Require documents to be submitted as files within the application record
- Decision
- 0003
- Status
- Proposed
- Date
- 2025-12-18
Context:
During discussions on how documents should be represented and referenced within an application submission, the option of allowing applicants to provide external links (e.g. URLs) to documents instead of uploading the documents themselves was raised.
This approach has been suggested previously in advisory group sessions as a way to reduce file uploads and simplify submissions. However, it introduces questions around data permanence, record integrity, and reliability once the application moves into back-office systems.
Decision:
We will require that documents associated with an application are submitted as files and captured as part of the application record.
External links to documents will not be treated as valid substitutes for submitted documents.
Rationale:
Planning applications are legal and administrative records. Documents that form part of an application must be:
- captured as part of the application record
- stable and referenceable at any given point in time
- changed only through an explicit, auditable process between the applicant and the authority
Allowing external links creates a risk that documents could change, move, or disappear outside the control of the planning process, undermining the integrity of the application record. It also adds complexity to validation, storage, auditing, and long-term retention.
By requiring documents to be submitted directly, we ensure that: - the application record represents a reliable snapshot at each stage of the process - any changes to documents are visible, intentional, and governed - back-office systems receive a consistent and dependable set of artefacts
This keeps the model aligned with how planning applications are assessed, amended and relied upon in practice.
Alternatives Considered:
- Allowing external links to documents → rejected due to risks around uncontrolled change, availability, and record integrity.
- Supporting a hybrid model (files or links) → rejected as it increases complexity without clear user or system benefit.
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