Visionary Planning UK

05/05/2026

IF you are considering an ACV building you need to be aware of the impending changes.

An asset of community value (ACV) is land or a building nominated by an organisation with a local connection and listed by the listing authority if it is considered that it has or recently had community value by furthering the cultural, recreational, or sporting interests of the local area.

17/04/2026

BNG Simplified? Smaller Sites, Fewer Hurdles
Nuala Wheatley

When mandatory Biodiversity Net Gain (BNG) came into force in February 2024, it represented one of the most significant environmental changes to the English planning system in decades. The principle of the system was clear – development should leave nature in a better state than it was before. Despite this sizeable shift, most developers supported the change, quickly adapting their working practices to factor in BNG design requirements, costs etc. to their projects.
However, the first couple of years of implementation revealed that in some instances, the system was creating disproportionate cost, delay and uncertainty, particularly for minor developments. Responding to this, the Government launched an 8‑week consultation[1] last year on improving how BNG is implemented for minor, medium and brownfield development, alongside a separate consultation covering NSIPs*. Following more than 25,000 consultation responses, the Government published its response on Wednesday.

Having reviewed the consultation outcome document in full, the overarching message is clear: BNG is staying, but it is becoming simpler, more flexible and more proportionate. Our reading is that the Government aren’t stepping back from the principles of the BNG system, more it is undertaking a recalibration of where the policy delivers most value. We summarise the key changes below.


Exemptions
The most substantial change is the introduction of a new area‑based exemption (originally announced in December 2025) meaning any development with a red line site area of 0.2 hectares or less will be exempt from BNG, provided no priority habitats are affected. Whilst it is noted that this change could result in a 12% reduction in biodiversity units delivered, the Government considers this change is proportionate to reduce the burden on smaller developers.
The exemption will remove what was often a significant cost relative to scheme size, as well as the need to commission ecological surveys, submit biodiversity gain plans and secure off‑site units for very small impacts. It is important to note that this exemption is measured by the planning red line, not the developable area, making it simple to apply and easy for LPAs to enforce.

Other changes include:
The removal of the self-build and custom build exemption (widely viewed as complex, hard to enforce and susceptible to misuse).

The retention of the de-minimis exemption (however this is to be reviewed following a separate brownfield consultation – more on this below).

Biodiversity-led development where the primary objective is to conserve or enhance biodiversity will be exempt from BNG e.g. habitat creating schemes requiring planning permission.

New exemption for parks, public gardens, playing fields e.g. community sports facilities ancillary to existing playing fields (this will not apply to professional sports stadiums or these types of proposals within residential or mixed-use developments).

New exemption for temporary development which is five years or less (this only applies where the whole development comprises solely of temporary development).

The Government has decided not to proceed with proposals for a blanket exemption for all minor development. Despite concerns that BNG was slowing progress on small sites, the majority view appears to be that a full minor development exemption could lead to substantial cumulative biodiversity loss, particularly in towns and cities. The new area‑based exemption is intended to strike a balance: removing BNG where it is most disproportionate, while retaining it where impacts and opportunities are greater.
No changes to the ‘de minimis’ exemption are currently proposed, with the Government noting that this will be considered alongside the future government response to the consultation on BNG for residential brownfield development. A change to this exemption is still crucial, given there will be certain types of development that have a site area above 0.2 hectares (and therefore not covered by the new area-based exemption) which will have little or no impact on habitat. In these cases the application of BNG is often disproportionate to the benefits.

Other notable changes
Beyond exemptions, the response also makes it easier for developers to ‘go off‑site’, particularly on smaller schemes that remain subject to BNG. For minor development, the biodiversity gain hierarchy will be relaxed so that off‑site delivery is treated equally to on‑site provision. This is a practical change that many developers have requested. For already constrained sites, attempting to make room for marginal on-site gains has often led to questionable design outcomes and long-term management risks. It seems that going forward, we’ll have greater certainty that purchasing off-site units is an accepted and equal option.
The Government has also confirmed changes to the spatial risk multiplier, which affects where off‑site units can be sourced from. Rather than being assessed against local authority boundaries and National Capital Areas (NCAs), the multiplier will be based on Local Nature Recovery Strategy (LNRS) areas – reducing the number of habitat ‘trading areas’ from 337 LPAs or 159 NCAs to 48 LNRS areas.
This change could be fairly polarising. On the one hand, this shift to LNRS based spatial risk will strengthen the link between BNG and strategic nature recovery but could also have negative consequences for landowners with gain sites or BNG providers – some landowners will see greater demand for units whilst others will be cut off from previous clients. For developers, this change could translate to greater availability and improved choice in off-site units.

