There is no single UK-wide label that every planning CGI must carry. What you must show is set by each council’s local validation list and drawing standards, and by the planning system of the nation you are applying in. In practice, a planning image should say what it shows, where it was taken from, how it was produced and how accurate it is. Any AI use should be disclosed where the relevant body asks for it.
This guide sets out what councils actually ask for. It also covers how to avoid an invalid application and how we label images at Visual Trick.
TL;DR
- Labelling rules come from the local planning authority’s validation list, not from one national standard. Check the list before you commission images.
- Photographs and photomontages should carry a clear title and the exact viewpoint location, ideally shown on a map.
- Images should be accurate, objective and fair. Verified views (Landscape Institute Type 4) carry the highest level of verifiability.
- Do not put “Not to scale” disclaimers on plans and drawings. Many councils reject them, and perspectives are usually the exception.
- If AI was used to generate or alter an image in Planning Inspectorate casework, say so, explain how, and confirm who is responsible for accuracy.
Table of Contents
- What “CGI labelling” means in a planning application
- Is there a UK-wide legal requirement?
- What councils actually ask for
- The core labelling checklist
- Scale disclaimers: a common validation trap
- Accuracy: what makes a planning image misleading
- AI-generated or AI-altered images
- How to check your local requirements before you commission
- Perspective
- Working with Visual Trick on planning visuals
- FAQ
- Sources
What “CGI labelling” means in a planning application
In planning, labelling means the information that travels with a visual so a planning officer, a consultee or a member of the public can tell what they are looking at. That covers the title, the site address, the viewpoint, the type of image (photomontage, verified view, illustrative CGI), the method used and the date of the base photography.
It matters because of how validation works. A valid application in England needs a completed form, the national information requirements, the correct fee and the local information requirements, as GOV.UK’s guidance on making an application sets out. The local requirements sit in a local list, which must be formally adopted and published on the authority’s website less than two years before submission. If a visual is missing or poorly labelled, the council can hold the whole application back.
Dudley Council’s validation checklist shows the consequence. An application without the requisite information can be declared invalid and will not be registered or processed. If the missing information is not provided within 28 days, the application and fee are returned in full.
Is there a UK-wide legal requirement?
Not in the form of a single labelling rule. Section 62(3) of the Town and Country Planning Act 1990 lets a local planning authority require other information or particulars, as one council’s national and local validation requirements document explains. That is the legal hook councils use to ask for CGIs, photomontages and their supporting detail.
The four nations also run their own systems. England, Scotland, Northern Ireland and Wales each have their own primary planning legislation, and a comparison of the four systems notes that while the structures are similar, the detail differs. Wales passed the Planning (Wales) Act 2015, and in Northern Ireland planning functions passed to councils under the Planning Act (Northern Ireland) 2011, in force from 1 April 2015.
The practical rule: the authority that will validate your application decides. A scheme in Tower Hamlets, one in Bristol and one in Belfast can each be asked for different things.
What councils actually ask for
Councils phrase their requirements differently, but the themes repeat. These are examples from published guidance.
| Council | What it asks for |
|---|---|
| Tower Hamlets | CGIs for all major developments, showing likely visual impact in context. Views and format are agreed at pre-application stage according to scale, prominence and sensitivity (local validation list) |
| Islington | Photographs and photomontages for major developments, plus a massing model in .fbx format, geolocated by OS Grid Coordinates or Lat/Long, with original software and units (validation requirements, April 2024) |
| Windsor and Maidenhead | Computer generated images for major proposals, within the Design and Access Statement or as standalone plans |
| Bath and North East Somerset | Photographs and photomontages labelled on the front with a title and exact location (drawing standards) |
| Bristol | Photographs with a title in the image itself, for example the site address; existing and proposed drawings in separate, clearly titled files (online application standards) |
| Derby | Drawings missing required information are not validated. 3D urban context matters for major applications, especially how a proposal is experienced (planning drawing guidance) |
Notice what is common. Every council wants an image that can be identified (title, address), placed (location, context) and, for major schemes, produced to a method that can be checked.
