CIL appeal 1892711 contains a particularly useful warning for anyone dealing with mobile-home-style structures, residential annexes and Community Infrastructure Levy.
The Appointed Person accepted important parts of the appellant’s caravan case. The annexe had been assembled from factory-made components, fitted within the statutory dimensions relevant to a twin-unit caravan and was capable of movement in the sense used by the caravan authorities.
That still did not answer the separate CIL question. Looking at size, permanence and physical attachment, the Appointed Person concluded that the annexe was a building giving rise to chargeable floorspace. The Regulation 114 appeal was dismissed.
What CIL appeal 1892711 actually decided
The Valuation Office Agency published the decision on 8th September 2026. The appeal itself was decided on 20th July 2026.
The development was described in the planning permission as the retention of a detached annexe ancillary to the main dwelling together with associated external decking. The location, liability amount and several other details are redacted in the published decision.
The collecting authority issued a CIL liability notice on the basis that the annexe created chargeable residential floorspace. The appellant first sought a review under Regulation 113 of the Community Infrastructure Levy Regulations 2010 and then appealed the chargeable amount under Regulation 114.
The appellant’s case was that the annexe was a caravan rather than a building. If it was not a building for CIL purposes, the argument was that it created no chargeable floorspace and the liability should be nil.
You can read the full CIL appeal 1892711 decision, hosted by Planning Geek. The decision was published by the Valuation Office Agency on GOV.UK on 8th September 2026.
This was a CIL appeal, not a caravan planning appeal
This is the part of the decision that makes it worth keeping.
The Appointed Person expressly said the appeal was being determined under the CIL Regulations, not as a planning appeal. Planning legislation, lawful development certificates and caravan cases were relevant only so far as they helped answer the CIL question.
The collecting authority had initially argued that the caravan-versus-building issue fell outside Regulation 114 because the arithmetic of the CIL calculation was not disputed. The Appointed Person rejected that approach. If the structure was not chargeable floorspace at all, that plainly affected the chargeable amount and could be considered under Regulation 114.
Planning Geek analysis: this is a neat example of why the legal regime matters. A label such as caravan, building, dwelling or structure can perform different work in different statutes. You have to identify the statutory question before borrowing an answer from another planning context.
Our guide to CIL reviews and appeals explains the Regulation 113 and Regulation 114 routes in more detail.
The caravan construction test helped the appellant
The statutory caravan framework comes principally from the Caravan Sites and Control of Development Act 1960, read with the twin-unit provisions in the Caravan Sites Act 1968.
The appellant said the annexe had been formed from factory-manufactured components and assembled on site, with a visible central joint. The supplier gave evidence about the way the two parts had been put together.
The Appointed Person accepted that evidence and also accepted the proposition that assembly on site does not automatically prevent a structure satisfying the construction test.
That is useful because the physical act of assembling something on the land can easily distract from the actual statutory caravan definition. Factory completion in one piece is not the only route to caravan status.
Mobility also helped the appellant
The appellant relied on authorities including Measor and Carter for the proposition that mobility is about capability of movement, rather than how often the structure will actually be moved or whether its owner intends to move it regularly.
Again, the Appointed Person accepted the important proposition. The unit fell within the maximum statutory dimensions associated with a twin-unit caravan, and the relevant question was capability of movement rather than frequency or intention.
Size also favoured the appellant when the later building test was applied.
But the decision did not stop there.
Why the caravan points did not settle CIL liability
At paragraph 37 the decision makes the central point: satisfying the construction and mobility tests was not, by itself, determinative of whether the structure was a building for CIL purposes.
The CIL Regulations do not contain a comprehensive definition of building. The decision therefore considered the ordinary meaning of the word and the established planning authorities on whether a structure has become a building.
The key authority was Skerritts of Nottingham Ltd v Secretary of State for the Environment, Transport and the Regions (No. 2) [2000] 2 PLR 102, which Planning Geek hosts locally.
