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Residents can verify a development’s promised local jobs and spending by checking the legally binding planning records and payment accounts—not the developer’s brochure. Start with the council’s planning register, retrieve the planning permission and Section 106 agreement (or unilateral undertaking), then follow each employment, skills and procurement commitment through its monitoring evidence, payment ledger and final discharge.
This guide is written for developments in England, where the cited government guidance applies. Local rules differ, so treat the targets in Barking and Dagenham and Westminster as examples of how obligations can be written, not as national standards.
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What records should I find first?
Search the local planning authority’s online planning register by the site address, application number or developer. Download the complete decision notice and every document that affects the promise, including:
- the planning permission and approved plans;
- the signed Section 106 agreement or unilateral undertaking;
- later deeds that modify the obligation;
- notices confirming an obligation has been discharged, varied or replaced;
- employment, skills, procurement or local-economy plans submitted under the agreement;
- committee reports, viability documents and officer reports that explain the intended benefits; and
- the authority’s infrastructure funding statement (IFS) for financial contributions.
Government planning practice guidance says a local planning authority must keep the planning obligation, details of modifications and discharge, and make them available on its planning register. The same guidance says an authority that has received developer contributions must publish an IFS at least annually. See the UK Government guidance on planning obligations for the legal and publication framework.
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Save the documents with their publication dates. A later deed or discharge notice may change the wording that appeared in the original permission. If a register entry is incomplete, ask the planning or Section 106 monitoring team for the missing deed and the current schedule of obligations.
How do I tell a binding promise from marketing language?
A promise is enforceable only when it appears in the permission, a planning obligation, a condition, or another document that the obligation expressly incorporates. A brochure, consultation display or press release can show what was advertised, but it does not by itself prove that the council can require delivery.
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Read the operative clause rather than the headline. Look for:
- the obligated party: which landowner or developer signed it;
- the action: for example, notify vacancies, provide apprenticeships, pay a contribution or deliver a facility;
- the definition: what counts as a job, apprentice, local business or eligible spend;
- the geography: a named borough, ward, travel-to-work area or another boundary;
- the phase: demolition, construction, fit-out, occupation or a later phase;
- the trigger and deadline: such as commencement, each quarter, first occupation or a specified date;
- the evidence and reporting duty: what must be submitted and to whom; and
- the remedy: enforcement, a financial payment, an alternative contribution or another consequence for non-delivery.
Keep a copy of any voluntary commitment separately. It may be useful for a question to the developer or councillor, but do not describe it as a legal requirement unless the planning documents support that description.
What should a resident’s claim ledger contain?
Create one row for every distinct promise. This prevents a broad phrase such as “hundreds of local jobs” from being counted as if it were a single, measurable obligation.
| Ledger field | What to record |
|---|---|
| Public claim | The exact wording from the brochure, consultation or public statement, with its date and page. |
| Legal clause or policy | Agreement paragraph, schedule, condition or incorporated plan. |
| Status | Binding obligation, planning condition, voluntary commitment or unclear. |
| Target definition | New jobs, total FTE workforce, resident share, apprenticeships, work placements, procurement value or another measure. |
| Geography | The agreement’s definition of “local” and any priority groups. |
| Phase | Construction, fit-out, occupation, or a named phase. |
| Trigger and deadline | Commencement, monthly or quarterly reporting, first occupation, completion or another event. |
| Evidence required | Returns, payroll summaries, referral records, invoices, contracts, payment confirmations or certificates. |
| Shortfall consequence | Enforcement, an alternative contribution, a missed-commitment payment, renegotiation or no stated remedy. |
| Current status | Not due, reported, disputed, partly delivered, discharged or outstanding, with the source and date. |
Record the measurement period as well as the total. A quarterly target cannot be validated by a single cumulative number unless the agreement allows cumulative reporting. Keep construction and occupation commitments on different lines: a construction workforce figure does not answer whether permanent jobs were created after opening.
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How can I verify “local jobs”?
First define the job being counted. “Local jobs” may mean new roles filled by residents, the percentage of the whole workforce who live locally, construction jobs, permanent jobs after occupation, apprenticeships, graduate starts or short work placements. Those measures are not interchangeable.
Check the clause for the following questions:
- Is the target a number, a percentage, an FTE equivalent or a number of starts?
- Does “local” mean the authority area, a list of wards, a radius or another stated geography?
- Are subcontractors included, and are self-employed workers counted?
- Are apprenticeships measured by starts, completions or months on programme?
- What dates define the reporting period, and can the same person be counted in more than one category?
