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NPPF 2026 Review: Key Changes and Implications for Development

The August 2026 revised National Planning Policy Framework (NPPF) outlines the Government’s ambitions for plan-making, development delivery and long-term growth. The update introduces a range of changes that will influence how local plans are prepared, how development proposals are assessed and how planning authorities, developers and infrastructure providers will be working together to bring forward sustainable developments in the coming years.

While some of the outline reforms are already underway, new additions introduce requirements and expectations that will shape decision-making across the planning system. Understanding these changes and what they mean in everyday terms will be important for developers, promoters, landowners and local authorities as we all continue to plan, promote and deliver projects.

In this article, we explore some of the most significant changes introduced through the latest NPPF and highlight what they mean for development strategy, plan-making and project delivery in practice.

Streamlining the Planning System: Procedural Changes

As expected, the Government opened the new NPPF (2026) with changes to the plan-making and decision-taking processes, seeking to accelerate the pace of the planning system.

The most impactful of changes focus around:

  • Requiring Spatial Development Strategies to form part of the Development Plan
  • Limiting Local Plans to 10 measurable outcomes
  • Requiring strong justification for the production of Supplementary Plans
  • Restricting duplicating policies
  • Integrating the requirements and timescales of the new plan making system, including the critical 30-month timescale for Local Plans
  • More specifically citing the need for viability to be included in assessing the achievability of development allocations
  • Requiring a pragmatic approach to uncertainty about the future direction of other parts of the development plan or the plans of infrastructure providers, such as due to misaligned timings, plan making authorities
  • In lieu of a Duty to Cooperate, instilling a need to prepare, maintain and publish one or more statements of common ground to demonstrate that relevant cross-boundary matters have been addressed where possible
  • Requiring a more standard approach to publishing expected developer contributions and setting these at a level that allows for the planned types of development and sites to be deliverable, maximising certainty and reducing the need for viability assessment at the decision-making stage
  • A national standard for validation lists is provided in Annex C, although additional justifiable local requirements remain a possibility.
  • A firmer position on consulting statutory and internal consultees and delayed consultation responses
  • Reducing the ability for LPA’s to refuse consent on the basis of prematurity, with only specific limited circumstances
  • Reinforcing that viability should be considered largely at the plan-making stage rather than repeatedly revisited application by application
  • Referring to the use of national model conditions, increasing consistency across decision notices

While not contained within the NPPF (2026) itself, the new national scheme of delegation forms an important part of the wider planning reform package that sits alongside the Framework, with the same intention to streamline decision-making and improve planning performance.

 

Brookbanks View:

The early chapters of NPPF (2026) provide increased certainty around how planning decisions are made. Developers now have a more predictable, plan-led system that rewards sustainable and deliverable development. While the policy direction is broadly positive for growth, its success will ultimately depend on how consistently local authorities and inspectors apply the new Framework in practice.

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Further Favouring Sustainable Development

As previously consulted on, the NPPF (2026) now favours sustainable development being incorporated into decision-making, shifting the focus from needing to argue that an LPA’s housing policies were out of date, and moving towards a more overtly pro-development starting point.

Policy S3 directs decision-makers to the specifics of Policy S4 and S5 on how to apply the presumption based upon the location of a site inside or outside of the settlement. In doing so, this has necessitated a clearer definition of a settlement, which was not previously included within national policy:

“Settlement: Includes cities, towns, villages and other predominantly built-up areas, including land which is allocated or has permission for development which will form part of the built-up area once the development is complete. This includes areas defined as a settlement in the development plan (whether using defined settlement boundaries or equivalent terms, or criteria for identifying settlement extents where boundaries have yet to be defined). Settlements do not include hamlets and scattered groups of houses located outside predominantly built-up areas, unless specifically defined as a settlement in the development plan. For the purpose of this Framework they also exclude villages which lie within and are defined as part of the Green Belt in the development plan.” 

S4 introduces a default position that within a settlement (as defined above), the presumption in favour is in full effect and the policy shifts towards the more typical planning balance, as to whether there are specific harms that justify refusal.

Alternatively,  S5 maintains a similar approach to previous policy, whereby only certain exceptions are considered acceptable outside of the settlement and continues to seek to restrict speculative developments falling outside of these categories, specifically: agriculture, rural businesses, tourism, infrastructure, redevelopment of previously developed land, building conversions, limited infill, station-led development, allocated sites and schemes addressing identified housing or accommodation needs.

 

Brookbanks View:

The principle behind the presumption has shifted from a reactive mechanism, triggered when plans are out of date, to a more proactive policy in support of sustainable development. In theory, this should provide a stronger platform for well-located and deliverable schemes. However, the true impact will depend on how Inspectors, local authorities and the courts interpret the new presumption over the next few years, and we can expect a key appeal battleground to be in distinguishing how settlements are defined when there may be inconsistencies in maps, outdated local plans and particularly focusing on Policy S5(j) which is where speculative housing and logistics developments may find most success.

Placing Sustainability at the Top of the Agenda

“Chapter 5: Meeting the challenge of climate change” is s a significant strengthening of climate policy within national planning policy. The key shift is climate change is now a core principle of plan-making and decision-making.

