A) Boroughs should seek to ensure that local and strategic need for purpose-built student accommodation is addressed, provided that:

 

 

B) Boroughs, student accommodation providers and higher education providers are encouraged to develop student accommodation in locations well-connected to local services by walking, cycling and public transport, as part of mixed-use regeneration and redevelopment schemes.

1. Reiterates the need for PBSA schemes to be located in well-connected areas and allows some flexibility for sites outside central zones if they are accessible to universities.
    
2. Seeks to prevent overconcentration of PBSA in certain areas, balancing student housing with other housing needs and provides guidance on how to achieve this. 
    
3. The guidance supports the inclusion of affordable student accommodation (ASA) and/or conventional housing in PBSA developments although it stops short of allowing C3 affordable housing to replace ASA.
    
4. Provides guidance on the requirement to consider the needs of residents and visitors with a range of disabilities.
    
5. Provides guidance on what is expected in relation to nomination agreements. 

The London Plan states that boroughs should seek to ensure that local and strategic need for PBSA is addressed, however, it falls short of requiring all applicants to demonstrate this need.

  

Our research shows that most London authorities require a PBSA needs assessment in support of planning applications under their adopted or emerging policy. Typically, regardless of policy, most PBSA applications tend to include an assessment of need to strengthen the application. Such assessments analyse student growth trends and the growth strategies of relevant higher education institutions in the area.

 

In addition, the London Plan requires PBSA developments to contribute to mixed and inclusive neighbourhoods, with the PBSA LPG setting out how this can be achieved. 

 

 

From our research, it is easier to demonstrate how a PBSA scheme contributes to a mixed and inclusive neighbourhood where the PBSA element itself forms part of a wider mixed-use scheme, and/or where it proposes onsite C3 affordable housing alongside the PBSA element. It is interesting that the new London Plan consultation document references this point as a potential way to address concerns relating to mixed and balanced communities.

 

From speaking to key PBSA stakeholders, there is a general recognition of PBSA need and integration strategies from LPA officers, however, in some authorities committee members are not always aligned on this point. Many stakeholders are still spending time educating LPAs on the benefits and perception of PBSA. All stakeholders confirmed that having a positive development track record helps.

 

As additional PBSA permissions are issued, we expect there to be a larger focus from LPAs on addressing need and promoting mixed and inclusive neighbourhoods. Indeed, this appears to be a potential area of focus for the new London Plan. 

The London Plan and the PBSA LPG encourage PBSA schemes to be in locations well-connected to local services by walking, cycling and public transport, and often as part of mixed-use regeneration and redevelopment schemes. Some LPAs are going further by requiring PBSA developments to be in specific locations such as Growth Areas, Town Centres or Opportunity Areas.

 

Our discussions with PBSA stakeholders highlighted differing views on preferred locations for PBSA, though all agreed that the location of a PBSA site is an important consideration. Preferences ranged from proximity to transport nodes like tube stations or bus stops, specific transport zones, or being within walking distance of higher education providers.

 

Some stakeholders were not concerned about the distance between the PBSA scheme and a Higher Education Provider, provided there are public transport options to access the facility. Other stakeholders were also minded to only progress schemes in boroughs with supportive LPAs.

 

Our research indicates that 70% of PBSA schemes coming forward are within authorities with at least one Higher Education Provider. The majority are also being delivered as part of a wider mixed-use development (either as a PBSA-led development or mixed use schemes with an element of PBSA). Indeed, PBSA providers, often view other integrated uses, particularly on the lower floors of development, as a positive feature of their schemes, and an attraction for prospective students.

 

Almost all PBSA developments appear to be located in close proximity of local services.

 

Without specific PBSA allocations in Local Plans, it is evident that the location of PBSA developments will continue to be market driven.

From our research we found that the majority of PBSA stakeholders, are willing to seek a nomination agreement with a higher education institution, particularly where they are providing ASA. This approach is often considered to provide certainty over future occupiers.

 

Where nomination agreements are not in place, providers and developers frequently work in close collaboration with universities and higher education institutions to ensure their products are meeting the needs of all students.