Brownfield sites
Brownfield development, particularly sites with Open Mosaic Habitat (OMH), has also received targeted attention. OMH has proven difficult to identify, value and compensate for, often creating viability challenges on previously developed land. It’s encouraging to see these long-standing challenges being addressed, with a commitment to make metric and guidance changes for the use of proxy habitats as a suitable alternative to OMH. Metric information, including the definition of OMH, will be updated to assist with clearer identification.
A further consultation[2] for residential brownfield development is now open and runs until 10 June 2026. It seeks feedback firstly on a definition of brownfield residential development - establishing a clear, operational definition that combines both what constitutes residential led development and what counts as brownfield land. This definition is then applied to a targeted BNG exemption for brownfield residential development, on sites potentially up to 2.5 hectares, unlocking urban sites where BNG requirements have previously had a significant impact on viability.


Implementation and next steps
In terms of the implementation of the above key changes, this will be phased through 2026. By 31 July 2026 (subject to parliamentary timetabling) secondary legislation will be published to introduce the 0.2 ha exemption, exempt temporary permissions and amend the gain hierarchy for minor development. Until then, existing BNG rules remain in place.
Later in 2026 the other exemptions will come into force, as well as a possible brownfield exemption subject to the outcome of the open consultation.
Overall, the raft of changes proposed is positive. It is clear that the Government has listened to delivery concerns and is willing to make adjustments without undermining its environmental objectives. The proposed changes mean that for minor development schemes, BNG should be simpler and more commercially workable than it was when the system was first introduced.
As always, Lichfields’ in-house BNG team are on hand if you have any queries in relation to the above, are interested in responding to the open Brownfield consultation, or need help with navigating the BNG system more generally. Please get in touch!
*Keep your eyes peeled for an incoming Lichfields blog on the Government’s response to the BNG consultation on NSIPs!

13/04/2026

In R (on the application of Oliver Perrin) v North Devon District Council [2026] EWHC 535 (Admin), the Planning Court quashed a planning permission granted contrary to the Officer’s Report, finding that the Council had acted irrationally and that there was apparent bias in the decision-making process. The judgment provides useful guidance on the level of justification required where a planning committee departs from officer advice, particularly on matters of planning policy interpretation, and underlines the need for councillors - especially senior and influential figures -to maintain clear distance from parties involved in the planning process.
09.04.2026

Background

The development which had been granted planning permission by North Devon District Council (the “Defendant”) consisted of the er****on of a singular open market dwelling (the “Development”) in Patchole, a small settlement centred around a road junction in Barnstaple, Kentisbury. Mr Perrin (the “Claimant”) had objected to the application as an owner and occupier of a nearby dwelling.

A particular source of contention was whether the Development complied with Policy DM23 of the North Devon & Torridge Local Plan 2011-2031 (the “Development Plan”) which provided that were a site is not within the built form of an existing settlement but merely “well related to the main built form of the settlement”, development would be supported where it was affordable housing focused. It was this policy context that resulted in the application being called in for determination by the Planning Committee (the “Committee”).

The first officer’s report recommended refusal of the application on the basis that the site was not within the built form of the Patchole settlement (despite being “well related”) and did not meet an identifiable need for affordable housing. However, the Committee resolved to grant permission on the basis there was accordance with Policy DM23. This was challenged by the Claimant by way of a pre-action protocol letter and subsequently quashed by consent on the basis of a failure to provide adequate reasons for granting permission contrary to the recommendation of the Officer’s Report.

