How to Produce Your Infrastructure Funding Statement in Half the Time
Step-by-step process for compiling your annual IFS efficiently — what Schedule 2 requires, where to find the data, and how to stop starting from scratch each December.
Every December, planning teams across England face the same deadline: publish your annual Infrastructure Funding Statement by 31 December. For councils tracking S106 obligations in spreadsheets, this means days of manual data compilation, cross-referencing, and reformatting. Every year. From scratch.
This guide breaks down exactly what your IFS must contain, where to find each data point, and how to structure your monitoring data so the IFS becomes a report you generate — not a project you dread.
This covers England only. This is general guidance, not legal advice. Confirm reporting requirements with your legal team.
What the IFS Is and Why It Exists
The Infrastructure Funding Statement is an annual report that every local planning authority in England must publish under Regulation 121A of the Community Infrastructure Levy Regulations 2010 (inserted by the 2019 Amendment Regulations). The first IFS was due by 31 December 2020.
The IFS replaced the former Regulation 123 list and serves two purposes:
- Transparency — showing residents and developers how S106 and CIL money is collected, held, and spent
- Accountability — demonstrating that contributions fund the infrastructure they were intended for
The reporting period covers the previous financial year (1 April to 31 March). So the IFS published by 31 December 2026 covers the 2025/26 financial year.
What Schedule 2 Requires You to Report
Schedule 2 of the CIL Regulations sets out the minimum reporting requirements. Here's what you actually need to produce, split into the three required sections:
Section 1: Infrastructure List
A statement of infrastructure projects or types that the authority intends to fund (wholly or partly) through CIL and/or S106. This is the strategic forward look — what you plan to spend developer contributions on.
You need:
- Named infrastructure projects or categories (education, highways, open space, affordable housing)
- Whether funded by CIL, S106, or both
- Approximate amounts allocated or anticipated
Section 2: CIL Report
If your council charges CIL, this section covers the financial year:
- Total CIL receipts
- Total CIL expenditure (with project breakdown)
- CIL retained and unspent
- Administrative expenses (up to 5% of CIL receipts)
- Amount passed to parish/town councils (neighbourhood portion)
- Amount of CIL applied to repay borrowing
Section 3: S106 Report
This is where most councils struggle. The S106 report must include:
- Total money received through planning obligations during the reporting year
- Total money spent during the reporting year, broken down by infrastructure type
- Total money retained (received but not yet spent) — including amounts received in previous years still held
- Non-monetary contributions agreed and delivered — affordable housing units, highway works, open space, community facilities
- S106 obligations entered into during the reporting year (number and summary of terms)
The non-monetary contributions section is consistently the hardest to compile. Affordable housing delivery data sits with the housing team. Highway works completion data sits with the highways authority. Open space delivery data sits with parks and leisure. None of these teams are thinking about your IFS in November.
The Five-Step IFS Compilation Process
Step 1: Confirm Your Data Sources (October)
Before you start compiling, map out where each data point lives:
| Data Point | Typical Source | Owner |
|---|---|---|
| S106 agreements signed | Legal/planning records | Planning team |
| Financial contributions due | S106 monitoring records | Planning obligations officer |
| Financial contributions received | Finance system (cash receipts) | Finance team |
| Contributions allocated to projects | Project/capital records | Service area leads |
| Contributions spent | Finance system (payments) | Finance team |
| Affordable housing delivered | Housing completions data | Housing team |
| Highway works completed | Highways adoption records | Highways authority |
| Open space/community facilities | Parks/leisure completion records | Relevant service area |
| CIL receipts and spend | CIL monitoring records | CIL officer (if separate) |
Start contacting service area leads in October. Give them a specific data request with a deadline of mid-November. Do not wait until December to ask.
Step 2: Reconcile Financial Data (November)
The most common IFS error is a mismatch between what planning records show was received and what finance records show was banked. These diverge because:
- Contributions arrive as a lump sum covering multiple obligations — finance records the payment, planning needs to split it across obligations
- Indexation adjustments mean the recorded "amount due" differs from the "amount received"
- Some councils hold S106 money in a single holding account, making it hard to match receipts to specific agreements
Reconciliation means matching every S106 receipt in the finance system to a specific obligation in your monitoring records. If you can't match them all, note the discrepancy and resolve it — don't fudge the numbers.
