Reference

Heritage Impact Assessment: Scotland vs England Differences

Reviewed by

Oliver Wakefield-Smith

Founder, Digital Signet

Last reviewed 22 June 2026 · Refreshed quarterly

Direct answer

How does HIA differ in Scotland?

In Scotland, listed buildings are categorised A / B / C (rather than I / II* / II in England). Policy is set by Historic Environment Scotland (HES) rather than Historic England. The governing document is the HES Policy Statement (2019) plus National Planning Framework 4 (NPF4). NPPF does not apply. HEAN documents are not used; HES Managing Change in the Historic Environment guidance is the equivalent.

Key Scottish documents

HES Policy Statement 2019, the equivalent of NPPF heritage paragraphs.
NPF4 (adopted 2023), Scotland's National Planning Framework, with heritage policies in Part 2.
HES Managing Change in the Historic Environment series, equivalent to Historic England's GPA and HEAN documents.
Scottish Historic Environment Policy (SHEP), historic; superseded but still referenced.

Categories A / B / C

Category A, international or national importance. Equivalent to Grade I and Grade II* in England.
Category B, regional or local importance. Equivalent to Grade II.
Category C, local importance. No direct English equivalent.

Differences in fee market

The Scottish heritage-consultancy market is smaller. Day rates are typically 5 to 10% below London but comparable to South-West England. Edinburgh-based consultancies dominate; rural Scotland is served by a smaller pool of HES-experienced practitioners.