The 2025 draft NPPF in brief with indicative responses

1 Background in brief
2 Draft in brief
3 Local verses National
4 Suitable verses sustainable
5 Related articles on Designing Buildings

[edit] Background in brief

In December the government published a consultation on a revamped National Planning Policy Framework, that consultation ends in early March 2026. This follows previous changes made to the NPPF on 12 December, 2024 (along with new guidance) many of which were directed towards achieving economic growth and targetting 1.5 million new homes. Some key elements of the previous changes included reintroduction of mandatory targets, raising the combined national annual target to 370,000 homes, and formally prioritising lower-quality grey belt land for development with a set of Golden Rules. The golden rules looking more closely around lower quality greenbelt land and its potential for development to allow for infrastructure (nurseries, GP surgeries) and also affordable housing under certain circumstances. Prior to this under the Conservative government an updated the NPPF had been published on 19 December 2023 with changes focused on making housing targets advisory rather than mandatory.

This current NPPF consultation remans open until 10 March 2026 National Planning Policy Framework: proposed reforms and other changes to the planning system. On its publication in December 2025 initial reaction to the draft NPPF from industry was generally positive from the construction side, with initial warnings voiced from the side of environmental management, ecology and conservation. The Chapters below aim to briefly talk through some of the key aspects noted more recently.

The Home Builders Federation said in December 2025 the NPF reinforces commitment to reforming the planning system 'removing barriers to homebuilding, retaining a clear focus on sustainable development while protecting the natural environment... reduce the complexity should help to reduce delays.. progressive approach urgently required if the industry is going to reverse the trend of recent years that has seen a decline in the number of homes being consented.” CIEEM said. " a 10% cap on uplifts by local authorities, which would limit their ability to go beyond nationally set requirements... risks constraining councils that wish to show greater local ambition or respond to higher levels of need for nature recovery, biodiversity enhancement or environmental protection within their areas... importance of ensuring that reforms to national policy do not undermine the ability of the planning system to deliver positive outcomes for nature alongside development."

[edit] Draft in brief

The draft NPPF restructures policy to clearly separate plan-making from decision-making and introduces stronger national direction on housing. It proposes a 40% minimum requirement for accessible homes (M4(2) and M4(3)), a national minimum proportion of social rent on major schemes, and housing targets set through spatial development strategies, reducing local flexibility. A new ‘medium development’ category (10–49 homes) may allow financial contributions instead of on-site affordable housing and could be exempt from biodiversity net gain. The draft also limits local authorities’ ability to set standards beyond national regulations and re-emphasises objectively assessed need for housing.

A shift of presumption in favour of development from “sustainable” to “suitable,” means development in existing settlements would generally be approved unless clear harm outweighs national policy benefits, and well-located sites outside settlements that efficiently use land and infrastructure gain stronger support. Near transport nodes such as railway stations, schemes could benefit from near-default approval with mandatory minimum densities of 40–50 dwellings per hectare. The concept of suitability also supports small-scale gentle densification (infill, corner plots, roof extensions), often alongside potential exemptions for affordable housing and biodiversity net gain. The draft further formalises the concept of “grey belt” land within or adjacent to the Green Belt, clarifying how lower-performing parcels may be released for housing or infrastructure while retaining the “very special circumstances” test and linking decisions more explicitly to Local Nature Recovery Strategies and environmental objectives.

The consultation also asks views on data centre thresholds, viability assessments, reforming site thresholds, and other planning system changes that accompany the NPPF revision such as Areas for producing spatial development strategies.

The consultation remans open until 10 March 2026 National Planning Policy Framework: proposed reforms and other changes to the planning system.

[edit] Local verses National

The new draft NPPF is now somewhat restructured, making a separation between plan-making policies or those that guide local plans and strategies, and decision-making policies at the National level as well as those that apply directly to planning applications, decisions and appeals.

A new national minimum requirement of at least 40% of new housing over a plan period must be delivered to meet the accessibility and adaptability requirements of Building Regulations as well as adaption for wheelchair users (M4 (2) and (3)). Local authorities being required to set out the specific proportion of new housing to meet the requirements, identifying specific sites or set requirements for parts of allocated sites to provide accessible housing.

