🎯 Objective
To expose and dismantle coordinated developer abuse within the planning system — including shell company networks, false independence of applicants, and systematic delivery failure. CEAP provides investigatory tools, misconduct tracking, and enterprise-wide enforcement to stop abuse at its organisational root.
🧾 Policy C1 – Developer Misconduct Register (with Sanctions)
What it does:
Creates a public, national register that lists developers who have:
- Failed to deliver as approved
- Repeatedly renegotiated obligations
- Submitted misleading documentation
- Been found in breach of planning or financial ethics
Inclusion on the register directly reduces planning weight in future applications and may trigger enhanced scrutiny.
Why it’s needed:
To disincentivise repeat abuse, protect community expectations, and shift developer culture from risk-free manipulation to transparent delivery.
International Analogy:
The UK’s Financial Conduct Authority (FCA) publishes misconduct registers for regulated firms. CEAP brings similar institutional discipline to planning.
🏢 Policy C2 – Mandatory Group-Level Enforcement Powers
What it does:
Empowers planning authorities to treat connected developer entities as one “economic actor” when enforcing delivery obligations — closing loopholes where one shell company defaults while others proceed unaffected.
Why it’s needed:
To stop rotation schemes, where control is split across technical subsidiaries that escape enforcement individually.
International Analogy:
The EU’s Anti-Money Laundering Directive and U.S. Beneficial Ownership rules target exactly this kind of layered legal concealment.
⚖️ Policy C3 – Financial Crime Referral Protocol
What it does:
Mandates that local planning authorities (LPAs) and the Planning Inspectorate refer suspected cases of:
- Intentional misrepresentation
- Land banking for manipulation
- Coordinated shell behaviour
to the National Crime Agency (NCA), HM Revenue & Customs (HMRC), and Competition and Markets Authority (CMA).
Why it’s needed:
Because current planning fraud often goes uninvestigated and unprosecuted due to unclear jurisdiction and lack of a statutory offence.
Note: This policy is enabled by the April legal reform proposal: “Statutory Planning Fraud by Misrepresentation or Omission”.
International Analogy:
In finance, banks are legally required to file Suspicious Activity Reports (SARs) to trigger criminal investigations — CEAP C3 brings that logic to planning.
⛔ Policy C4 – Planning Moratorium Power
What it does:
Grants LPAs and the Secretary of State the legal power to suspend all applications and appeals associated with a developer or group under active investigation for misconduct or fraud.
Why it’s needed:
To prevent ongoing abuse during investigations, and restore trust by signalling that bad faith applicants will not proceed unchecked.
International Analogy:
Financial regulators suspend licences and trading rights — CEAP creates the planning system equivalent.
🕵️ Policy C5 – Statutory Right to Investigate Ownership & Control
What it does:
Gives LPAs the right to demand full beneficial ownership disclosure of landowners, applicants, and all associated entities during the planning process — including trust structures and offshore holdings.
Why it’s needed:
To stop entities from hiding control, gaming multiple applications, or bypassing thresholds using shell proxies.
International Analogy:
The UK’s Economic Crime (Transparency and Enforcement) Act 2022 created similar rules for overseas property ownership disclosure.
🧠 Policy C6 – Internal Land Registry Monitoring Directive
What it does:
Establishes a planning intelligence partnership with HM Land Registry to proactively monitor:
- Patterns of land flipping
- Suspicious clustering of shell company ownership
- EIA (Environmental Impact Assessment) threshold gaming via site fragmentation
Why it’s needed:
To detect speculative coordination early — not after communities are overwhelmed.
International Analogy:
Canada’s real estate data reforms now monitor ownership concentration and market distortion through land registry analytics.
📘 Summary
The Coordinated Enterprise Abuse Prevention Portfolio (CEAP) recognises that planning manipulation is not just policy failure — it’s systemic, enterprise-level misconduct. CEAP introduces tools to detect, investigate, and stop developer networks that misuse the planning system to hoard land, evade obligations, or delay delivery. It protects the public interest by ensuring that control, not just paperwork, is accountable — and that abusers are stopped, not rewarded.