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Aipedia: Planning consultants
AI-generated or AI-altered images can be used in planning, but the Planning Inspectorate requires them to be declared and discourages AI cartoons or exaggerated illustrations. Images strongly influence decision makers, so a misleading visual can undermine a whole case.
Part of: AI in Planning consultants
In short
Planning consultants commission or produce visualisations to show how a proposal will look, and AI now makes it easy to generate scenes or alter photographs. Under the Planning Inspectorate guidance updated on 23 September 2026, generating or altering images or video with AI must be declared, saying which parts were affected. AI caricatures or exaggerated illustrations are discouraged, and the guidance warns AI can create fake images. Verified views built from survey data and a stated method carry more weight than AI imagery. Misleading visuals risk credibility, costs and client claims.
AI image tools can turn a sketch into a realistic street scene, add planting or people to a render, remove clutter from a photograph, or produce "before and after" images in minutes. Objectors may use the same tools to show a scheme at its most dominant. Consultants may use them for early massing studies, community consultation boards and design and access material.
The problem is accuracy. An AI image is not built from measured survey data or a known camera position, so scale, height and distance can be wrong without anyone noticing. A small alteration, such as softening a skyline or adding mature trees, can change how an inspector reads the impact. The AI in planning consultancy overview explains how imagery sits alongside other AI risks.
The Planning Inspectorate guidance on AI in casework evidence requires a declaration where AI has been used to generate or alter images or videos. The declaration should say which parts of the image were generated or altered, what checks were made, and confirm responsibility for accuracy.
The guidance warns that AI can create fake images and discourages AI cartoons or exaggerated illustrations of a proposal. It applies to appellants, applicants, local planning authorities and interested parties, so objectors' AI images are caught too. For wording, see the PINS AI declaration guide.
| Verified view or accurate photomontage | AI-generated or altered image | |
|---|---|---|
| Basis | Surveyed camera positions, measured model, stated method | Prompt or reference image; scale inferred |
| Reproducible | Yes, from the recorded method | Usually not |
| Declaration to PINS | Not needed if no AI generation or alteration | Required, identifying the affected parts |
| Best use | Evidence of visual impact | Early illustration, clearly labelled |
Where visual impact is a main issue, rely on accurate, reproducible visuals and keep AI imagery to clearly labelled illustration.
Illustrative scenario. For an appeal on a scheme in a conservation area, a consultant includes images in which an AI tool was used to add tree cover and tidy the foreground. The alteration is not declared. The council's heritage witness shows that the trees do not exist and the scheme appears lower than drawn. The inspector asks for clarification, gives the images little weight and the appeal fails. The council seeks costs, and the client questions whether the consultant's evidence cost them the appeal.
There are also intellectual property questions. AI images may reproduce protected material, and ownership of AI output is uncertain: the government's Report on Copyright and AI (18 March 2026) proposes removing protection for purely computer-generated works under CDPA s.9(3).
A client claim that misleading visuals lost an appeal is usually handled as professional negligence, subject to the wording. Points to check:
Apex arranges PI for planning consultants and a broker can review how your policy treats AI imagery, IP and appeal costs exposure. For document risks see AI in appeal statements and proofs.
Yes. The guidance requires a declaration where AI has been used to generate or alter images or videos, saying which parts were affected, what checks were made, and confirming responsibility for accuracy. Simple colour or exposure correction is less clearly in scope, but declaring is the safer course.
The guidance applies to interested parties as well, so AI images must be declared. AI cartoons or exaggerated illustrations of a proposal are discouraged, and fake images can undermine the party's credibility. Consultants acting for community groups should apply the same standards as for appellants.
It is uncertain. Ownership of purely computer-generated works under CDPA s.9(3) is under review, and the government report of 18 March 2026 proposes removing that protection. Tool licence terms also matter. Do not assume you or your client own exclusive rights in AI output.
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