The core labelling checklist
Whatever your authority, put these on or alongside every planning visual. It is a sensible baseline built from the guidance above and the Landscape Institute’s technical note.
- A title that says what is shown. For example “Proposed view from the High Street looking north”, not “View 3”.
- The site address. Bristol’s guidance asks for it in the image itself.
- The exact viewpoint location. Oxford’s drawing standards say photographs and photomontages should show the exact location they were taken from, and that showing it on an associated map is best.
- The type of image. Say whether it is an illustrative CGI, a photomontage or a verified view, so nobody assumes more accuracy than the method gives.
- Technical methodology. The Landscape Institute’s TGN 06/19 says visualisations should be accompanied by appropriate information, including a technical methodology and required data in page title blocks.
- Base photography details. Date, camera and lens, and the field of view, so the image can be reproduced.
- Existing and proposed kept distinct. Label them separately and keep files clearly named.
The Landscape Institute’s note is under review, so check its current status before you rely on a specific clause. It was published on 17 September 2019 and replaced earlier advice notes, as the Landscape Institute’s visualisation page records.
Scale disclaimers: a common validation trap
Many applicants add “Not to scale” to be safe. Several councils treat that as a fault. Oxford says drawings with “Not to Scale” or “Do Not Scale” disclaimers should not be provided, because plans are available for electronic measuring. Bath and North East Somerset will not accept them, with perspectives excepted. Central Bedfordshire’s validation guide goes further and says submissions carrying “Do not Scale”, “Not to Scale” or “Draft” will be considered invalid.
The lesson for visualisation is to keep scaled plans and perspective images separate. A perspective view cannot be measured with a ruler, so it is the one place such wording is tolerated. Even so, your title and method note should explain what the image is meant to show, so it never looks like a drawing in disguise.
Accuracy: what makes a planning image misleading
Labels only help if the image behind them is fair. The Landscape Institute’s guidance says visualisations should be accurate, objective and unbiased, and should give a fair representation of what would likely be seen if the proposal is built. They should also show the proposal in scale with its surroundings.
Things that commonly undermine that:
- A lens or field of view that makes the building look smaller or more distant than it will be.
- Vegetation shown at full maturity on day one, or winter views left out where leaf cover would hide the scheme.
- Sky, light or season chosen to flatter rather than to represent.
- A viewpoint picked because it is kind to the scheme, not because it is representative.
- Cartoon-like or exaggerated illustration passed off as evidence.
The guidance also warns that a sophisticated technique is not automatically more trustworthy, since accuracy depends more on implementation than on technique. A polished render can hide errors. A plain, well-documented one can be reliable.
Matching the image type to the setting
TGN 06/19 sets out photomontage types. Type 3 gives a reasonable level of locational and photographic accuracy but is not suited to the most demanding and sensitive contexts. Type 4 requires quantifiable verification data so the image can be checked, and is what the industry calls AVRs or verified views. It is the highest level of accuracy and verifiability.
So for a tall building near a conservation area or a heritage setting, agree early that verified views are expected. For a modest extension, a well-labelled Type 3 style image may be enough. Your council’s pre-application advice settles it.
AI-generated or AI-altered images
This is the newest labelling issue. The Planning Inspectorate’s guidance on AI in casework evidence applies in England and Wales. It says that if you intentionally used AI to generate or alter images or videos, you must tell the Inspectorate. You should explain what the AI was used for and how, state what checks you made, and confirm you take responsibility for accuracy. It also cautions against AI-made cartoons or exaggerated illustrations of a proposal, and notes that AI can produce fake representations.
That guidance covers appeals and casework evidence. Local authorities may take their own line on applications, so ask at pre-application stage. Our advice is simple: if a tool touched the pixels, record it in the methodology note. Keep the workings so a reviewer can see how the final image relates to the surveyed model and photography.
Architects who publish their planning work online may also find it useful to read about SEO for architects, since transparent visual evidence and clear online presentation both build trust with clients and councils.