 

In addition, the majority of approvals do include at least 35% ASA.

 

Where a nomination agreement has not been secured or the ASA is less than the expected 35%, our research indicates that a stakeholder will either opt for the delivery of onsite C3 accommodation or a payment in lieu as an alternative, or they will use these as a top up to ASA/nomination agreements.

 

Our research indicates this trend has increased from 2023 onwards. In 2022, there were no permissions following this approach. In 2023, there were two schemes (both with PiL). In 2024, there were 10 schemes (six with onsite affordable C3, two with a PiL, and two with a mix of both). By April 2025, there were five schemes (three with onsite C3, one with a PiL, and one with a mix), with nine more schemes proposing onsite affordable C3 in the pipeline.

  

PBSA stakeholders have different business models and cater for different student markets. This in turn affects whether their preference is to provide ASA or onsite affordable C3 affordable accommodation (or a PiL).

 

Planning policy is also catching up and is starting to recognise that there can be different approaches. Whilst it is recognised there is a need for ASA, the PBSA LPG also acknowledges that there is also a need for onsite affordable C3 accommodation. Increasingly, LPAs such as Southwark do see the benefit of onsite affordable C3 in lieu of nomination agreements and ASA. The GLA now also appears to recognise these alternative options in the formation of the new London Plan.

The London Plan does not require the delivery of onsite affordable C3 alongside PBSA. There is, therefore, no strategic policy which dictates the amount or proportion of onsite affordable C3 required. This is left to the LPAs in local plans. 

 

From our research, it is clear that since the adoption of the London Plan, the number of schemes coming forward with on-site C3 affordable housing is increasing. This has grown from zero schemes in 2021, 2022 and 2023 to eight developments in 2024 and four so far in 2025 (with at least nine more schemes providing on site C3 affordable housing in the pipeline). This is likely due to the combination of a more flexible approach to planning policy, a recognition from LPAs that the value generating PBSA element can support the delivery of C3 affordable homes, and a recognition that the delivery of a mix of PBSA and onsite C3 can help contribute to mixed and balanced communities.

 

Where onsite C3 affordable housing or a PiL is being secured, our research shows this is largely where the full provision of ASA has not been provided and/or where there is an absence of a nomination agreement (or a small proportion of bedspaces are secured through a nomination agreement).

 

From our research, there is generally no clear correlation between the location of schemes providing onsite affordable C3 and/or a PiL and local plan policies which support this approach. The exception here is Southwark which includes a supportive policy and accounts for 50% of the overall permissions providing onsite affordable C3 homes. In fact, of the nine PBSA permissions in Southwark, six (67%) provide onsite affordable C3 homes. 

 

This could indicate that the provision of onsite affordable C3 and/or a PiL allows applicants to negotiate the removal of a nomination agreement and/or ASA. We recognise that such an approach is not in every PBSA stakeholders’ interest,  particularly those that focus entirely on PBSA.

  

The delivery of C3 affordable can help create a mixed and inclusive neighbourhood, however, its delivery poses its own challenges, such as ensuring the provision of play space, amenity, servicing, separate access, and also identifying a Registered Provider partner to take the onsite affordable C3 homes. Whilst some operators, will consider onsite affordable C3, they will only do so where a site is large enough to accommodate this in a separately delineated building.

 

Overall, the provision of onsite affordable C3 homes alongside PBSA is likely down to the individual circumstances of the PBSA developer and the site in question.

 

Given the lack of onsite affordable housing being delivered in London, we do see the cross funding of C3 affordable housing through the provision of PBSA as a planning benefit and a means to help develop mixed and inclusive neighbourhoods.

The London Plan requires the design of PBSA schemes to be of high quality and in accordance with the requirements of “Policy D3 Optimising site capacity through the design-led approach”. In this regard, PBSA developments are treated in the same manner as any other housing/quasi-housing products or other forms of development.

 

Policy D3, requires schemes to follow the design-led approach in terms of optimising sites, considering the form and layout, the experience and the quality and character of the scheme. Some LPAs have gone further and require specific design related criteria in adopted and emerging policies.