Upon redetermination, the Committee at first instance resolved to grant permission on the basis of findings from the Planning Inspectorate (in a prior unrelated appeal case) as to what a principle built form could consist of, however the Defendant remitted this decision again following legal advice and publication of the National Planning Policy Framework (December 2024) (the “NPPF”), specifically the need for a ‘tilted balance’ assessment. The revised officer’s report (the “Officer’s Report”) considered that Policy DM23 had limited weight due to the absence of a 5-year housing supply, meaning that the presumption in favour of sustainable development applied. Nevertheless, the report found this was offset by significant weight to be afforded to the retention of the site for affordable housing rather than open market housing and on that basis recommended refusal. The Committee disagreed with this assessment, giving increased weight to producing another property for the vitality of the village in accordance with the aspiration of community growth in Policy ST01 on sustainable development. They therefore resolved to grant permission.

Findings

HHJ Russen KC dealt with the following grounds together:

Ground 1: Irrationality, irrelevant consideration and inadequate reasons in the Council’s finding that the Development accorded with Policy ST01
Ground 2: Irrationality and a failure to provide adequate reasons in relation to the failure of the proposed development to meet an identifiable need for the provision for affordable housing focused development.
Ground 3: Irrationality, irrelevant consideration and inadequate reasons in the Council’s finding benefits in the Development “producing another property for the vitality of the village”.
It was held that Ground 1, 2 and 3 were successful in respect of inadequate reasons and irrationality. HHJ Russen KC found that the planning committee did not explain the basis for concluding that the development of an open market dwelling as opposed to an affordable housing dwelling was to be given greater weight in producing another property for the vitality of the village than the social perspective in Policy ST01, ST19 and DM23. They were entitled to give these policies limited weight (as the Officer’s Report had done) but did not appear to have the “particular regard” required by NPPF paragraph 11 (d) iii to the relevant policy framework in relation to affordable homes. The Officer’s Report had still given significant weight to the retention of the site for affordable housing notwithstanding the presumption of sustainable development. The Committee did not adequately explain why they had taken a different view by not engaging with the officer’s view that the Site was only well related to the main built form of the settlement and not in fact within its principal-built form.

In respect of irrelevant considerations, HHJ Russen KC considered the committee’s references to an “aspiration of community growth” and “enhancing the vitality of the village” as addressing the economic perspective under paragraph 8 of the NPPF to which the Officer Report attributed only limited weight in the assessment of the titled balance.

Ground 4: Apparent Bias

HHJ Russen KC upheld the Claimant’s allegation of apparent bias through the participation of Counsellor Prowse in the decision-making process. This was based on the Counsellor’s personal familiarity with the applicants (including remarks about their family in the Committee Meeting), his direct involvement with them before and during the planning process (e.g. through providing procedural advice related to the application) and their intervention by way of calling the application in to the committee. This was compounded by the number of times the Committee had reached a decision contrary to the recommendation in the Officer’s Report, and Counsellor Prowse’s influence over other members given his seniority as a Councillor. Even if the other grounds had not succeeded, it was held that this ground alone would have been sufficient.

Impact of this case

This decision emphasises the importance of substantiating a decision to go against an officer’s report with reasons which directly engage with the officer’s reasoning and why a departure is necessary. This is particularly so where the planning committee arrives at a different conclusion in respect of accordance with planning policy. The decision also provides a clear reminder of the standards expected of councillors whose participation in the decision-making process may be influential. Such councillors should exercise caution where they have personal familiarity with applicants and provide procedural advice (even if permitted to do so).

10/04/2026

Reforms to BNG needed, says home building industry

More than 80 per cent of home builders have reported finding the implementation of biodiversity net gain (BNG) a challenge, according to a report by the Home Builders Federation (HBF).
This comes two years after the policy was introduced.

Overall, 84 per cent of home builders said they continue to find implementing BNG challenging, with SME builders particularly impacted.

The research found that the policy is having a growing impact on development viability and housing delivery, especially on smaller sites. Although proposed changes to assist SMEs were welcomed, including exemptions for smaller developments of up to 0.2 hectares from BNG, two-thirds of respondents to HBF’s member survey do not think they go far enough to make a difference.

