Attic conversion with dormer on the exterior

Hello,
maybe someone can help me?
There is the following situation. I want to convert the attic in an existing house where there are already two apartments (grandparents and parents) and create a dormer. Since a third apartment is now being created, the building falls into building class 3. The resulting fire protection requirements are not a problem. We were also confirmed that the dormer would be approved.
There is only one other problem. The district office says that we are located in an outer area. And in the outer area, no more than 2 residential units are allowed in one house. This was shown to me in the law and apparently is correct. Only my question is when exactly is one considered to be in the outer area? Our house is located right on the edge of a settlement with about 80 houses. The annoying thing is that our property boundary to the neighbor in the direction of the settlement is also the municipal and cadastral boundary. The land use plan extends over the entire settlement exactly up to our neighbor. Unfortunately, our property lies outside the land use plan.
Are we really in the outer area? We always thought that we belong to the settlement. Our access road also leads through the settlement. I attached a picture. The house marked in red is mine.
I would be happy if someone could help me.

Residential building class 3 is more than just a bit of fire protection. Which federal state do you live in?

[*]What about the escape routes?
[*]Do you have appropriate apartment entrance doors?
[*]Since it's an existing building, probably no ventilation system!?
[*]Structural engineer for inspections?
[*]Soundproofing?
[*]Parking spaces for bicycles and strollers?
[*]Playground?
[*]Is a WEH barrier-free accessible?

The list is certainly not complete or binding, but it gives an insight into what, among other things, one must think about or consider.

All these things regarding fire protection are already in place or can be produced with little effort. That has been clarified. We are in Bavaria. Whether building class 3 is permissible depends on whether we are in the outer area or not. We also had considerations that the attic conversion would be officially carried out by my parents. So officially there would only be 2 apartments and we would remain building class 1. But I need money from the bank to be able to carry all this out. For that, I also need collateral. My parents would then have transferred the rooms in the attic to me. But if the 3rd apartment officially does not exist, I think the bank will not see this apartment as collateral either.

We also considered having the attic conversion officially carried out by my parents. So officially there would only be 2 apartments, and we would remain building class 1.

I don't understand? And if Meister Eder converts the roof, will it become a TV tower?

I would stay away from such scheming very quickly. It only causes trouble. Often it’s nosy neighbors, or if you rent out, the tax office. And if something happens, it gets expensive.

Whether you are allowed to build 3 residential units is usually regulated by the development plan (unfortunately in our area about 90% of development plans exclude this) or the building authority with certain conditions or interpretations.

If building is allowed, certain conditions must be met, see currently with us in NRW (post above).

My only question is: when exactly is one in the outer area?

Accuracy is the surveyor’s issue, and precisely for that reason the urban planner decides on the boundary between inner and outer areas, because there are no exact criteria for it. There are cases where you get different answers from different caseworkers (sometimes even from the same caseworker if some time has passed). From an urban planning perspective, you have to gather indications that support a connection of your house with the rest of the settlement. Municipal boundary, cadastral boundary, outside the land use plan are already three counterarguments. If the district office says it is an outer area, you probably won’t have a chance.