Converting commercial office space to residential use has become one of the most significant sources of new housing supply in England over the past decade. The permitted development right for office-to-residential conversion — currently Class MA of Part 3, Schedule 2 of the GPDO — allows conversion without full planning permission in many cases, subject to a prior approval process. Crown Architecture & Structural Engineering Ltd has experience designing and engineering office-to-residential conversions across London and the South East. This guide explains how Class MA works in 2025.
What is Class MA?
Class MA (introduced in 2021, replacing the former Class O rights) permits the change of use of a building in Use Class E (which includes offices, retail, restaurants, and light industrial) to Use Class C3 (dwellinghouses) without a full planning application. Instead, the developer must apply for “prior approval” from the LPA, which considers a limited set of specified matters rather than the full range of planning considerations.
Buildings Eligible for Class MA
To be eligible for Class MA conversion, the building must:
- Be in Use Class E at the date of prior approval application
- Have been in a use falling within Class E on 1 September 2020 (to prevent circumvention of the protection)
- Not have been in Use Class C3 (residential) at any time in the 10 years before the application
Class MA Does Not Apply Where
The right does not apply where:
- The building is a listed building or within the curtilage of a listed building
- The site is within a Site of Special Scientific Interest (SSSI)
- The site is within 3km of an aerodrome runway
- The site is in a safety hazard area or military explosives storage area
- The building has a floor area over 1,500m² (only the first 1,500m² can be converted under Class MA)
- The LPA has made an Article 4 Direction removing Class MA rights (many London boroughs have done this in employment-protection areas)
Prior Approval: What the LPA Can Consider
Unlike a full planning application, Class MA prior approval limits the LPA’s assessment to specified matters:
- Transport and highways impacts
- Contamination risks
- Flooding risks
- Noise impacts from existing commercial or industrial uses
- Natural light to proposed residential units (introduced in 2021 — all habitable rooms must receive adequate natural light)
- Adequate fire escape
- Impact on protected view (within the setting of a listed building or World Heritage Site)
- Impact on the provision of industrial floorspace (in protected employment areas)
The LPA cannot consider matters such as residential design quality, density, affordable housing, or impact on local character — these are not within the prior approval scope.
The Prior Approval Process
Application Submission
A prior approval application is submitted to the LPA with:
- Site location plan
- Existing and proposed floor plans and elevations
- Supporting assessments addressing the prior approval considerations (noise, flood risk, contamination, natural light, transport)
- Application fee (currently £120 per dwelling to be created, up to a maximum of £35,000 for sites creating 75+ dwellings)
Determination Period
The LPA has 8 weeks to determine a Class MA prior approval application. The LPA must also consult:
- The adjoining owner/occupiers
- The highway authority
- The Environment Agency (if the site is in a flood risk area)
If the LPA approves prior approval (or does not respond within 8 weeks), the developer may proceed with the conversion subject to Class MA conditions. If prior approval is refused, the developer can appeal to the Planning Inspectorate.
Building Regulations for Class MA Conversions
A prior approval under Class MA does not include Building Regulations approval. A separate Building Regulations application must be submitted for the conversion works. Key Building Regulations requirements for Class MA conversions:
- Part B (Fire Safety): Fire compartmentation, protected escape routes, fire alarms, and means of escape — typically significantly upgraded from the commercial specification
- Part C (Moisture): Dampproofing and weathertightness — many commercial buildings lack adequate damp protection for residential use
- Part E (Sound): If the conversion creates multiple dwellings from a single building, sound insulation between dwellings is required. Pre-completion acoustic testing is required for adjacent dwellings and floors
- Part F (Ventilation): Whole dwelling ventilation design — commercial buildings typically rely on mechanical ventilation systems that may not be suitable for residential use
- Part L (Energy): Thermal elements must meet Part L standards for change of use. Upgrading walls, floors, and roofs to current U-values is required where technically feasible
- Part M (Access): Accessible entrance and Category 1 (Visitable Dwellings) requirements for new dwellings
Structural Considerations for Commercial-to-Residential Conversion
Commercial office buildings are typically designed for higher imposed floor loads (3.0–5.0 kN/m²) than residential dwellings (1.5 kN/m²). The structural frame is usually more than adequate for residential loading. However:
- Floor-to-ceiling heights in commercial buildings may be lower than residential standards (2.4m+ is typical residential minimum)
- Where new openings are required (windows, doors, lift shafts), structural design for new beams and lintels is needed
- Service penetrations (for new drainage, ventilation, and mechanical systems) through structural elements require careful coordination
- Where the building requires new staircase arrangements or additional lifts for the residential layout, structural design for new openings is required
Costs for Class MA Office-to-Residential Conversions
Costs vary enormously depending on the building’s existing condition and specification. Typical cost ranges in 2025:
- Basic fit-out (commercial to standard residential finish): £500–£900/m² GIA
- Mid-specification residential conversion: £900–£1,400/m² GIA
- High-specification conversion (central London): £1,500–£2,500+/m² GIA
- Prior approval application fee: £120/dwelling (capped at £35,000)
- Architect and structural engineer fees: Typically 8–12% of construction cost for full service
How Crown Can Help
Crown Architecture & Structural Engineering Ltd provides full architectural and structural services for Class MA office-to-residential conversions — including prior approval applications, building regulations submissions, structural assessment of the existing frame, and construction stage services. Call us on 07443804841 to discuss your conversion project.
Frequently Asked Questions
What Article 4 Directions affect Class MA rights?
Many London boroughs — and some other LPAs in areas with concentrations of office employment — have made Article 4 Directions removing Class MA rights in designated Employment Protection Areas (EPAs) or similar zones. If your building is in a London borough, check whether Class MA rights apply at that location before relying on the PD route. Full planning permission for change of use to C3 may still be possible where Class MA does not apply, but requires demonstrating compliance with employment protection policies.
Can I extend a Class MA conversion to add additional floors?
The permitted development right to upward extension (Class A of Part 20) allows additional storeys to be added to existing residential buildings and some commercial buildings converted to residential, subject to prior approval. This creates an opportunity to increase the number of units in a Class MA conversion by adding new floors. Structural engineering assessment is required for any upward extension.
Do Class MA conversions need affordable housing contributions?
Class MA prior approval does not include assessment of affordable housing — it is not one of the specified prior approval matters. For this reason, Class MA conversions have been criticised for contributing to housing supply without contributing to affordable housing provision. Government policy on this continues to evolve; some LPAs have sought to use Article 4 Directions partly to redirect development to full planning permission routes where affordable housing can be negotiated.