Conducted in early 2026, the survey found that 60 per cent of respondents considered that BNG had influenced their company’s decision not to pursue sites that may previously have been viable. In particular, uncertainty around agreeing on the cost and type of biodiversity enhancements needed on a site was cited as a concern.

In addition, local authority capacity was cited as a “significant challenge” for the delivery of BNG, owing to delays in reviewing biodiversity assessments. The survey found that 80 per cent of respondents reported planning delays because of BNG, with 66 per cent citing insufficient resources or expertise, down from 79 per cent in the 2025 survey.

Other challenges include:

Ongoing uncertainty around aspects of BNG policy.
Inconsistencies in how requirements are applied.
The cumulative burden of increasing regulatory and cost pressures is facing the industry.
The Future Homes Standard, which HBF said is estimated to cost on average £10,000 per home.
According to the survey, 50 per cent of those canvassed said their company had reduced housing numbers on at least one site due to BNG requirements. Respondents said that they had reduced the number of homes on a site in response to these pressures, as land must be set aside for habitat creation and enhancement.

With the off-site biodiversity unit market improving “significantly”, 47 per cent of respondents reported sufficient supply, up from 31 per cent last year.

Delivering 10 per cent mandatory BNG on new developments was introduced in the Environment Act 2021, and came into force in various stages in 2024. It can be delivered on-site or off-site.

HBF has called on the government to make sure that BNG is implemented without restricting housing supply. This includes addressing the recruitment crisis for public sector ecologists, providing clearer guidance, and including baseline biodiversity assessments in local plans.

Moreover, it wants to see stronger support for SMEs through a higher small sites threshold, arguing that the proposed exemption of 0.2 hectares is too low.

Neil Jefferson, chief executive at HBF, said: “The cumulative impact of biodiversity net gain requirements and wider cost pressures is increasingly affecting the viability of housing developments, with too many sites becoming difficult to bring forward.

“The home building industry supports the goals of BNG and remains committed to delivering new homes alongside meaningful improvements to nature.

“However, we need the government to provide greater clarity and ensure a consistent approach across local authorities and to provide support for SME builders so that these requirements do not become a barrier to delivering much-needed housing.”

This second BNG survey received responses from more than 80 companies, six in 10 of which are SME home builders.

The Biodiversity Net Gain Sentiment Survey 2026 can be found on the HBF website (PDF).

08/04/2026

75% of major grey belt appeals approved since policy introduction – analysis

Three-quarters of major residential appeals have been approved since the policy was introduced in the 2024 National Planning Policy Framework (NPPF), according to research.
The analysis by planning, design and development consultancy Marrons reviewed all 224 planning appeals referencing ‘grey belt’ between 12 December 2024 and 28 February 2026.

Of the 24 major residential schemes, 18 were allowed by the Planning Inspectorate. These schemes are defined as development comprising 10 or more homes.

The most common residential grey belt appeal size is between two and nine dwellings. Seventy-three of these were considered, with 22 appeals allowed.

Overall, the analysis found that 48 of 111 residential grey belt appeals were allowed – 43 per cent. Major housing schemes make up 22 per cent of residential grey belt appeals and 38 per cent of approved residential schemes.

Last year, The Planner reported on Marrons’ previous analysis of grey belt appeals approved in the nine months to the end of August 2025, following the introduction of the December 2024 NPPF. The success rate for major residential appeals has dropped from 80 per cent (16 of 20) to 75 per cent.

Non-residential appeals were split across a range of uses, including:

19 per cent – caravan and traveller sites
11 per cent – energy projects
5 per cent – commercial
5 per cent – industrial developments
4 per cent – sui generis
3 per cent – leisure
2 per cent – retail
1 per cent – education
1 per cent – specialist residential
1 per cent – healthcare
Considering grey belt appeals by region, the South East remains the primary hotspot, Marrons noted, accounting for 35 per cent of appeals, although its dominance has declined from 52 per cent. The East of England represents 26 per cent of appeals, with the West Midlands and North West each at 11 per cent. This reflects a wider geographical spread of grey belt activity, said the company.

Roland Brass, planning director at Marrons, said: “Grey belt policy continues to be a game changer for achieving major residential planning permissions.