A credible evidence pack normally includes vacancy notifications, referrals from the council’s brokerage service, workforce or payroll summaries showing resident status, apprenticeship starts and completions, skills forecasts, training attendance records and the developer’s monitoring returns. Ask for aggregated or redacted data where personal information is protected; you need the defined totals and verification method, not individual names.
Local policy shows how precise these requirements can be. Barking and Dagenham’s Planning Obligations SPD requires vacancies to be sent through the council’s job-brokerage service, monthly monitoring after commencement and confirmation that obligations were met—or an agreed alternative contribution—before discharge. That is a local rule, so check whether the development’s own agreement adopts it or uses different terms.
Westminster’s 2026 draft Inclusive Local Economy and Employment Guidance Note illustrates quarterly employment-and-skills returns containing qualitative and quantitative information, vacancy notification and escalation after two consecutive missed quarters. Because it is draft guidance, it should be treated as an example of reporting design, not evidence that every development must follow it.
How do I check whether a jobs target was actually met?
- Extract the baseline. Establish whether the target applies from commencement, a baseline workforce, each phase or a fixed reporting year.
- Check the denominator. For a percentage, confirm whether it is resident FTEs divided by total FTEs, local hires divided by all hires, or another formula.
- Match evidence to the period. Compare monthly or quarterly returns with the clause’s reporting calendar.
- Look for independent identifiers. Brokerage referrals, anonymised postcode or ward totals, apprenticeship-provider records and payroll summaries are stronger than an undated narrative.
- Separate starts from completions. An apprenticeship start does not establish completion, and a vacancy notification does not establish a hire.
- Check discharge. Find the notice or officer confirmation stating that the obligation was satisfied, varied or replaced. A discharge can cover one clause while other obligations remain open.
If the evidence shows a shortfall, ask what the agreement says happens next. Some agreements permit an alternative contribution; others provide for enforcement or a specified payment. Do not apply a local formula from another borough unless the development’s own documents adopt it.
How can I verify local spending and contributions?
Start by identifying the permitted purpose, amount, trigger and recipient in the agreement. Then compare those terms with the authority’s latest IFS. Government guidance says authorities should report when contributions are received and spent or transferred, allocated expenditure, future spending priorities and intended infrastructure projects. The planning-obligations guidance explains these publication duties.
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Build a second ledger with, at minimum:
- amount promised and the clause that creates it;
- amount due and the trigger date;
- amount received and receipt date;
- amount allocated, spent and transferred;
- recipient department or external body;
- project or infrastructure category;
- date of expenditure or transfer;
- unspent balance and any stated future priority; and
- whether the obligation was cash, land, works, a facility or a mixture.
Keep cash contributions separate from direct provision. A developer-built nursery, junction or public space may satisfy an obligation without appearing as a cash receipt in the IFS. Conversely, an IFS entry can show money received without proving that the promised project has been completed. Ask for the completion certificate, handover record or project account where the obligation concerns works or a facility.
Check indexation, interest, administration deductions and repayment clauses. These details can explain why the amount paid differs from the headline figure. If the agreement allows a contribution to be pooled or transferred, follow the IFS narrative to the receiving project rather than assuming the money was spent at the development site.
How do I investigate promises to use local businesses?
Request the procurement plan and compare it with the agreement’s definition of local procurement. Useful records include work packages, tender timetable, bidders, awards, supplier locations, contract values and evidence of payment. Ask whether the target concerns the value of contracts, the number of suppliers, the value of goods purchased, or opportunities advertised to local firms.
Barking and Dagenham’s SPD requires a procurement plan, tender and award information, genuine opportunities for local businesses and monitoring evidence. Use that document as a model for the records to seek, not as a universal rule.
A supplier’s registered address alone may not prove that work or value was delivered locally. Compare the legal entity, the actual work package, site location, subcontracting chain, invoices and payment trail. A national contractor with a local registered office may not meet a clause requiring local businesses to perform work; a locally based specialist may deliver value through a subcontract even if the prime contractor is based elsewhere.
What should I do when the records do not reconcile?
Send the planning or Section 106 monitoring officer a short, numbered request tied to the development, clause and reporting period. Ask:
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- Which clause is being measured, and what definition and formula were used?
- What evidence was accepted for the reported jobs, apprenticeships or procurement value?
- What amount was due, received, allocated, spent or transferred, and on what dates?
- What remains outstanding, including any unspent balance or missed report?
- What discharge, alternative contribution, penalty or enforcement action applies?
