Faculty or Listed Building Consent for Church Solar?

Two parishes a mile apart, both with Grade II listed buildings, both putting panels on a south slope. One applies to the diocesan chancellor. The other applies to the council. Neither is doing it wrong.

Which route you are on is set by who owns the building and what it is used for, not by its listing grade — and getting it wrong wastes months. This post sorts out which consent regime applies to a listed place of worship, and, more usefully, where the exemption stops applying to buildings a parish assumes are covered.

For the wider picture on what actually gets approved on a listed building and what it costs, see our guide to solar panels on listed buildings.

The starting position: listing removes permitted development

Solar on an unlisted, non-domestic building is normally permitted development under Class J of Part 14, Schedule 2 to the General Permitted Development Order 2015. Class J is dimensional — 0.2 m beyond a pitched roof plane, 1 m above the highest part of a flat roof, 1 m back from the roof edge — and since 21 December 2023 it has carried no capacity limit.

But Class J is switched off for a listed building, a scheduled monument, and land within the curtilage of either. So the moment the building is listed, permitted development stops being the answer and something has to grant consent instead. The question is what.

The ecclesiastical exemption, and the six denominations that hold it

Under the Planning (Listed Buildings and Conservation Areas) Act 1990, certain places of worship are exempt from the requirement for listed building consent and conservation area consent. In England the denominations holding that exemption are set out in the Ecclesiastical Exemption (Listed Buildings and Conservation Areas) (England) Order 2010:

• the Church of England
• the Church in Wales
• the Roman Catholic Church
• the Methodist Church
• the Baptist Union of Great Britain
• the United Reformed Church

If your listed building belongs to one of these and is in use as a place of worship, you do not apply to the local authority for listed building consent. You go through your denomination’s own control system instead — which exists precisely because Parliament accepted that these buildings have a living liturgical function and that their own bodies, with proper consultation, could regulate change to them.

Two things follow that parishes routinely get wrong.

The exemption is from listed building consent, not from planning. Planning permission is a separate question and can still be required, particularly for anything on a boundary, in a churchyard or visible in a conservation area streetscape. Being exempt does not mean being unregulated by the council.

If your denomination is not on the list, you are in the ordinary system. An independent evangelical church, a Quaker meeting house, a Unitarian chapel, a mosque, a synagogue, a gurdwara or a mandir in a listed building applies for listed building consent like any other listed building owner. That is not a worse route — it is a different one, with a published determination period and a conservation officer rather than a chancellor.

What the Church of England route actually involves

For a Church of England parish the internal system is the faculty jurisdiction. In outline: you consult the Diocesan Advisory Committee, which advises on the proposal and issues a notification of advice; you give public notice; and the chancellor of the diocese determines the application and grants the faculty. Historic England, the Amenity Societies and the local authority are consulted where the proposal warrants it.

The practical difference from a council application is what the decision-maker is weighing. A conservation officer is applying statutory tests about harm to a listed building’s special interest. A chancellor is doing something closer to that but in a church-law framework, with the DAC’s expert advice and the parish’s own missional case both in front of them. A well-made faculty application therefore reads differently from a well-made listed building consent application: it has to explain the need as well as the impact.

Our listed church installation guide covers the route in detail, and the faculty application page covers what goes in the paperwork.

Where the exemption stops — the three buildings parishes get wrong

This is the part worth reading twice, because each of these is a real trap.

1. Residences are not covered. The exemption applies to places of worship, their contents and curtilage. It does not extend to residences. A listed vicarage, rectory, manse or presbytery is an ordinary listed building for consent purposes, so solar on it needs listed building consent from the council even though the diocese owns it and even though the church next door is exempt.

2. Halls depend on use, not ownership. The exemption attaches to the building used as a place of worship. A separate church hall used for lettings, groups and community activities is not a place of worship, so it is not covered by the exemption in its own right — and if it is separately listed, it needs listed building consent. The church and parish hall guide covers the hall-specific position, including how lettings affect the VAT rate.

3. Curtilage catches unlisted buildings. Cutting the other way: a hall that is not listed can still lose its permitted development rights if it sits within the curtilage of the listed church, because Class J excludes land within the curtilage of a listed building. Parishes discover this late, having assumed an unremarkable 1970s hall was outside the whole regime. Establish the curtilage position before you design anything, because it determines whether you need any application at all.

So a single parish can easily be running three different consent routes on one site: faculty for the church, listed building consent for the listed vicarage, and a planning application for an unlisted hall inside the curtilage.

A practical order of work

1. Confirm the listing. Check the building on the National Heritage List for England, or the equivalent register in Wales, Scotland or Northern Ireland. Do not rely on local knowledge about grade.
2. Identify the denomination and the use. Exempt denomination plus use as a place of worship equals the internal route. Anything else equals listed building consent.
3. Map the curtilage. Which of your other buildings sit inside it, and therefore lose Class J.
4. Ask which buildings are actually the best candidates. Frequently the answer is the unlisted hall outside the curtilage, which needs no application at all.
5. Only then design the array, because the consent route shapes what is designable — reversible fixings, slope choice, and visibility from the public realm.

Two things the consent route does not change

It is worth being clear about what listing does not affect, because both get muddled into consent discussions.

It does not change the VAT. Installing solar is an installation of energy-saving materials, zero-rated in a building used solely for a relevant charitable purpose until 31 March 2027 whether the building is listed or not. The scheme that used to reimburse VAT on works to listed places of worship closed on 31 March 2026, which is a real loss for repairs but makes no difference to a zero-rated installation.

And it does not change the grid connection. G98 and G99 are set by system size — 16 A, about 3.68 kW per phase, is the G98 threshold — and the distribution network operator neither knows nor cares what grade your building is.

If you are working out which route applies to a specific building and what is likely to be approved on it, start with our main guide to solar panels on listed buildings, which covers what conservation officers and chancellors approve by grade and the reasons applications get refused.