“The data shows that larger sites in particular are much more likely to succeed, which is crucial for unlocking the scale of development we need to address the housing crisis.

“While the overall proportion of major residential appeals allowed has dipped slightly since our last report, the policy is still performing and creating new opportunities across the country in sustainable and logical locations where there is a need for new homes.

“It is also important to acknowledge that more major schemes are being granted planning permission locally, and this impacts on the number of appeals.

“However, given the number of planning applications that have been submitted over the past six months, we expect overall numbers – for both local decision and appeals – to increase over the next year, particularly with the new National Planning Policy Framework (NPPF).”

27/03/2026

Huge news for the UK Planning System today!

The government has officially published the draft regulations for the new National Scheme of Delegation (NSD). This is a massive step toward ending the "postcode lottery" of planning speeds across England.
We are moving to a "delegated by default" model.
Key Takeaways:
✅ Tier A: Minor and householder applications are now mandatorily delegated to officers.
✅ Tier B: Larger schemes stay with officers unless they meet strict "high-impact" criteria for committee review.
✅ Efficiency: The goal is to free up committees to focus on strategic growth rather than debating extensions.
✅ Accountability: New mandatory training for all committee members to ensure professional standards.
This is a game-changer for developers and local authorities alike, aiming to slash determination times and provide much-needed certainty for the housing and infrastructure sectors.
The consultation will run until 23 April.

20/03/2026

London and the 5 year Housing Land supply

20/03/2026

As the London Plan turns five, will its review create a new beginning for housing delivery?
Ross Raftery, Simon Slatford & Mia Busby

20 Mar 2026

This month, the London Plan turned five years old. As most of us look ahead to the next iteration of this Spatial Development Strategy (‘SDS’) - the first under this Government’s direction of being “genuinely strategic” - we consider what this anniversary, the new Local Plans system and the new London Plan could mean for London boroughs and those looking to build new homes across London.

It is now well documented that the Mayor recognises the scale of the housing crisis in London and he has indicated that the new, slimline, London Plan is expected to seek to meet the London’s housing need in full. We watch this space with interest, to see how that will be achieved. The aim is to have a new London Plan in place by 2027/28, but there is plenty of time to influence what that will contain.

In the intervening period, there are other potential opportunities that will arise for bringing forward new homes:
In certain boroughs, the Five Year Housing Land Supply (‘5YHLS’) requirement will increase dramatically;
There may be trouble ahead for those boroughs who seek to adopt lower housing targets; and
There are many new opportunities to influence emerging local plans or to ensure they keep on the straight and narrow.

We consider these in this blog.

The timeline

Over the next year, there will be changing circumstances at a local, London and national level which will significantly influence the housing position in London (in terms of planning). We have therefore analysed the local plan position for each London borough and in Figure 1 identify what their local plan trajectory is expected to be against key upcoming milestones. These milestones are:
March 2026 - London Plan becomes 5 years old and the basis of calculating the 5YHLS changes to be in line with standard method.

1 July 2026 - NPPF 2024 §78c requires a 20% buffer to be applied where a borough has a housing requirement adopted in the last five years whose annual average housing requirement is 80% of less than the LHN (unless a 20% buffer is already applied).

summer 2026 - anticipated publication of draft London Plan (including its proposed housing distribution, although this will have limited weight).

2027/ early 2028 - GLA’s published target adoption date.
Overall findings are that 11 no. of Local Plans are in place that will run through this period. 10 no. of local plans are currently underway and due to be adopted before the London Plan is adopted and the remainder of plans will be adopted after the new London Plan. We explore the implications of this in more detail below.

The anniversary for 5YHLS

Colleagues have previously analysed the importance of this anniversary[1] and the window of opportunity it creates when measuring the 5YHLS.

Now that the London Plan is five years old, the 5YHLS measurement for decision-making depends on the status of individual Local Plans[2]. If a London borough’s local plan is already five years old, then this reverts to the standard method which is, almost uniformly, higher than the current London Plan targets.

