From 13 October a submission to a planning authority on a new application must be made on a prescribed form, must follow its format rules, and must carry a signed declaration. A submission that does not is invalid. This guide sets out what the form asks for and what changes from the letter people have always sent.
The basics do not move. Anyone may make a submission or observation on a planning application within five weeks of the authority receiving it, for a fee of €20, and only a person who made a submission (or the applicant) may later appeal the decision. What moves is the container the submission has to arrive in.
Section 86(1)(c) of the Planning and Development Act 2024 obliges the authority to have regard to any written submission made "in accordance with any provision or requirement of this Act or any regulations made under this Act", which is why the form matters. Section 86(4) requires the authority to return a submission received after that period. Section 588(1) requires a submission under Chapters 3 to 5 of Part 4 to be accompanied by a declaration in a form the Minister prescribes. The draft regulations do the prescribing: regulation 17(1) sets the period at five weeks from receipt, regulation 17(3) returns a late submission with the fee, and regulation 17(5) provides that a submission "shall be in the form as set out in Form No. 5" and "shall be accompanied by a declaration in accordance with section 588(1) of the Act in the form as set out in Form No. 6". The €20 fee is in the draft Planning and Development (Planning Authority Fees) Regulations 2026, Schedule 2.
Form No. 5 is a one-page template headed "Planning and Development Act 2024, Submissions and Observations". It asks for the name and address of the person making the submission, the application it relates to and the planning reference, and then gives a box, "to be expanded as required", for the submission itself. Where a submission is made electronically with the authority's consent, contact details are taken from the registration on the authority's system rather than from the form. Every authority will publish its own version carrying its logo; the content is fixed by the Schedule.
The form is followed by guidance notes, and the notes are where the change lies. They are not advisory. The form states: "Failure to comply with the mandatory format requirements shall invalidate the submission or observation." An invalid submission is not considered, and a person whose submission was invalid has not made a submission for the purpose of appealing later.
A submission or observation shall:
Three habits that have always been part of a submission are now outside the form. A photograph taken from a back garden to show overlooking is an embedded image; describe the relationship in words and, where the applicant's own drawing shows it, cite the drawing number and the dimension on it. A link to the development plan, to a Commission decision or to a guideline is a web address; cite the document by name, section and paragraph instead. A consultant's report, a daylight study or a traffic count is an appendix; it may go in only with the written permission of whoever holds its copyright, which for a report the submitter commissioned is usually the consultant, so ask for the permission when commissioning it. The applicant's drawings and the planner's report belong to others and cannot be attached; quote them.
The 1,000-word threshold is worth respecting in the other direction too. A submission of three or four grounds, each tied to a plan objective or a national standard and to something on the applicant's own drawings, will usually come in under it. Where it does not, the 300-word summary at the top is what a busy case planner reads first.
The submission is a public document. The form states that its content is entered on the planning register and, unless specified, published online and available for inspection within five working days of receipt. Rule 7 is the reason to argue the planning and not the applicant.
Form No. 6 is headed "Declaration under Section 588(1)". The person making the submission gives their name, address, email and telephone number and declares that the submission "is not made for the purpose of (a) delaying the carrying out of any development or proposed development, or (b) securing the payment of any consideration to, or the doing of any other thing for the benefit of, any person", then signs and dates it. There is no witness and no commissioner for oaths; it is a declaration in a prescribed form, not a statutory declaration under the 1938 Act. Only a person over 18 may sign it; a guardian makes the submission for a minor. The form itself is not published: it is held for the authority, An Coimisiún Pleanála and the courts. A submission without it cannot be accepted. A declaration that is knowingly false or misleading in a material respect is an offence under section 588(6), carrying a class A fine or up to twelve months' imprisonment. Section 587 makes it a separate offence for anyone to ask a submitter for money or a benefit to withdraw, complete when the request is made whether or not anything is paid.
The fee of €20 is unchanged from the 2001 Regulations. The five weeks run from the date the authority receives the application, not from the site notice, and the authority's website and weekly list give that date. Where the authority has consented to electronic submissions, one received before midnight on the last day is in time. A submission that arrives after the period is returned with the fee and the person is told it cannot be considered. The authority acknowledges every valid submission in Form No. 7, and that acknowledgement is what An Coimisiún Pleanála will ask for as proof that a submission was made if the decision is later appealed. Keep it.
A submission on a local authority's own development under section 153 (the successor to Part 8) is made on a similar form prescribed by the draft Planning and Development (Local Authority Own Development) Regulations 2026, with the same seven format rules and the same consequence for breaking them, but without a section 588 declaration, because that section does not reach Chapter 6 of Part 4. A submission on a material contravention notice under section 99 does carry the declaration (draft regulation 23). An appeal to An Coimisiún Pleanála by anyone other than the applicant carries the declaration too, and so does a later withdrawal of a submission or an appeal; the Commission's own procedures may prescribe its version of the form.
None of this applies to an application lodged on or before 12 October 2026. A submission on such an application is made under the 2000 Act and article 29 of the 2001 Regulations: within five weeks, with the €20 fee, in any legible form, with photographs, links and appendices as the submitter sees fit, and with no declaration.
We can advise whether there is a planning case, and prepare the submission or appeal if there is.