Articles

What Is an Energy Statement for Planning?

Read time: 5 minutes
June 30, 2026

In this article:

  • What an Energy Statement for Planning actually is, and how it differs from a planning condition
  • Whether your project actually needs one
  • What the "energy hierarchy" is, and why the order matters
  • How strict councils' targets actually are
  • Why Energy Statements get rejected, and what a carbon offset fund is
  • When to bring an Energy Statement into your design process

If you've been told your planning application needs an Energy Statement, and nobody's actually explained what that means, you're not alone. It's one of the most commonly requested documents at planning stage, and one of the least understood.

Here's the headline figure most people want first: Energy Statement targets typically range from a 10% reduction in predicted CO2 emissions up to full net-zero carbon, depending on your council's Local Plan. Where on-site compliance isn't feasible, the fallback is a carbon offset fund payment, priced at roughly £500 per tonne of the shortfall. Neither figure is universal, both are set locally, but they're the benchmarks most projects are working against, and the rest of this article explains exactly how.

What is an Energy Statement?

Short answer: a technical report submitted with your planning application, showing how your development meets your council's carbon and energy targets.

An Energy Statement is a modelling-based assessment, not a written summary of good intentions. It's built from data: predicted energy use, predicted carbon emissions, and the specific measures that bring both down. It demonstrates, in numbers, that your development meets your local council's carbon and energy targets.

It can also appear later in the process, as a planning condition rather than something submitted upfront. This is typically phrased as "before development above slab level" or "before first occupation", meaning the council has granted permission, but won't sign off on construction proceeding (or won't allow occupation) until the Energy Statement has been submitted and approved.

Verification renderVerification check of brace line gapsWhen can an Energy Statement be required?ConceptdesignPlanningsubmissionPlanningapprovedSlablevelFirstoccupationCompletionIn support of planningSubmitted with the application —layouts and systems can still flexAs a condition — either wording"Before development above slab level" or"before first occupation" — far less flexibility left

Do I actually need an Energy Statement?

Short answer: almost certainly, if you're requesting permission for a new build, and increasingly, yes, for conversions and extensions too.

There's no single national rule that triggers the requirement. It depends on your local authority's Local Plan. That said, the trend across most councils is the same: Energy Statements are now required for both minor and major developments, not just large-scale schemes.

  • New builds — almost always required
  • Conversions — increasingly required
  • Extensions — increasingly required

The only way to know for certain is to check your Local Plan or ask your planning officer or energy assessor before you submit. Requirements vary enough between councils that assuming your project is too small to need one is a common, and avoidable, mistake.

For the overheating side of planning compliance, see our companion article, Why Your Part O Overheating Assessment Is Failing — many of the same projects that need an Energy Statement also need a Part O assessment, and the two are worth coordinating early.

What is the energy hierarchy, and why does the order matter?

Energy hierarchy: Be Lean, Be Clean, Be GreenThree stacked colour blocks showing the energy hierarchy in order. Be Lean covers building fabric such as insulation, windows and airtightness. Be Clean covers efficient energy delivery such as low-carbon heating and fixed services. Be Green covers renewable technology, added only once the first two stages are addressed.01BE LEANFix the fabric — insulation, windows, airtightness02BE CLEANDeliver energy efficiently — heating, fixed services03BE GREENAdd renewables — only once the above is right

Short answer: it's the three-stage approach, Be Lean, Be Clean, Be Green, that most councils expect your Energy Statement to follow, in that order.

Be Lean comes first. This stage is about optimising the building fabric itself: insulation, windows, and airtightness. The goal is to reduce energy demand before anything else is considered.

Be Clean comes next. This stage looks at how energy is delivered to the development cleanly and efficiently, typically low-carbon heating systems and high-efficiency fixed services.

Be Green comes last. This stage determines how much renewable technology is actually needed, on top of the improvements already made in the Lean and Clean stages, to meet the carbon and energy policies set by your local council.

The sequence matters because each stage exists to get the development closer to the council's targets in the most effective order. A statement that leads with renewables, without first addressing fabric performance and system efficiency, is a common reason a council pushes back, it suggests the easier, more visible measure has been used to paper over a less efficient underlying design.

How strict are the carbon and energy targets?

Short answer: anywhere from a 10% reduction in predicted CO2 emissions to full net-zero carbon, depending on the council, and it's not always just about carbon.

There's no fixed national percentage. Each Local Plan sets its own target, and that target can also extend beyond carbon alone. Councils may additionally require:

  • A specific reduction in delivered energy for the heating system
  • A specific reduction in delivered energy for the whole building
  • A minimum percentage of energy generated on-site from renewables
How strict are the carbon and energy targets?Preview renderHow strict are the targets?Carbon reduction target, set by Local Plan10%CO2 reductionNet-zerocarbonVaries by council —check the Local PlanAnd it's not always just about carbon. Councils can also set:Delivered energy— heating systemA target specific to howefficiently heat is deliveredDelivered energy— whole buildingA target across totalbuilding energy use% from on-siterenewablesA minimum share of energygenerated on the development

Because the figure can range so widely between authorities, the percentage that applied to a previous project isn't a reliable guide for a new one, each Local Plan needs to be checked individually.

Why do Energy Statements get rejected?

Short answer: rarely because of an error in the underlying logic, usually because the calculation doesn't add up, or because the proposed measures don't fit the design.

If an Energy Statement is calculated correctly, it normally shouldn't be rejected. Rejections typically happen for one of two reasons:

  • The maths doesn't add up. Planning officers check the numbers, and a calculation error is a straightforward reason for refusal.
  • The target isn't physically achievable on-site. Sometimes the design simply can't accommodate the system size needed to hit the council's carbon or energy target, there isn't roof space for enough solar capacity, for example, or the building form limits what a heat pump installation can realistically deliver.

When the second scenario applies, there's a recognised route forward: paying into a carbon offset fund. This is a ring-fenced fund, with the payment calculated based on how far short the development falls of the target, typically priced at roughly £500 per tonne of carbon. It isn't a workaround used to avoid genuine effort; it's a formal mechanism for situations where on-site compliance genuinely isn't feasible, and it should be treated as a fallback rather than a starting assumption.

When should an Energy Statement be commissioned?

Short answer: as early as possible, ideally alongside the design, not after it's finalised.

The earlier an Energy Statement is brought into the process, the more options remain available. Commission it once layouts, glazing, and system choices are already locked in, and you're left retrofitting a strategy onto a building rather than designing the two together.

Getting the calculation right matters for a second reason too: an Energy Statement prepared incorrectly can unexpectedly tie a development into requirements it never actually needed to meet, once it's been submitted and accepted as part of the planning record. Choosing an experienced assessor at the outset reduces that risk significantly.

What does this mean for your project?

An Energy Statement isn't a box-ticking document, it's a numbers-based case for how a development will perform, built around a recognised structure that most councils expect to see followed in order: fabric first, efficient systems next, renewables last.

If you're not yet sure whether your project needs one, the first step is checking your Local Plan or speaking to your planning officer. If you already know one is required, the earlier it's brought into the design process, the more flexibility there is to get it right the first time, and if your project also needs a Part O overheating assessment, coordinating the two from the outset avoids strategy clashes.

This article reflects general Local Plan practice and the energy hierarchy as commonly applied by UK local planning authorities, current as of 30 June 2026. There is no single national rule for when an Energy Statement is required, or what target applies, these are set individually by each council's Local Plan, and the figures referenced above (target percentages, the carbon offset rate) are general patterns rather than universal rules. Project-specific requirements should always be confirmed against the relevant council's current Local Plan or with a qualified energy assessor.

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