short guide for each, and to the council pages where you can search applications.
Who decides planning applications
In all four nations, the local council decides almost every application. The bodies above the council are different:
- England: councils, with appeals to the Planning Inspectorate. National infrastructure projects are decided by the relevant Secretary of State under the Planning Act 2008.
- Wales: 22 councils and 3 national park authorities, with appeals to Planning and Environment Decisions Wales (PEDW). The largest projects are decided by the Welsh Ministers.
- Scotland: 32 councils and 2 national park authorities. Some refusals go to the council's own local review body; the rest go to the Planning and Environmental Appeals Division (DPEA). Large power stations are consented by the Scottish Ministers.
- Northern Ireland: 11 councils, which took over planning in 2015. Regionally significant applications go to the Department for Infrastructure, and appeals go to the Planning Appeals Commission.
How long planning permission lasts
This is the difference that catches most people out.
- England: 3 years to start work (Town and Country Planning Act 1990, section 91).
- Wales: 5 years to start work (the same section, which sets five years for Wales).
- Scotland: 3 years for full planning permission (Town and Country Planning (Scotland) Act 1997, section 58).
- Northern Ireland: 5 years (Planning Act (Northern Ireland) 2011, section 61).
The council can set a longer or shorter period, so always check the decision notice. Our guide to what happens when planning permission expires covers outline permissions and how to start work lawfully.
Outline permission has a different name in Scotland
England, Wales and Northern Ireland use outline planning permission, with the details ("reserved matters") approved later. Scotland uses planning permission in principle, with the details approved through "matters specified in conditions". The idea is the same; the paperwork and time limits differ.
Permitted development is different in every nation
Permitted development rights let you do some work without applying. Each nation has its own order, and the limits for extensions, outbuildings, solar panels and changes of use are not the same:
- England: the Town and Country Planning (General Permitted Development) (England) Order 2015.
- Wales: the Town and Country Planning (General Permitted Development) Order 1995, as amended in Wales.
- Scotland: the Town and Country Planning (General Permitted Development) (Scotland) Order 1992.
- Northern Ireland: the Planning (General Permitted Development) Order (Northern Ireland) 2015.
Most permitted development guides online describe the English rules. If you are in Wales, Scotland or Northern Ireland, check your own nation's order or ask the council before you build.
Appeals
- England: to the Planning Inspectorate. 12 weeks for a householder appeal, 6 months for most others.
- Wales: to PEDW, within 6 months of the decision in most cases. Householder appeals have a shorter deadline, shown on the decision notice.
- Scotland: within 3 months, either to the council's local review body (for local developments decided by an officer) or to the DPEA. The decision notice says which.
- Northern Ireland: to the Planning Appeals Commission, within 4 months of the decision (Planning Act (Northern Ireland) 2011, section 58).
National and nationally significant projects
The biggest schemes skip the council in every nation, but the routes differ:
- England: Nationally Significant Infrastructure Projects, consented by a development consent order under the Planning Act 2008.
- Wales: Significant Infrastructure Projects, which need infrastructure consent from the Welsh Ministers under the Infrastructure (Wales) Act 2024. The new regime replaced Developments of National Significance from 15 December 2025, and applications already in the system finish under the old rules.
- Scotland: power stations over 50 megawatts are consented by the Scottish Ministers under section 36 of the Electricity Act 1989. National developments are set out in National Planning Framework 4.
- Northern Ireland: regionally significant development, decided by the Department for Infrastructure under section 26 of the Planning Act (Northern Ireland) 2011.
See every project in each nation on our national infrastructure map, with its stage and site boundary: Wales, Scotland, Northern Ireland.
Guides for each nation
- Planning permission in Wales
- Planning permission in Scotland
- Planning permission in Northern Ireland
Search applications in any nation
Planning Signal covers planning applications from every council in England, Wales, Scotland and Northern Ireland. Search by postcode, or browse every council, to see what has been applied for, approved and refused near you.
Frequently asked questions
Does English planning law apply in Wales?
Partly. The Town and Country Planning Act 1990 still applies in Wales, but many sections work differently there, and Wales has its own Acts, policy and permitted development rules. Never assume an English rule applies in Wales.
Is planning permission valid for 3 or 5 years?
3 years in England and Scotland, 5 years in Wales and Northern Ireland, unless the council has set a different period on the decision notice.
Who do I appeal to in Scotland?
If an officer decided your application under the council's scheme of delegation, you ask the council's local review body to review it. Otherwise you appeal to the Planning and Environmental Appeals Division. The decision notice tells you which route applies.
Does Northern Ireland have its own permitted development rules?
Yes: the Planning (General Permitted Development) Order (Northern Ireland) 2015. Its limits differ from England's.