This means that the following boroughs all revert to using the standard method LHN, which is higher than their London Plan target (until they adopt a new Local Plan), creating potential opportunities for speculative planning applications[3]:
Bromley; Camden; City of London; Croydon; Ealing; Enfield; Hackney; Hammersmith and Fulham; Haringey; Harrow; Hillingdon; Hounslow; Kingston upon Thames; Redbridge; and Sutton

July 2026 – 20% buffer
A new 20% buffer was introduced by the Government in the 2024 NPPF (§78c) to help address shortfalls between recent local plans and the new standard method. This new buffer to the 5YHLS calculation will apply to seven London boroughs where their housing target is 80% or less than the LHN and a 20% buffer is not already applied by virtue of the 2023 Housing Delivery Test results:
Barnet; Bexley; Brent; Merton; Waltham Forest; Wandsworth; and Westminster

Combined with the 2023 HDT results, of the boroughs with a plan adopted in the past five years, we anticipate that all will have a 20% buffer applied.

For these boroughs, there could be greater scope to demonstrate an unmet housing need – creating the future opportunity for the broader presumption in favour of development in the draft NPPF to be applied.


Emerging Local Plans

The Government has announced that local planning authorities can submit plans under the existing system until 31 December 2026[4]. While we move to a faster and more streamlined plan-making system with great anticipation, this deadline is having a bearing on boroughs with local plans in preparation.

We expect the following boroughs to try and submit plans for examination before this deadline:
Bromley; Greenwich; Hammersmith & Fulham; Kingston upon Thames and Sutton
Failure to achieve this deadline will mean that boroughs then need to transition to the new Local Plans system promptly, including repeating relevant plan-making steps, so the stakes are high for them to achieve this. This will further delay having an adopted plan in place, when we are meant to be working with a ‘plan based’ system.

To understand the cumulative effect of the transition to the new Local Plans system and layering the timeline for the preparation of the new London Plan, we have reviewed some case study boroughs in more detail:


Hillingdon
Hillingdon’s original ambition was to submit a local plan under the existing plan-making regime, by December 2026. However, in a Cabinet Report[5] officers recommended delaying this process and instead progressing under the new plan-making system.

This approach was, partially, based on Hillingdon’s LHN more than doubling from the London Plan target, and a recognition that the plan was being prepared in advance of the Mayor’s apportionment of London’s LHN to each individual borough. This apportionment could require substantial revisions and further consultation – they considered it is prudent to delay publication of the draft plan, so that the apportioned targets can be considered.

The indicative timetable now proposes submission in September 2027 and adoption in April 2028 which would tie in closely with the London Plan.


Camden
In the alternative, LB Camden submitted its plan for examination in October 2025. However, its proposed housing target is 11,550 additional homes from 2026/27 to 2040/41 – an average of just 770 homes per annum (74% of the annual London Plan target, 1,038 dpa between 2019-29).

This drop in housing requirement was challenged by the GLA[6]. The GLA note that the “current London Plan does not meet London’s identified need and therefore the overall amount of housing required annually should not be expected to reduce.”

The GLA also state that the text at paragraph 4.1.11 of the London Plan[7] is “now considered to be out of date”, in the context of working towards delivering 88,000 homes per annum. The GLA stated that boroughs “should seek, as a minimum, to roll over the current London Plan target beyond 2028/29, including any shortfall accrued to date, and to continue to take proactive measures to increase housing supply.”

The GLA’s position here demonstrates that it is seeking to try and boost housing supply through local plans now – in anticipation of increases in the next London Plan.

While Camden’s position was ultimately agreed in the statement of common ground between the GLA and Camden it could result in a Local Plan being adopted with a materially lower housing target than the current position. This will be superseded by the targets in the next London Plan when it is adopted, but it will effectively ‘bake in’ a housing strategy and site allocations at this lower level for the duration of the plan.

It is also notable that 25 boroughs[8] responded to Camden’s duty to co-operate request and all confirmed that they are not in a position to help Camden identify a 5YHLS.


What this all means for local plan preparation?

The cyclical lag between local plans, the London Plan and, now, the application of the new standard method, continues to create a complex picture of the housing requirement across the capital.