A 15 year plan period relating to the local plan remains although the potential to reduce this timeframe to 10 years is also proposed, under the new system. In terms of housing for social rent where as previously local authorities would specify proportions for social rent, a national minimum proportion of social rent (such as 10%) is now being sought for all major developments. The spatial development strategies are envisaged a housing target setting tool for each local planning authority and to identify broad growth locations, constraining local flexibility to lower or redistribute numbers through local plans. The five per cent buffer to five‑year housing land supply annual calculations (and removal of the ten per cent buffer from the 2024 version), remains but the focus is continuous delivery rather than on technical buffer mechanisms.

Although with one caveat to the national minimum proportion of social rent is the newly defined category of a ‘medium development’, which represents sites of up to 2.5 hectares with 10 to 49 homes. At this scale of development it is proposed that the likely SMEs carrying out the work may make contributions in lieu of meeting the requirements for affordable housing. These kinds of exemptions for scale would also apply to biodiversity net gain requirements, subject to legislation.

One further element of this aspect is the addition of PM13, a proposed new policy which aims to limit quantitative standards set by local authorities to certain items (e.g., infrastructure provision, affordable housing requirements, parking, design), and restricting their ability to set additional building performance standards beyond national building regulations (such as energy efficiency or carbon performance). The use of objectively assessed need” (OAN) is re‑introduced more clearly as the basis for quantifying housing requirements. It os considered that the draft aligns closely with the new Planning and Infrastructure Act, statutory authority this gives nationally but also locally.

Bioregional, corporate and built environment sustainability consultants in their article NPPF consultation 2025 – what's new? Describe the newly proposed PM13 as 'one of the most striking proposals' of the proposed NPPF. "Under PM13, local authorities would no longer be able to set energy efficiency standards beyond Building Regulations, except in very narrow circumstances." It also notes that "The consultation also signals the Government’s intention to amend the Planning & Energy Act 2008 to remove the explicit power for LPAs to set higher energy efficiency standards for dwellings. If enacted, this also seeks to change how local plans can drive climate action."

[edit] Suitable verses sustainable

The draft makes the argument to apply suitable as the presumption in favour of development which can be considered more systematically than the blanket presumption of sustainable as exists, varying with regard to location. Development within existing settlements should in effect normally be approved unless harm clearly outweighs benefits within the context of the national objectives, this extends also beyond a brownfield only approach. Outside of settlements, the argument is that well located sites that make efficient use of land and existing infrastructure are given stronger policy support, again with an emphasis on benefits versus clearly evidenced harm.

The term suitable is pushed yet further when housing or mixed-use sites near infrastructure nodes such as railway stations are considered with in effect potentially default permission being granted. Furthermore such granted developments are indicatively being requested to meet a mandatory minimum density of 40 dwellings per hectare (dph) near stations with this increasing to 50 when they are well-connected.

The use of suitable development further extends to smaller sites and extensions referred to as gentle densification through infill sites, end or corner plots and roof spaces which will be favoured on the proviso other key aspects are met. Note that at this scale a number of the exceptions to affordable housing, biodiversity net gain and so on mention above are likely to also apply.

The previously tinkered definitions and remits for grey belt to low quality green belt land are further formalised with in this framework. Grey belt (land within or adjacent to the Green Belt that makes limited contribution to its core purposes) is more clearly defined, with streamlined wording aimed at distinguishing high performing and low performing Green Belt parcels. Clarification is made that unsuitable, unsustainable development should not be taken forward on grey‑belt land, but at the same time it is made easier to justify development on lower performing land where this might secure housing, infrastructure or regeneration benefits.

While the “very special circumstances” test for inappropriate development in the Green Belt remains, the framework gives more direct policy routes for allocating and determining certain forms of development without relying solely on that test, particularly in identified grey‑belt locations. Local Nature Recovery Strategies (LNRS) and wider environmental objectives are more explicitly tied into Green Belt and grey‑belt decisions, reflecting “golden rules” for release and guidance promised for early 2025 and carried through into the draft.

On 24 February CIEEM noted that "Through further analysis of the proposed changes, we have also seen a notable shift in the overarching objective of the framework compared to previous iterations, from sustainable development to economic growth. It is this shift that is perhaps the most worrying for nature, casting a shadow over the rest of the policies within, even those that are or could be, in isolation, favourable to nature... The planning system must, of course, strike a balance between expansion and protection, but we believe this shift in focus risks tipping the scales disproportionately and unnecessarily in favour of the former, painting environmental concerns as a nuisance impeding short-term economic gain, rather than an essential and positive consideration."