Summary
If your premises falls within a Cumulative Impact Zone (CIZ) — also called a Special Policy Area — your licence application faces a presumption against being granted. That means the council starts from a position of no, and it is your job to convince them otherwise.
CIZs now cover significant portions of central London, most major UK city centres, and a growing number of town centres nationwide. Understanding how they work, and how to make the exceptional circumstances case, is the difference between a licence granted and an application refused before it reaches a hearing.
What Is a Cumulative Impact Zone?
A Cumulative Impact Zone is a geographic area designated in a council's Statement of Licensing Policy (SLP) where the licensing authority has concluded that the cumulative impact of existing premises already poses a risk to the licensing objectives.
Once a CIZ is in place, the council adopts a rebuttable presumption that new applications, or applications to vary existing licences to extend hours or expand activities, will be refused. This is sometimes called a "special policy area" or a "saturation policy."
The presumption does not mean automatic refusal. It means the burden shifts. Normally, applicants who promote the licensing objectives are presumed to deserve a licence. In a CIZ, applicants must demonstrate that granting their application will not add to the cumulative impact, which is a considerably higher bar.
The Exceptional Circumstances Case
The presumption in a CIZ is rebuttable. Barnab can, and regularly does, succeed by demonstrating exceptional circumstances: evidence that granting the application will not add to the existing cumulative impact and will not undermine the licensing objectives.
What counts as exceptional circumstances?
1. The Nature and Character of the Venue
A venue that is genuinely different in character from the premises that created the cumulative impact problem may not contribute to it. A members-only private dining club, a culture venue, a cinema, or a hotel bar that exclusively serves residents presents a fundamentally different risk profile from a late-night bar or nightclub.
The question the council must ask is: does this specific type of premises add to the cumulative impact concerns that justified the zone? If the answer is no, the policy may not apply.
2. Trading Hours
Applications restricted to hours well within the problem hours, say 11pm, may be able to demonstrate that the venue will not operate during the periods that cause cumulative impact concerns. The later the hours sought, the harder this argument becomes.
3. Robust Management and Conditions
A comprehensive, credible management plan covering door staff, Challenge 25 policies, dispersal procedures, CCTV, noise management, and engagement with local Business Improvement Districts or Pubwatch schemes demonstrates that the applicant takes their obligations seriously. Some councils will negotiate agreed conditions in advance with the police, which can significantly reduce the risk of objections.
4. No Net Increase in Impact
If the premises previously operated as a licensed venue of equivalent character and scale, an applicant can argue that granting a new licence represents no net addition to cumulative impact. The number and type of licensed premises in the area does not change.
5. Community Support
Evidence of support from local residents, businesses, or community organisations, particularly from those who live or work closest to the proposed premises, carries weight. It does not override the policy, but it forms part of the overall picture the licensing committee considers.
What Happens at a Hearing in a CIZ?
Because responsible authorities routinely object to applications in CIZs on policy grounds, many applications in these areas proceed to a licensing committee hearing rather than being granted automatically.
If you are unsure what happens at a hearing, take a look at this short write-up of What to Expect at a Licensing Hearing (And How to Win It) prepared by Team Barnab.
Importantly, CIZ policy does not create an absolute presumption of refusal and that each application must be considered on its individual merits. Committees that mechanically refuse all applications in a CIZ without considering exceptional circumstances are not correct.
At the hearing, the licensing committee must:
Consider the evidence and representations from the applicant and any responsible authorities or interested parties who have made representations.
Apply the rebuttable presumption. The committee starts from the position that the policy points toward refusal.
Decide whether the exceptional circumstances case is made out. If it is, the committee may grant the application, with or without additional conditions.
Act proportionately. The committee cannot simply refuse because a CIZ policy exists. It must consider the specific circumstances of the application. Blanket refusal without individual consideration is unlawful.
Practical Guidance for Businesses: Applying in a CIZ
Before you apply:
Read the council's current Statement of Licensing Policy in full. Understand which licensing objectives are cited as the basis for the CIZ and why. Westminster's policy and Leeds's policy are good examples of how detailed these documents can be.
Look at what types of venues the council has approved within the CIZ. This tells you what exceptional circumstances arguments the committee finds persuasive.
Check recent appeal decisions. If the council has been overturned on appeal, understand why.
Make early contact with the responsible authorities, particularly the police licensing team. Find out their concerns and whether they would agree conditions in advance of the application.
When you apply:
Write a detailed operating schedule that directly addresses the concerns underlying the CIZ. If the policy cites late-night crime and disorder, explain specifically how your venue's operating model mitigates those risks.
Prepare a management plan that goes beyond the minimum. The more detailed and credible your approach, the harder it is for responsible authorities to maintain objections.
Gather evidence of support where you can.
Engage a licensing consultant or solicitor who understands the local policy and the authorities. In a CIZ application, professional representation is not a luxury.
At the hearing:
Address the presumption directly. Acknowledge the policy and explain, specifically, why your application falls outside its intended scope or why exceptional circumstances apply.
Use evidence, not assertions. Statements about what you intend to do are less persuasive than documented operating models, comparable venues, and agreed conditions.
How Barnab Helps With CIZ Applications
Barnab works with premises operators across England on complex licensing applications, including applications in cumulative impact zones. We understand how councils apply their policies, what exceptional circumstances arguments are accepted in which areas, and how to structure an application and management plan that gives you the best possible chance of success.
We offer:
Pre-application assessment: we review the local SLP, recent decisions, and the responsible authorities' known positions before you commit to an application.
Operating schedule and management plan drafting: tailored to your venue type and the specific concerns underlying the CIZ.
Responsible authority engagement: early dialogue with police and environmental health to understand objection risk and identify agreed conditions.
Hearing representation: if your application proceeds to committee, we present your exceptional circumstances case.
Useful Resources
Legislation and Government Guidance:
Section 5A Licensing Act 2003: Cumulative Impact Assessments
Section 141 Policing and Crime Act 2017 (introduced CIAs into statute)
Example of Council CIZ Policies:
Bristol City Council: Licensing Policy (including CIA, updated 2025)
Leeds City Council: Licensing Policies (including cumulative impact maps)
House of Commons Library: Cumulative Impact Assessments explained
Barnab:
This article provides general information about cumulative impact zones and premises licensing policy. It is not legal advice. Licensing policy varies significantly between local authorities and is subject to change. Always verify the current Statement of Licensing Policy with your local council before submitting an application. Last updated: February 2026.