Step 3: Compile Non-Monetary Contributions (November)
For each S106 agreement with in-kind obligations, you need to report whether the obligation has been:
- Agreed — in a signed S106 agreement
- Commenced — work started or units under construction
- Delivered — completed and accepted/adopted
This requires direct confirmation from service areas. Send a structured template — not a free-text email request. A simple table works:
| Agreement Ref | Obligation | Status | Completion Date | Evidence |
|---|---|---|---|---|
| PA/2021/0456 | 12 affordable housing units | Delivered | 2025-09-15 | Housing completions certificate |
| PA/2022/0789 | Junction improvement, High Street | Commenced | In progress | Highways update 2025-11-01 |
Step 4: Draft and Cross-Check (Late November)
Assemble the three sections. Cross-check:
- Do total receipts match between your S106 records and the finance system?
- Does the "retained" figure equal previous retained + this year's receipts − this year's spend?
- Are all agreements signed in the reporting year listed?
- Have you accounted for contributions returned to developers (clawbacks)?
- Does the CIL section reconcile with CIL billing records?
The PAS IFS guidance includes a checklist of required information — use it as a final verification pass.
Step 5: Publish and Archive (December)
Publish on your council's website by 31 December. The regulations require publication on the authority's website — no specific format is mandated. Most councils publish a PDF document, but some publish the data alongside an interactive dashboard.
After publication:
- Archive the source data that produced the IFS — you may need it for audit queries or developer disputes
- Note any data gaps or reconciliation issues to resolve before the next cycle
- Update your monitoring process to close the gaps that made this year's compilation difficult
What Makes This Take So Long — and How to Fix It
The councils that spend 3–5 days on their IFS share common patterns:
Problem: Unstructured monitoring data. Obligations recorded as free text rather than structured fields. Fix: standardise your S106 register so every obligation has a type, a financial value, a trigger, and a status — discrete fields, not paragraph descriptions.
Problem: No receipt-to-obligation matching. Money arrives but nobody records which obligation it satisfies. Fix: when finance confirms a receipt, immediately match it to the specific obligation and record the receipt date. This is also critical for spend-by deadline tracking.
Problem: Late service area data requests. Asking the housing team for delivery data on 15 December gets you a hurried, incomplete response. Fix: send a structured template in October with a mid-November deadline. Follow up.
Problem: Year-on-year reinvention. Each year's IFS is compiled from scratch rather than rolling forward the previous year's data. Fix: maintain a persistent monitoring dataset that rolls forward. Next year's IFS should start with this year's "retained" figure and add new activity.
IFS Data That Doubles as Monitoring Intelligence
The IFS isn't just a compliance exercise. The data you compile for it answers questions your planning committee and senior leadership should be asking:
- How much S106 money is sitting unspent? If the answer is growing year on year, you have a spend-rate problem — and spend-by deadlines are approaching.
- Which obligation types are consistently under-delivered? If highway works are routinely "commenced" but never "delivered," there may be an enforcement issue.
- What's the average time from receipt to spend? If it's more than 3 years, contributions are at risk of clawback.
If your IFS data is well-structured, these questions become queries you can answer in minutes rather than investigations that take days.
For a complete overview of the monitoring process that feeds into your IFS, see our guide to S106 monitoring for planning officers.
Need a starting point right now? Try the free IFS Template Generator — enter your council's data and download a structured template in PDF format.
S106Ledger is building automated IFS generation from live monitoring data — your annual report compiled in minutes, not days. Join the waitlist for early access.
Sources
- Community Infrastructure Levy Regulations 2010 (including Schedule 2)
- Community Infrastructure Levy (Amendment) (England) (No. 2) Regulations 2019 — inserted Regulation 121A (IFS requirement)
- PAS — Infrastructure Funding Statements Guidance and Sample Template
- GOV.UK — Publish Your Developer Contributions Data
Track S106 Obligations Without the Spreadsheet Chaos
S106Ledger gives planning teams deadline alerts, financial tracking, and one-click IFS reporting. Join the waitlist for early access.
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