How Much Land for Townhouses: Council Requirements

What Determines Townhouse Land Requirements in Victoria?

One of the most common questions property developers ask before committing to a site is deceptively simple: how much land do I actually need to build townhouses? The honest answer is that there is no single figure that applies across every council, every zone, or every site configuration. What there is, however, is a clear set of planning controls, ResCode standards, and council-specific requirements that — when understood correctly — allow you to assess a site’s development potential with confidence before you spend a dollar on due diligence.

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For developers targeting Melbourne’s Eastern Suburbs — including the City of Whitehorse, City of Boroondara, Manningham City Council, City of Monash, Knox City Council, and Maroondah City Council — the regulatory landscape has shifted considerably since 2018, and again in 2025 and 2026. The introduction of the Townhouse and Low-Rise Code (Amendment VC267, gazetted 6 March 2025), updated ResCode standards, and the Planning Amendment (Better Decisions Made Faster) Act 2026 have all changed how townhouse applications are assessed, how quickly decisions may be made, and what design standards must be met to unlock a streamlined approval pathway.

This article outlines the land size thresholds, planning controls, and council requirements that are most relevant to townhouse development in Melbourne’s Eastern Suburbs as of mid-2026. Whether you are evaluating a 500m² infill site or a 1,200m² corner block, understanding these fundamentals may help you avoid costly mistakes and identify sites with genuine development potential.

Understanding the Regulatory Framework in 2025–26

Before looking at raw land size figures, it is worth understanding the planning framework that governs townhouse development in Victoria. Townhouses — defined broadly as two or more dwellings on a lot up to three storeys — are assessed under Clause 55 of the relevant planning scheme. A planning permit is always required for these developments in residential zones. For a broader introduction to this process, see A Beginner’s Guide To Townhouse Development In Victoria.

The most significant recent change is the introduction of the Townhouse and Low-Rise Code, which came into operation on 31 March 2025 following Amendment VC267. This code introduced a deemed to comply assessment pathway: if a development meets all applicable Clause 55 standards, the responsible authority must treat the corresponding objectives as satisfied and cannot refuse the application on those grounds. Critically, where all applicable standards are met, there is no third-party right of VCAT appeal — a significant advantage for developers seeking certainty.

Layered on top of this is the Planning Amendment (Better Decisions Made Faster) Act 2026, described as the biggest shake-up to Victoria’s planning system in decades. This legislation introduces a tiered permit assessment system. Townhouse and low-rise apartment applications are expected to fall within the Type 2 category, which carries a 30-day approval timeframe. This is a material improvement for developers who have historically faced protracted assessment periods across Eastern Suburbs councils. For a comprehensive overview of the 2026 planning environment, see our Townhouse Development Victoria: Complete 2026 Guide to Planning, Approval and Construction.

The Garden Area Requirement: The Single Biggest Constraint on Yield

If there is one planning control that most directly determines how many townhouses a site can accommodate, it is the Minimum Garden Area (MGA) requirement under ResCode. This is not simply a landscaping requirement — it is a statutory constraint that, if not met, results in a mandatory refusal.

The current thresholds are:

• Lots under 400m²: No minimum garden area requirement applies under ResCode (though council overlays may impose additional requirements)
• Lots 400m² to 650m²: 25% of the site must be set aside as garden area
• Lots over 650m²: 35% of the site must be set aside as garden area

It is essential to understand what “garden area” means in this context. It is not simply soft landscaping or permeable paving. Garden area must be uncovered, open, and unencumbered by buildings, driveways, decks, or services. On a 700m² site, 35% equates to 245m² of land that cannot be built upon, driven over, or covered by a deck. For developers accustomed to older planning rules, this figure may be surprising — and it is the primary reason why sites that once supported four townhouses may now only viably accommodate three.

The garden area requirement can directly reduce yield on projects where initial feasibility assumed an extra dwelling — a pattern SQM Architects has observed across projects in Melbourne’s Eastern Suburbs. Accurate MGA calculation at the site assessment stage is typically one of the most important inputs into a property development feasibility assessment.

Tree Canopy Requirements: A Growing Constraint on Larger Sites

For sites over 1,000m², the updated ResCode introduces an additional layer of complexity: tree canopy coverage requirements. Specifically, developments on lots exceeding 1,000m² may need to demonstrate that planted trees will provide a 20% canopy cover over the site at maturity. On a 1,001m² lot, that equates to approximately 200m² of projected canopy coverage.

This has practical implications for site layout, driveway placement, stormwater design, and — most importantly — dwelling yield. Trees take time to mature, and responsible authorities will typically require canopy projections based on species selection and growth modelling, not just a planting schedule. On townhouse sites in the City of Whitehorse or Manningham City Council, where established tree canopy is already a neighbourhood character consideration, this requirement can meaningfully constrain what is achievable on a larger block.

Developers should factor tree canopy requirements into feasibility assessments for any site over 800m², even if the formal threshold is 1,000m², as council-specific overlays — particularly Vegetation Protection Overlays and Significant Landscape Overlays — may impose additional canopy requirements below the ResCode threshold.