It is expected that the Mayor will redistribute the 86,000 homes per annum LHN for London across boroughs, so that this is met in full. However, achieving this will be reliant on having local plans that are prepared with sufficient allocations and ambition to match this requirement. The current picture is that most local plans will be based on out-of-date housing targets, including those that are continuing to be prepared.

Our analysis of borough’s local plan timetables (Figure 1) indicates that:
there is a group c.11 boroughs with adopted local plans that will remain less than five years old through to 2029-31.

there are c.15 boroughs in the preparation of a local plan now, five of which are seeking to submit ahead of the 31 December 2026 deadline for the current plan-making system. Concerningly, a number of these boroughs are seeking to adopt targets beyond 2029, which will be below the current London Plan target, let alone seeking to meet their LHN. It is unclear if Inspectors and the Mayor will expect these boroughs to meet a draft LHN redistribution figure, or if this will only be applied closer to adoption of the London Plan.

the remaining c.8 boroughs are expected to progress under the new local plan-making system, and their timescales are likely to coincide with the Mayor’s LHN redistribution figure being at an advanced stage. This should lead to the expectation that those boroughs prepare plans to meet this need.


Concluding thoughts

Housing distribution: In order for boroughs to begin to prepare local plans that contribute to achieving London’s LHN as a whole, the distribution of those 86,000 homes cannot come soon enough. This is necessary for effective planning and to avoid local plans being adopted which ‘bake in’ anomalous housing numbers for the next plan period.

HDT methodology: Positively, the Government is proposing to amend the Housing Delivery Test rule book, so that the relevant housing requirement is derived from whichever is the most recently adopted plan (whether it is a spatial development strategy or borough/district-level local plan). If implemented, this will address the risk of boroughs being measured against materially lower targets for the HDT.

5YHLS methodology: The next London Plan will return to primacy as the basis of the 5YHLS from its adoption (likely late 2027/early 2028). However, until then, those boroughs with local plans that are more than five years old will revert to the full LHN for this measure. Based on the potential implication of failing the 5YHLS[9], we anticipate that this will be most relevant to Camden; Hillingdon; Hounslow; Redbridge and Tower Hamlets.

Local elections: with all London borough councillor seats up for election in May 2026, there is the possibility for new local plan committees to introduce yet more uncertainty to this position. This could mean potential delays in local plan preparation, as new councillors/parties seek to understand and influence their local plan.

Clearly, given the complexities of considerations over the next year, the housing position needs to be considered on a borough-by-borough basis, but there are expected to be significant opportunities, both through speculative applications and through engaging in local plan consultations in the context of significant increases in housing requirements.

Footnotes
[1] The Presumption: a London Focus - A Complex Outlook for Calculating Land Supply, Paddy Hynes & Harry Bennett
[2] Until the next London Plan is adopted (stated by the GLA to be 2027, https://www.london.gov.uk/programmes-strategies/planning/london-plan/next-london-plan and in the more recent Hounslow/GLA statement of common ground as ‘early 2028’).

[3] It is recognised that for some boroughs, this is tempered by existing failings in the Housing Delivery Test, but it will add further weight to the importance of housing delivery.

[4] https://www.gov.uk/government/news/new-local-plan-system-launching-early-2026-latest-update

[5] Cabinet Report 15 January 2026.https://modgov.hillingdon.gov.uk/documents/s65395/05%20-%20REPORT%20HC%2020251124%20Local%20Development%20Scheme%202025%20December%20Cabinet%20Report%201.pdf

[6] https://www.camden.gov.uk/documents/d/guest/sd19-statement-of-common-ground-with-the-gla

[7] Paragraph 4.1.11 of the London Plan requires that housing targets beyond the 10-year period of the London Plan targets should draw on the 2017 SHLAA findings, any local evidence of identified capacity.

[8] Barnet, Bexley, Brent, Bromley, City of London, Ealing, Enfield, Greenwich, Hackney, Haringey, Havering, Hillingdon, Hounslow Islington, Lambeth, Lewisham, Merton, Newham, Redbridge, Richmond, Southwark, Tower Hamlets, Waltham Forest, Wandsworth and Westminster

[9]Based on Planning Resource 5YHLS data, these boroughs could see their position fall below five years.