Compared with previous national policy, Chapter 5 places much stronger emphasis on:

  • Net zero as a central planning objective.
  • Carbon reduction influencing spatial strategy choices.
  • Embodied carbon and resource reuse.
  • Energy retrofit and renewable energy receiving substantial weight.
  • Climate adaptation becoming a core development requirement.
  • Wildfire, overheating and drought being recognised alongside flooding.
  • Nature-based solutions and carbon sequestration being integrated into planning decisions.

For local plans, this means climate considerations are increasingly expected to influence where development goes, how it is designed, how it moves people, how it manages resources, and how resilient it will be throughout its lifetime.

Policy CC1 significantly strengthens the role of climate change in plan-making by requiring local plans to take a proactive approach to both climate mitigation and adaptation. Spatial strategies and site allocations are expected to contribute to radical reductions in greenhouse gas emissions, improve resilience to climate impacts such as flooding, drought, overheating and coastal change, and identify opportunities for nature-based solutions, green infrastructure and carbon sequestration. This represents a shift from climate change being a consideration within planning to becoming a key driver of spatial planning decisions.

CC2 places much greater emphasis on delivering net zero through development. New development is expected to support sustainable travel patterns, reduce the need to travel, improve energy efficiency, facilitate low-carbon heat and energy networks, encourage the reuse of buildings and materials, and protect or enhance natural carbon stores. Importantly, the policy requires substantial weight to be given to the benefits of energy efficiency improvements, retrofit, heat pumps and renewable energy installations, strengthening support for decarbonisation projects.

CC3 introduces a much stronger focus on climate resilience, requiring developments to consider future climate conditions over their lifetime rather than just the current risks. In addition to flood and coastal risk, the policy explicitly addresses overheating, drought, sustainable drainage, urban greening and wildfire risk. Substantial weight should also be given to proposals that improve the resilience of existing buildings and public spaces, reflecting the growing importance of climate adaptation within the planning system.

Additionally, PM13 continues to allow local authorities to set energy efficiency standards that exceed Building Regulations, as was previously the case; however, it now expressly requires any such standards to be set as a percentage improvement against the dwelling’s Target Emissions Rate (TER), calculated using a specified version of SAP or another approved methodology. In addition, any requirement that goes beyond Building Regulations must be supported by robust evidence and viability testing to demonstrate that it will not adversely affect the viability or deliverability of development. Similarly, for water efficiency, local authorities may apply the tighter optional Building Regulations standard where justified, or, in exceptional circumstances, adopt a more stringent local standard in areas identified as being subject to serious water stress.

 

Brookbanks View:

Chapter 5 is a significant shift towards a climate-led planning system, with net zero, resilience and sustainability central to both plan-making and development decisions. While developers will face greater expectations around energy efficiency, renewable energy, sustainable transport and climate adaptation, the Framework also provides stronger policy support for low-carbon development and infrastructure. Importantly, viability and deliverability remain key considerations, meaning climate ambitions must still be supported by robust evidence and realistic implementation strategies.

Continued Housing-led Development Focus

Policies S1 and HO2 retain the expectation that housing needs should be met as a minimum and continue to support higher housing requirements where justified by economic growth, infrastructure investment or unmet needs arising elsewhere. This reflects a clear intention to increase housing supply and align planning policy more closely with growth objectives.

More emphasis has also been placed on the sources of housing delivery. HO6 maintains the previous 10% minimum requirement for housing allocations to come from sites below one hectare and introduces a further 10% from sites between one and 2.5 hectares, reducing reliance on a limited number of large strategic sites. This could signal greater opportunities for SME housebuilders and medium-sized developments, albeit does not represent as strong measures many wished to see coming forwards and raises the question whether this NPPF (2026) goes far enough for the SME sector.

At the other end, the proposed wording of Policy HO4: Land for strategic site development, is a welcome acknowledgement of the realities of delivering major strategic sites. In particular, the reference to supporting access to services and employment opportunities “without expecting an unrealistic level of self-containment” reflects the fact that demand for local centres and on-site services does not always align with planning assumptions, allowing for a more flexible and deliverable approach to creating sustainable communities.

The most significant shift, however, is the increased focus on delivery rather than allocation. Whilst the 2024 NPPF encouraged authorities to monitor build-out rates, Policy HO13 embeds delivery more firmly within national policy, placing greater emphasis on implementation, infrastructure provision, phasing and realistic build-out assumptions. Strategic sites are now expected to be supported by clear delivery frameworks and credible routes to implementation.

Annex D, now incorporates the standard method directly within the NPPF (2026) rather than within the Planning Practice Guidance, as was the case under the 2024 Framework. It uses housing stock as its baseline and applies an affordability uplift, creating a stronger relationship between housing requirements and affordability pressures. At the same time, the consequences of under-delivery have become more closely aligned with decision-making. Under the Housing Delivery Test, authorities delivering below 75% of requirement are now deemed to have an evidenced unmet housing need for the purposes of Policy S5(1)(j), creating a clearer policy link between housing under-delivery and additional development opportunities than existed previously.