The familiar factors are size, permanence and degree of physical attachment. They are considered together as a matter of fact and degree rather than as three rigid boxes.
Our guide to when a caravan can also amount to a building explains that wider planning-law question.
Permanence was the strongest factor
Size favoured the appellant. Permanence did not.
Planning permission had been granted for the retention of the detached residential annexe. There was no condition limiting how long it could remain and no requirement for its future removal.
The Appointed Person considered it reasonable to treat the annexe as installed for long-term residential occupation ancillary to the house and forming part of the established planning unit.
Those facts pointed strongly towards permanence.
This is a useful reminder that permanence does not mean a structure must be physically incapable of removal. The planning and functional reality of how it has been placed and authorised on the land can carry substantial weight.
The foundations and supporting works mattered too
The annexe was not mechanically fixed to the land. It rested under its own weight, which again assisted the appellant.
But it was supported by substantial brick and blockwork piers, plinth walls and associated hardstanding built specifically to accommodate it.
The decision referred to Massingham v Secretary of State for Local Government and the Regions [2002] EWHC 1578 (Admin). That authority supports the proposition that connection to services or placement on a base does not automatically turn a caravan into a building.
The Appointed Person did not treat the base as an automatic answer. Instead, the purpose-built supporting works were considered alongside the permanent residential use, integration within the planning unit and intended permanence.
Taken together, those matters were sufficient to establish the physical and functional relationship with the land needed to support classification as a building for CIL.
Why neighbouring caravan decisions carried limited weight
The appellant relied on planning appeal decisions and a lawful development certificate relating to another property.
The Appointed Person treated them as useful guidance on caravan legislation, but gave them limited weight because they arose in different planning contexts and turned on their own facts.
That is exactly the trap this decision exposes. A successful caravan argument in a lawful development certificate or enforcement appeal does not automatically answer a later CIL liability question.
For the same reason, this decision should not be rewritten into the over-broad statement that caravans are liable for CIL. It says nothing of the sort.
The connection with Rayleigh and Leigh-on-Sea
Planning Geek has recently covered two other decisions about moveable structures and buildings.
In Rayleigh, 47 shipping containers were treated as buildings. In Leigh-on-Sea, an Inspector found that a car port could be moveable by hand and still be a building.
CIL appeal 1892711 belongs in the same broad family, but the legal point is materially different. Rayleigh and Leigh-on-Sea were about operational development and planning status. This appeal was about chargeable floorspace under the CIL Regulations.
Planning Geek analysis: that difference is why this CIL decision deserves its own place in our CIL guidance rather than simply being added as a third example everywhere we discuss buildings and chattels.
What should an owner or developer take from the decision?
First, do not assume that satisfying important elements of the caravan definition ends every planning or CIL question.
Second, look at the physical works around the unit. Purpose-built piers, plinths, hardstanding and long-term domestic integration may be important even where the unit itself rests under its own weight.
Third, read the planning permission. A permanent permission for a residential annexe with no removal requirement can be highly relevant to permanence.
Finally, use the correct statutory route if the CIL liability notice is disputed. Regulation 113 provides a review mechanism and Regulation 114 provides the chargeable amount appeal. The procedural deadlines matter.
Our CIL calculation guide explains how chargeable floorspace is worked out, while our garden caravan guidance deals with the separate planning questions that arise when a caravan is kept within a residential curtilage.
The Planning Geek lesson
A structure may satisfy important statutory caravan characteristics and still be treated as a building when the CIL Regulations are applied.
The safe question is not simply “is it a caravan?” It is “what legal test am I applying, for what purpose, under which statutory regime?”
That is why CIL appeal 1892711 is more useful than a simple caravan-versus-building headline suggests.
Primary source
Planning Geek hosts the full CIL Appeal 1892711 decision locally. The original was published by the Valuation Office Agency on GOV.UK on 8th September 2026 and is dated 20th July 2026.
Created: 9th September 2026
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