Indicative Land Size Requirements by Dwelling Count

With the above controls in mind, the following figures provide indicative land size guidance for townhouse development in Melbourne’s Eastern Suburbs. These are not guaranteed thresholds — every site must be individually assessed — but they reflect typical outcomes across the General Residential Zone and Neighbourhood Residential Zone in this region.

Two Townhouses (Dual Occupancy)

A minimum site area of 400m² to 500m² is typically required for two townhouses, with a frontage of at least 12 to 15 metres. Corner sites may allow narrower frontages due to the availability of secondary street access. At this scale, the 25% MGA applies to sites over 400m², meaning approximately 100m² to 125m² of the site must remain as unencumbered garden area. The VicSmart process — updated in October 2024 — may apply to straightforward two-dwelling proposals, potentially enabling faster assessment.

Three Townhouses

For three townhouses, a site of 600m² to 750m² is generally required, with a frontage of at least 15 to 18 metres. At this scale, the 35% MGA threshold (for sites over 650m²) becomes the dominant constraint. On a 700m² site, the developer must set aside 245m² as garden area, leaving 455m² for buildings, driveways, and private open space. Secluded Private Open Space (SPOS) of 25m² per dwelling — a standard introduced under the updated ResCode — must also be provided, adding a further 75m² of dedicated open space across the three dwellings.

Four Townhouses

Four townhouses typically require a site of 800m² to 1,000m², with a frontage of at least 18 metres. Corner sites may allow slightly smaller land areas due to improved access configuration. At this scale, the 35% MGA applies across the full site, and tree canopy requirements may begin to influence layout on sites approaching 1,000m². Shared driveway design, waste management access, and visitor parking requirements also become more complex at four dwellings — and building setbacks across all boundaries should be modelled into feasibility at the site selection stage.

Five or More Townhouses

For five or more townhouses, sites of 1,000m² or more are generally required, and the interaction between MGA, tree canopy, SPOS, setbacks, and car parking can significantly constrain yield relative to raw land area. At this scale, engaging an architect and town planner at the site assessment stage — before exchange of contracts — is generally recommended to avoid costly surprises. For a broader overview of what makes townhouse projects succeed, see 8 Key Principles For Successful Townhouse Development.

How Zoning Affects What Is Possible

Land size alone does not determine development potential. The applicable residential zone is equally important, as it sets density expectations, height limits, and the weight given to neighbourhood character considerations. For a detailed reference on applicable ResCode standards across zones, see our ResCode Victoria 2026 developer reference.

General Residential Zone (GRZ)

The General Residential Zone is the most common zone for townhouse development across Melbourne’s Eastern Suburbs. It permits medium-density development subject to ResCode compliance and neighbourhood character considerations. Most two-to-four townhouse projects in the City of Whitehorse, City of Monash, and Maroondah City Council are assessed under this zone.

Neighbourhood Residential Zone (NRZ)

The Neighbourhood Residential Zone imposes more restrictive density controls. Many NRZ schedules across Eastern Suburbs councils specify a minimum lot size per dwelling — commonly 300m² to 400m² per dwelling — which directly limits the number of townhouses permissible on a given site. In some NRZ schedules, a maximum of two dwellings per lot applies regardless of site area. Developers should check the specific NRZ schedule for each council before assessing yield.

Residential Growth Zone (RGZ)

The Residential Growth Zone supports higher-density development and is typically applied near activity centres and train stations. In areas of the City of Boroondara and City of Whitehorse near major transport nodes, RGZ zoning may allow greater yield relative to land area, though neighbourhood character and height controls still apply.

Council-Specific Considerations in Melbourne’s Eastern Suburbs

While state-level controls set the baseline, each council’s planning scheme contains local policies and overlay controls that can materially affect what is achievable on a given site. The following provides a brief overview of key considerations across Eastern Suburbs councils.

• City of Boroondara: Strong neighbourhood character policies apply across most residential areas. Heritage Overlays affect a significant proportion of residential land, particularly in Hawthorn, Kew, and Camberwell. Townhouse yield is often constrained by character requirements even where land size is adequate.
• City of Whitehorse: Vegetation Protection Overlays apply across many residential areas, and significant trees can substantially reduce the buildable envelope. The council has historically applied ResCode standards carefully, and the deemed to comply pathway under the Townhouse and Low-Rise Code may assist in streamlining straightforward applications.
• Manningham City Council: Significant Landscape Overlays and Vegetation Protection Overlays are prevalent, particularly in Doncaster and Templestowe. Tree protection requirements can reduce yield on otherwise viable sites.
• City of Monash: A mix of GRZ and NRZ applies across the municipality. NRZ schedules in some areas specify minimum lot sizes per dwelling. The council has been active in applying neighbourhood character policies.
• Knox City Council: Outer suburban character and larger lot sizes are common. Sites in Knox often have more generous land areas, but slope, vegetation, and bushfire overlay considerations may apply in some areas.
• Maroondah City Council: Activity centre precincts near Ringwood and Croydon may support higher-density outcomes. Residential areas away from these centres are typically assessed under standard GRZ or NRZ controls.