How to check your local requirements before you commission
- Find the local list. Search your council’s website for “local validation requirements” or “local list”. It should have been adopted and published within the last two years.
- Read the drawing standards. Many councils publish separate guidance with the labelling rules above.
- Ask at pre-application. GOV.UK notes that pre-application discussions can help agree what information is required before you apply. For CGIs that means agreeing the viewpoints, the image type and the format.
- Brief your visualiser with the list. Send the relevant clauses with the commission, not after the first draft.
- Keep a methodology note. One page per set of views: base photography details, software, model source, verification approach and any AI use.
- Check the file requirements. Islington, for example, asks for a geolocated massing model in a named format. A late request for that can cost days.
Perspective
At Visual Trick, we see most validation delays start with a brief that never mentioned the local list. The images were fine. The labels, viewpoints or method notes were not what the council wanted.
Every image we produce is made in-house by one experienced operator, with no outsourcing. That means the person who reads your council’s requirements is the person who builds and labels the view. There is no hand-off where a viewpoint note gets lost, and you talk to one person about deadlines.
We build planning visuals to the purpose they serve: a fair, clearly titled view for a planning officer, a verified view where the setting demands it, and a separate, more atmospheric image for marketing. Keeping those apart protects the application and lets the marketing work do its job.
The Landscape Institute’s principle is the one we work to: show what would fairly be seen, and say how you produced it.
Paride
Working with Visual Trick on planning visuals
We produce planning visuals for developers, architects, planning consultants and designers: CGI photomontage, aerial CGI photomontage and verified views, alongside exterior and interior CGI for marketing. Send us the scheme, the site and your council’s validation list, and we will propose viewpoints and a labelling approach to match.
For a closer look at how images fit into an application, read our guides to CGI renders for planning applications and the role of visuals in planning permission. You can also see our page on CGI for planning applications or browse all architectural visualisation and rendering services. Pricing is project-based, so tell us what you need and we will quote for it.
FAQ
Do I have to label a CGI as “computer generated” in a planning application?
There is no single national wording. Local lists such as Windsor and Maidenhead’s refer to computer generated images by name, and most councils expect a clear title and a stated image type. Labelling it plainly as a CGI, photomontage or verified view is good practice and avoids confusion.
Can I put “Not to scale” on a planning visual?
On plans and drawings, often not. Oxford, Bath and North East Somerset and Central Bedfordshire all object to such disclaimers, and Central Bedfordshire treats them as invalid. Perspective images are generally the exception, but check your own council’s wording.
Do I need to say if AI was used?
For Planning Inspectorate casework in England and Wales, yes: you should state that AI was used, what for, how, what checks you made and who is responsible for accuracy. For a local application, ask your planning officer, and record any AI use in your methodology note either way.
Are the rules the same in Scotland, Wales and Northern Ireland?
No. Each nation has its own planning legislation, and the detail differs even though the structures are similar. Always read the validation guidance of the authority that will decide your application.
When do I need verified views rather than a standard CGI?
When the setting is sensitive or the building prominent. The Landscape Institute describes Type 4 verified views as the highest level of accuracy, with data that lets them be checked. Your council will usually confirm at pre-application which views and types it expects.
Sources
- Making an application, GOV.UK
- Use of artificial intelligence in casework evidence, GOV.UK
- National and Local Validation Requirements
- Comparison of the planning systems in the four UK countries
- Landscape Institute TGN 06/19, Visual Representation of Development Proposals
- Landscape Institute, Visual representation of development proposals (2017)
- Landscape Institute, Visualisation of development
- Tower Hamlets, CGI Visualisations
- Islington, Validation requirements update April 2024
- Bath and North East Somerset, Drawing standards
- Bristol, Standards for online planning applications
- Derby, Planning Drawing Guidance
- Oxford, Drawing Standards
- Central Bedfordshire, Validation Guide
- Dudley, Validation checklist for Planning Applications
- SEO for architects



