How to Read an Infrastructure Funding Statement
Every Local Planning Authority in England must publish an Infrastructure Funding Statement by 31 December each year. The document reports how much developer money the council collected, spent, and is sitting on. It should be the single most useful transparency document in local planning — but most are dense PDFs that take real effort to decipher. This guide walks you through what to look for.
What is an Infrastructure Funding Statement?
The IFS requirement was introduced by amendments to the Community Infrastructure Levy Regulations 2010, specifically Regulation 121A. It replaced the old Regulation 123 list and took effect from 31 December 2020. The aim was straightforward: force councils to account publicly for the developer money they handle.
Every council that has received Section 106 contributions or CIL payments must publish one. There are no exemptions. In practice, a handful of councils miss the deadline or publish late, but the legal requirement is absolute.
The structure of a typical IFS
The regulations prescribe specific matters that must be reported. Most councils follow a similar structure, though the formatting varies wildly from slick designed PDFs to bare-bones Word documents.
A typical IFS has three main sections:
1. Section 106 (planning obligations)
This section must report the total money received, the total spent, and the total held at the end of the reporting period. It should also list individual agreements entered into during the year, including the development site, the obligations secured, and the amounts. Some councils go further and break down spending by category — affordable housing, education, transport, and so on. Others give only the headline totals.
2. CIL (if the council charges it)
If the council has adopted the Community Infrastructure Levy, this section reports CIL receipts, expenditure, and balances. It must state how much CIL has been passed to parish councils or neighbourhood areas (15% or 25%, depending on whether a neighbourhood plan is in place). It must also report any CIL spent on administrative expenses, which is capped at 5% of receipts.
3. Infrastructure list
The council must list the infrastructure projects it intends to fund, wholly or partly, from developer contributions. This replaced the old Regulation 123 list. The list gives you an idea of what the council plans to spend money on, though it creates no obligation to actually deliver those projects.
What to look for
The “held” balance
The most revealing number is the total held or unspent. A large balance is not automatically a problem — some money is committed to multi-year projects, and some has only just been received. But if the held balance has been growing year on year while the spending stays flat, that warrants scrutiny. Developer contributions have time limits (typically 5 to 10 years), and money returned to developers because the council failed to spend it is money the community lost.
Money returned to developers
Some IFS documents report the amount returned or “clawed back” by developers. This happens when the council fails to spend the money within the agreed time limit. Any non-zero figure here deserves attention. It means the community was entitled to infrastructure that was never delivered.
Spending categories
Where the IFS breaks down spending by category, compare it with what was secured. If a council collects a lot for education but spends mostly on highways, it might indicate that contributions are being redirected — which may or may not be within the terms of the original S106 agreements.
CIL admin expenses
Councils can retain up to 5% of CIL receipts for administrative expenses. Check whether the council is taking the full 5%. On large CIL receipts, this can be a substantial sum that might otherwise go to infrastructure.
Common terminology
| Term | Meaning |
|---|---|
| Secured | An obligation has been agreed but no money has changed hands yet |
| Received | The council has received payment from the developer |
| Allocated / Committed | The money has been earmarked for a specific project but not yet spent |
| Spent / Expended | The money has been paid out to deliver infrastructure |
| Held / Unspent balance | Money received but not yet spent — the running balance |
| Commuted sum | A cash payment instead of on-site delivery (common for affordable housing) |
| Clawback / Returned | Money returned to the developer because the council didn't spend it in time |
Or just use s106 Tracker
We extract the key numbers from every council's IFS so you don't have to read 30-page PDFs yourself. Search for your council to see the data in a clear, comparable format.
Frequently Asked Questions
Where can I find my council's IFS?
Most councils publish it on their planning policy or developer contributions page. Search for “[council name] infrastructure funding statement”. If you can't find it, the council may have missed the deadline — you can request it under the Freedom of Information Act 2000.
What financial year does the IFS cover?
The IFS must be published by 31 December and covers the previous financial year (1 April to 31 March). So the IFS published by December 2024 covers the 2023/24 financial year. Some councils publish a few months late.
My council's IFS doesn't break down spending by category. Is that allowed?
The regulations require councils to report totals but don't mandate a category breakdown for Section 106. Many councils provide one voluntarily, but some report only headline figures. For CIL, the infrastructure list must be published, but detailed spending categories are not strictly required either.