SQM Architects has delivered projects across all six of these council areas, and our site assessment process is designed to account for council-specific policies from the outset.

The 2026 Reforms: What Changes for Townhouse Developers

The Planning Amendment (Better Decisions Made Faster) Act 2026 introduces structural changes to how planning permits are processed in Victoria. For townhouse developers, the most relevant changes include:

• Type 2 permit pathway: Townhouse and low-rise apartment applications that comply with specified codes are expected to be assessed under a 30-day timeframe, reducing the uncertainty that has historically affected project financing and programme management.
• Deemed approval mechanism for Type 1 applications: Simple, low-risk proposals — including duplexes — may benefit from a deemed approval mechanism if the responsible authority has not made a decision within 10 days. This is a significant shift from the current deemed refusal framework.
• Affordable housing contributions: The reforms introduce a framework for affordable housing contributions. Regulations are yet to be finalised, but developers of larger townhouse projects may need to factor potential contributions into feasibility modelling.
• Restrictive covenant reforms: The Act introduces new provisions relating to restrictive covenants, which may assist developers where title covenants have historically prevented townhouse development on otherwise suitable sites. For more on the subdivision process in Victoria, see our updated guide.

These reforms are being phased in, and not all provisions are yet fully operative. Developers should seek current information on which provisions apply to applications lodged after the relevant commencement dates.

Frequently Asked Questions

Is there a single minimum lot size for townhouses in Victoria?

No. There is no single state-wide minimum lot size for townhouse development. The viability of a site depends on zoning, applicable overlays, the Minimum Garden Area requirement, setbacks, frontage, access, and council-specific policies. Each site must be individually assessed against the relevant planning scheme and ResCode standards.

How does the Minimum Garden Area requirement affect townhouse yield?

The MGA is one of the most significant constraints on townhouse yield in Victoria. For sites over 650m², 35% of the site must remain as unencumbered garden area — meaning it cannot be covered by buildings, driveways, decks, or services. This requirement has reduced viable yield on many sites that were previously assessed under older planning rules, and accurate MGA calculation is essential at the feasibility stage.

What is the Townhouse and Low-Rise Code and how does it affect my application?

The Townhouse and Low-Rise Code, introduced via Amendment VC267 on 6 March 2025, created a deemed to comply assessment pathway under Clause 55. If a development meets all applicable standards, the responsible authority must treat the corresponding objectives as satisfied and cannot refuse on those grounds. Where all standards are met, there is also no third-party right of VCAT appeal, providing greater certainty for developers.

Can I build townhouses in the Neighbourhood Residential Zone?

It depends on the specific NRZ schedule for the relevant council. Some NRZ schedules specify a maximum of two dwellings per lot or impose minimum lot sizes per dwelling that limit yield. Developers should check the applicable NRZ schedule before assessing a site’s potential, as these controls vary between councils in Melbourne’s Eastern Suburbs.

How do tree canopy requirements affect larger townhouse sites?

For sites over 1,000m², updated ResCode standards may require planted trees to provide 20% canopy coverage at maturity. This can influence site layout, driveway placement, and dwelling yield. Council-specific overlays — such as Vegetation Protection Overlays — may impose additional requirements on smaller sites, particularly in the City of Whitehorse and Manningham City Council.

What does the 2026 Better Decisions Made Faster Act mean for townhouse approvals?

The Act introduces a tiered permit assessment system with defined timeframes. Townhouse applications are expected to fall within the Type 2 category, carrying a 30-day assessment timeframe. This may reduce delays that have historically affected project financing and programme certainty. Some provisions are still being phased in, so current legal advice is recommended for applications lodged in 2026.

Do I need a planning permit to subdivide townhouses into separate titles?

Yes. In Victoria, you generally need a planning permit for both the development and the subdivision — the creation of separate titles. A Statement of Compliance is required before separate titles can be issued. The subdivision process runs in parallel with or following the development permit process, and both should be factored into your project programme and budget.

Conclusion

Determining how much land you need for townhouse development in Melbourne’s Eastern Suburbs is not a matter of applying a single rule — it is a process of layering zoning controls, ResCode standards, council-specific policies, and site-specific constraints to arrive at a realistic yield assessment. The Minimum Garden Area requirement, tree canopy rules, SPOS standards, and the applicable residential zone are the primary drivers of what is achievable on any given site. The 2025 Townhouse and Low-Rise Code and the 2026 Better Decisions Made Faster reforms have introduced meaningful improvements to the assessment pathway, but they do not remove the need for rigorous site analysis before committing to a purchase.

SQM Architects has delivered projects across Melbourne’s Eastern Suburbs. Our site assessment process is designed to give developers a clear, evidence-based view of what a site may support under current planning controls — before exchange of contracts. To find out what your site may support, contact our team for a Book a Strategy Call or call us on (03) 9005 6588.

This article provides general information about Victorian planning for property developers. It does not constitute professional advice. For specific guidance on your project, contact SQM Architects for a complimentary site assessment.