 

In our discussions with PBSA providers and developers, the quality of the overall product is paramount to the success of the scheme. Each PBSA provider Lichfields has spoken to, confirmed they work meticulously to ensure the design and quality of its schemes are of a suitably high standard to ensure their products remain attractive to students.

 

Whilst the level of quality differs from one PBSA scheme to another depending on the product on offer, as a minimum all are expected to meet the requirements of Policy D3. This requires consideration of all the key technical and microclimatic considerations such as noise, ventilation and overheating early in the design process. Daylight and sunlight testing is also increasingly important, with nine Local Plans including Camden, Enfield, Hammersmith and Fulham, Harrow, Hounslow, Islington, Lewisham, Wandsworth and the OPDC all requiring this to be a consideration. The PBSA LPG strengthens this position. It builds on the London Plan Policy 15 A(5) requirements for ‘adequate’ and ‘functional’ living space and layout. The LPG indicates other considerations including daylight and natural ventilation in private and communal spaces as well as noise proofing and providing dual aspect rooms where possible in shared rooms.

 

Careful consideration of planning policy and the PBSA LPG in respect of quality and wellbeing early in the design development stages of a project are critical to a development’s success.

The London Plan does not mandate the requirement for PBSA management plans, however, as illustrated in the policy map, this is often an additional LPA policy requirement. Even where it is not cited in local policy, in our experience management plans are often expected to support planning applications.

 

A key concern for LPAs is the need to demonstrate how students will be managed in respect of nearby communities. This includes management of deliveries (parcels and food), the management of moving in/out, as well as other day to day management issues. 

 

PBSA providers and developers with a track record of delivering PBSA schemes can draw on evidence to demonstrate how their other schemes operate. This enables a clear and well-evidenced approach to the development’s management and operation, which reflects the specifics of a scheme. In other cases where a developer does not have a track record, identified operators often produce management plans on behalf of the applicant.

 

Although it is not always a specific planning policy requirement, a well-considered and carefully evidenced PBSA management plan can ease management concerns for an LPA and strengthen the credibility of an application for PBSA.

The London Plan sets a requirement for PBSA development to provide “adequate functional living space and layout for occupants.” Unlike other forms of residential development, there is no set requirement for unit sizes. This is replicated in Local Plan policies. 

 

PBSA units typically take the form of cluster bedrooms, studios (including larger premium studios), ‘twodios’, or ‘threedios’. The sizes are typically dependant on many factors, including location, market, operators’ business model/product, form of development, amount of communal space and viability. Our research indicates that the number of approved cluster rooms (51%) and studio rooms (48%) is quite evenly balanced. 

 

 

 

Increasingly, LPAs are using bedroom sizes to compare between PBSA schemes. Operators and developers argue that continued flexibility in room sizes is essential as the need will vary from location to location. 

 

In our view, qualitative considerations like the overall design and layout efficiency of a bedroom and the amount, range and quality of students’ facilities are of equal or greater importance to unit size. Continued flexibility will ensure PBSA schemes can come forward according to market demand to help address the overall need.

As with bedroom sizes, the London Plan does not specify area-based standards for communal facilities or external amenity space. Instead, it states that PBSA schemes should offer "adequate functional living space and layout for occupants". 

 

The communal facilities in a PBSA scheme are an important part of the student experience and indeed a key selling point for PBSA providers. Many PBSA developers pride themselves on delivering a high quality internal and external amenity offer.

 

The communal facilities in PBSA schemes take many forms such as communal living room areas, gyms, cinemas and the kitchen and dining spaces associated with cluster units.

 

 

In our research, we found that the ground floor uses and active frontages are very important for providers and operators who consider this to be an aspect of the profile and ‘kerb appeal’ of the PBSA development.  

 

Our research suggests that most LPAs do value the provision of both internal and external amenity space within new PBSA development, though many appear to prioritise internal space especially where there are external space constraints. It is important in our view to retain flexibility in the provision of communal facilities and amenity space for students.