Non-designated heritage assets and locally listed buildings

 

Not every building, structure or place with heritage value is nationally designated. A non-designated heritage asset (NDHA) is an asset identified as having a degree of heritage significance which merits consideration in planning decisions, but which does not fall within one of the statutory or nationally designated categories.

A locally listed building is one common form of non-designated heritage asset, but the terms are not identical. NDHAs can also be identified through a conservation-area appraisal, neighbourhood plan, Historic Environment Record or during the consideration of a planning proposal.

The crucial practical point is that NDHA status is a planning consideration, not a separate consent regime. Local listing by itself does not remove permitted development rights or create a form of “local Listed Building Consent”.

 

What counts as a non-designated heritage asset?

 

The August 2026 NPPF glossary defines the wider term heritage asset to include buildings, monuments, sites, places, areas or landscapes identified as having a degree of significance meriting consideration in planning decisions, including through local listing.

That can include locally important houses and shops, industrial buildings, farm buildings, archaeological sites, parks, landscapes, memorials, structures or other places with demonstrable heritage significance.

Historic landscape features can qualify too where the evidence shows sufficient significance. Our guide to ridge and furrow planning explains how surviving field earthworks may be treated as a non-designated archaeological or historic landscape asset.

By contrast, designated heritage assets include listed buildings, scheduled monuments, conservation areas, registered parks and gardens, registered battlefields, protected wreck sites and World Heritage Sites.

 

A building does not have to appear on a local list

 

“Non-designated heritage asset” is wider than “locally listed building”. A local list is a useful formal way of identifying assets, but an authority can identify an NDHA through other plan-making evidence or during decision-making where there is sound evidence of heritage significance.

That does not mean any old building can simply be called an NDHA to strengthen a planning objection. The identification should be based on evidence of genuine heritage significance. Current Planning Practice Guidance and Historic England’s Advice Note 7: Local Heritage Listing, third edition May 2026 provide useful guidance on identification and local-list criteria.

 

Does local listing remove permitted development rights?

 

No. Inclusion on a local list does not by itself remove permitted development rights.

This is a fundamental difference from the separate statutory controls affecting a nationally listed building. A local list does not create Listed Building Consent and does not itself turn ordinary works into development requiring planning permission.

If a local planning authority considers that particular permitted development could harm local heritage, it may make an Article 4 direction withdrawing specified GPDO rights. That is a separate legal step. Always check whether an Article 4 direction actually covers the property and the work proposed.

 

When does NDHA status affect a planning application?

 

The status matters when a planning decision has to be made. The authority should understand the asset’s significance and assess the effect of the development upon it.

Policy HE7 of the August 2026 NPPF says proposals having a positive effect on an NDHA should be supported. Where a proposal would harm its significance, that harm should be weighed against the benefits of the proposal using a balanced judgment, having regard to the scale of harm or loss and the significance of the asset.

This is deliberately different from the HE6 framework for designated heritage assets. There is no section 66 listed-building duty simply because a building is locally listed, and an NDHA does not acquire the same statutory status as a listed building.

For the wider policy exercise, see heritage significance and harm.

 

Can the setting of an NDHA matter?

 

Yes. The surroundings of an NDHA can contribute to its heritage significance. A farm building might derive significance from its relationship with a historic farmstead, or a locally important civic building from its relationship with a square, park or street.

The fact that a development is within the setting does not automatically mean harm. The assessment should identify how the surroundings contribute to significance and what the proposal would change.

The policy balance remains HE7; it should not be replaced with the statutory listed-building test.

 

What should a heritage statement cover?

 

Where an NDHA is relevant to an application, the supporting assessment should be proportionate. It should normally:

• identify the asset and the evidence for treating it as an NDHA
• explain its architectural, historic, archaeological or other heritage significance
• identify any contribution made by its setting
• describe the effect of the proposal on that significance
• explain design changes or mitigation used to avoid or reduce harm
• identify the benefits to be weighed if harm remains

A modest locally listed building will not ordinarily justify the same scale of assessment as a Grade I listed building. Proportionality is part of the national policy approach.

 

Can you appeal against local listing?

 

There is no statutory planning appeal simply against a local authority deciding to include a building on its local heritage list. Councils commonly provide their own consultation, representations or review procedures as part of managing the list.

If planning permission is later refused partly because of harm to an NDHA, the applicant can appeal that planning refusal in the normal way. The Inspector can then consider the evidence for the asset’s significance and the weight it deserves in the decision.

 

Relevant policy and guidance

 

• National Planning Policy Framework, August 2026 – especially HE7 and the Annex B glossary
• Planning Practice Guidance: Historic environment
• Historic England Advice Note 7: Local Heritage Listing, third edition May 2026
• General Permitted Development Order 2015 – including the separate Article 4 mechanism

 

Conservation, Heritage & Protected Sites

 

Non-Designated Heritage Assets Page Updated: 24th August 2026