If the response is incomplete, make a focused information request for the monitoring return, evidence schedule, payment ledger or discharge decision. Name the development, clause, phase and reporting period. Narrow requests are easier to answer and reduce the risk that a broad request is treated as unclear or excessively burdensome.
Protect personal data by asking for totals, methodology and redacted records. Keep a chronology of requests, responses and document versions. If a statutory register entry is missing, ask the planning authority to correct or complete it; if the issue concerns spending, direct the question to the authority’s Section 106, finance or infrastructure-funding team as well as the case officer.
Which comparisons are fair when developments make different claims?
Compare like with like. The most useful axes are:
- binding obligation versus marketing claim;
- construction phase versus occupation phase;
- total jobs versus resident share;
- jobs versus apprenticeships or work placements;
- cash contribution versus direct provision of works or facilities;
- amount promised versus amount received;
- amount received versus amount spent; and
- monitoring evidence versus final discharge.
A larger headline number may represent total FTE workforce, while a smaller number may represent new resident hires. Label the unit, geography and period in every comparison. Never rank developments by combining unlike measures into one score.
What local target figures can—and cannot—tell me?
The available data contains no cross-development statistic showing how many promised jobs or pounds were delivered. The available figures are examples of local policy:
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- The same SPD uses at least 25% of construction spending with Barking and Dagenham businesses.
- Its alternative-contribution formula uses £5,000 per target resident job.
- Westminster’s 2026 draft guidance uses one job, apprenticeship or graduate start per £3 million of project spend and a £6,000 missed-commitment payment.
These numbers are not national benchmarks and should not be used to declare another development compliant. The controlling figures are those in that development’s signed agreement and approved plans.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What is the quickest reliable verification workflow?
- Identify the authority and application. Save the register URL, application number and decision date.
- Collect the legal documents. Download the agreement, plans, modifications, discharge notices and incorporated employment or procurement plans.
- Transcribe each promise. Put the clause, definition, geography, phase, trigger and remedy in the claim ledger.
- Request monitoring evidence. Ask for returns and evidence schedules for the exact reporting periods.
- Reconcile spending. Compare the agreement with the IFS and any project or handover records.
- Check the end state. Confirm whether each clause is discharged, still open, varied, replaced or in default.
- Publish cautiously. State what the records prove, what remains unverified and which definition controls the result.
This workflow produces an auditable answer rather than a repeat of promotional language. It also makes a disagreement precise: the issue may be a missing report, a different definition of “local,” an unpaid trigger, or spending that has been received but not yet allocated.
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What are the most common verification mistakes?
- Counting a promise as delivery: an announced target is not evidence of performance.
- Using the wrong geography: a borough-wide result may not satisfy a ward-specific clause.
- Mixing phases: construction jobs cannot be presented as permanent occupation jobs.
- Confusing notifications with outcomes: a vacancy sent to a brokerage is not a confirmed hire.
- Equating receipt with expenditure: money received may remain unspent or be transferred later.
- Treating a local example as a universal rule: policy targets vary by authority and agreement.
- Ignoring modifications: a later deed may lawfully change the amount, trigger or remedy.
- Overlooking discharge limits: one discharged obligation does not automatically close every commitment.
What should a defensible resident report say?
State the development, application number, document versions and reporting period. Quote the operative clause, define the measure, identify the evidence reviewed and show the arithmetic. Distinguish “the authority reports,” “the agreement requires” and “the available records do not establish.” If a figure is provisional, say why: for example, the latest quarterly return is available but the final discharge has not been issued.
Link readers to the planning register and the relevant government or council document. Avoid publishing personal data from payroll or referral records. A careful report can still identify a shortfall without asserting misconduct: the records may simply be late, incomplete, disputed or subject to a permitted alternative contribution.
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Can I see a developer’s Section 106 agreement online?
Usually, the local planning authority’s register should contain the planning obligation and details of later modification or discharge. If the document is absent or unreadable, request it from the planning or Section 106 monitoring team by application number and site address.
Does a Section 106 payment have to be spent on the same site?
Not necessarily. The agreement may permit pooled or transferred contributions for a defined infrastructure purpose. Check the payment clause and the authority’s infrastructure funding statement for the receiving project, transfer date and remaining balance.
Can I challenge a local-jobs figure that uses percentages?
Yes—ask for the denominator, FTE method, reporting period and definition of “local.” A percentage of the total workforce is different from a percentage of new hires, and the agreement controls which calculation is valid.
What if the council says the monitoring information is confidential?
Ask for aggregated totals, methodology, redacted returns and the clause relied on for withholding details. Personal information may need protection, but confidentiality does not automatically prevent publication of non-personal compliance and spending information.
