BEFS has been actively engaging with its Members and Working Groups on the implications of the late 2025 withdrawal of 46 planning guidance publications by the Scottish Government.
The Planning and Architecture Publications Declutter statement by the Scottish Government explained its rationale for removing what it termed, “all dated national planning advice.”
BEFS Members have shared concerns about the implications of the withdrawal of two Planning Advice Notes in particular: PAN 2011/2: Planning and Archaeology, and PAN 71: Conservation Area Management.
BEFS Members including the Association of Local Government Archaeological Officers (ALGAO) Scotland, the Chartered Institute for Archaeologists and the Society of Society of Antiquaries of Scotland, have expressed concern that the withdrawal of PAN2/2011 is creating problems in the determination of planning applications with archaeological implications. In addition, the Conservation Officers Group, facilitated by BEFS, have reported difficulties in the management of conservation areas emerging from the withdrawal of PAN 71.
BEFS has been representing the views of its Members and Working Groups to policy-makers. We are now pleased to share the following update statement from Historic Environment Scotland’s Heritage Directorate.
Update on PAN 71: Conservation Area Management and PAN 2011/2: Planning and Archaeology
Historic Environment Scotland (HES) has been liaising with the Scottish Government on the withdrawn Planning Advice Notes (PANs) that relate to the historic environment, including PAN 71: Conservation Area Management and PAN 2/2011: Planning and Archaeology. We have agreed with Scottish Government that HES will work with relevant stakeholders to develop updated guidance and advice covering these important subject areas.The withdrawal of these PANs provides an opportunity to refresh the guidance so that it references and reflects recent policy changes, including National Planning Framework 4 (NPF4), and responds to the current and relevant issues facing decision makers. We also hope to align the updated guidance/practice notes with the refresh of the Historic Environment Policy for Scotland (HEPS), ensuring that future advice is clear, current and well connected to the wider policy context.Over the coming months, HES will be in touch with stakeholders to gather information and views on the current advice notes. This will help us understand which parts of the existing guidance remains useful, where further clarity may be needed, and what revisions that would be beneficial. We will also arrange workshops with key stakeholder groups to discuss the scope and content of the updated guidance. This would most likely take the form of a new Historic Environment advice note and will not result in an updated PAN.We are working directly with ALGAO Scotland on the guidance covering Planning and Archaeology and will work with the Conservation Officers Group (COG) to develop guidance for Conservation Areas.In the meantime, if you have any questions or queries, please contact the Heritage Policy Team at HES.
BEFS looks forward to working with HES, ALGAO Scotland, COG and other stakeholders on next steps.
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The Places of Worship Forum (POWF) is seeking views on the best mechanism for these special buildings – both in and outwith worshipful use – and invites readers to participate in a survey on Ecclesiastical Exemption.
Why are we talking about Ecclesiastical Exemption?
Ecclesiastical Exemption in Scotland is a legal provision under the Planning (Listed Buildings and Conservation Areas) (Scotland) Act 1997. Listed buildings whose primary use is as a place of worship will normally have exemption from the need for listed building consent. Historic Environment Scotland’s Guidance on Ecclesiastical Exemption answers many frequently asked questions on this subject.
Ecclesiastical exemption is considered to end when the final closing service is held, or when no more services are scheduled. Local authorities administer listed building consents and are responsible for deciding whether consent is required.
Current context for places of worship
Built Environment Forum Scotland provides secretariat support for the Places of Worship Forum (POWF). POWF represents faith groups as well as national bodies with an interest in the ownership, funding, sustainability, and the future of places of worship. The aim of the group is to collectively seek sustainable future uses and transition pathways (both within and beyond worship) for Places of Worship in Scotland.
Change and adaptation is an important part of seeing these special buildings survive into the future.
The origins of this recent conversation about Ecclesiastical Exemption stem from the Places of Worship: Planning Forward conference back in October 2025, where discussions explored – amongst other topics – the changed context for places of worship since Ecclesiastical Exemption was put into place.
Questions were raised around how well Ecclesiastical Exemption is understood by congregations, communities, building owners, and decision makers, and highlighted a desire for better signposting and guidance on grey areas, such as when it should end, and how it applies to places of worship used for multiple purposes.
As HES’ Guidance notes: ‘Many congregations wish to use their buildings in a more diverse way. This means that there are an increasing number of situations that the existing legislation did not anticipate and to which there are no straightforward answers.’
This survey has been created on behalf of POWF and aims to gather views and information, to understand what is the most effective mechanism to enable protection and continued use of these buildings, within the planning system and consents process (ecclesiastical exception or otherwise) – both in and outside of ecclesiastical use.
POWF is seeking all views – from congregations; denominations and faith groups; communities; heritage organisations; building managers; developers; architects; planners; businesses and more.
To participate in the survey please follow this link. The deadline for submissions is the 1st of September 2026.
What happens next? BEFS Team will analyse the responses, with the findings forming the basis for recommended next steps by the Places of Worship Forum and stakeholders, as part of a continuing conversation.
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