 

Brookbanks View:

The revised NPPF (2026) signals a move away from a planning system focused primarily on housing allocations towards one focused on housing delivery outcomes. The combination of the revised standard method in Annex D, stronger delivery expectations through Policy HO13, and the enhanced role of Housing Delivery Test performance is likely to place increasing pressure on authorities to identify and support genuinely deliverable sites. For landowners, promoters and developers, the greatest opportunities are likely to arise in locations facing increased housing requirements, affordability pressures or persistent delivery shortfalls, particularly where sites can demonstrate a realistic and timely route to delivery.

Affordable and Accessible Housing

The NPPF (2026) continues to place significant emphasis on delivering a wider range of housing needs, whilst increasing certainty around affordable housing provision and accessibility standards. Key Requirements include:

  • Clear affordable housing percentages and tenure mixes, including a minimum proportion of social rent
  • Fixed affordable housing requirements rather than negotiated ranges
  • At least 40% of homes on major developments to meet M4(2) accessible and adaptable homes standards

The move towards fixed affordable housing requirements provides greater clarity for all but it does potentially weaken the scope for negotiation through the planning process. Higher affordable housing requirements, particularly where a high proportion of social rented accommodation is required, have the potential to reduce scheme revenues and place downward pressure on residual land values. This reinforces the need for robust early-stage viability testing.

The strengthened focus on older persons housing, disability-led accommodation, build-to-rent, retirement living and specialist residential products is likely to create new opportunities for developers and investors operating within these sectors.

 

Brookbanks View:

The proposed changes may place additional pressure on viability assessments upfront, but they do also provide clarity around planning expectations and serve the intended purpose by Government to reinforce support for affordable housing delivery.

 

Continuation of Green Belt and Grey Belt Reforms

The NPPF (2026) continues the significant shift in Green Belt policy that began in December 2024. The aim of preventing urban sprawl remains, but the Government has moved towards a more proactive approach to identifying Green Belt land capable of accommodating growth. Through Policies GB2-GB4 and Annex E, local authorities are now expected to undertake formal Green Belt assessments and identify Grey Belt land using a consistent national methodology rather than the more varied local reviews that took place previously.

A clear example of this shift is the support afforded to development around well-connected railway stations through Policies S5(1)(h), GB3(4) and GB7(1)(h). Together with the density expectations in Policy L3, these policies indicate a clear Government intention to direct a greater proportion of future housing growth towards sustainable, transport-connected locations. For promoters and developers, this is likely to create a significant new focus on station-led growth opportunities, particularly where those sites are also capable of satisfying the Grey Belt criteria.

At the same time, the NPPF (2026) continues to balance additional development opportunities with the enhanced obligations established through the Golden Rules in Policy GB8. Enhanced affordable housing, infrastructure provision and publicly accessible green space remain key requirements, with substantial weight now attached to compliance in decision-making. As a result, the revised Framework may improve the prospects of certain Green Belt sites, but the policy expectation remains that development should deliver a greater level of public benefit than would typically be required on non-Green Belt land.

 

Brookbanks View:

The Green Belt debate is continuing to move away from whether land should be released and towards which Green Belt sites are most suitable to accommodate growth. The introduction of a formal assessment framework through Annex E, the continued prominence of Grey Belt policy and the strong support for development around well-connected stations provide a clearer and more predictable route for bringing forward certain Green Belt sites, whilst retaining significant delivery obligations through the Golden Rules.

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Transport Focus Shift to Sustainable Locations

The NPPF (2026) places further emphasis on vision-led transport planning in Policy TR1 and supports development in locations with access to sustainable modes of travel, both in the existing and proposed context. The status of the Connectivity Tool has also been increased, with the policy stating that it should be used to inform the assessment and selection of sites, alongside other relevant quantitative and qualitative evidence.

There is also greater acknowledgement of the role of mixed uses, across the plan area and within strategic sites, in minimising the number and length of journeys. An interesting addition is the opportunity for spatial development strategies and local plans to set thresholds for what constitutes a significant amount of movement arising from new development. It is unclear how the thresholds will be set and applied.

Consistent with the vision-led approach set out in TR1, Policy TR3 establishes five transport principles that development proposals should reflect, accounting for the vision for site, the type of development and its location. Again, it is stated that the Connectivity Tool should be used alongside other quantitative and qualitative evidence when assessing the connectivity of proposed development locations.

The five principles state that development which could generate significant movement should be directed to sustainable opportunities, and that opportunities to make effective use of existing or proposed infrastructure should be taken to optimise the amount and density of development. There is also a change in terminology for assessing development impacts and the need for mitigation, with the policy stating that any significant adverse impacts from development on the transport network, or on highway safety, should be “mitigated to an acceptable degree using a vision-led approach” The policy also recognises the specific context of rural areas, stating that “opportunities to improve connectivity should be taken where they exist and can be supported”.

Policy TR6 additionally gives more flexibility to the assessment of development proposals and reinforces the use of vision-led transport planning. Transport assessments, statements and travel plans should reflect the vision and wider transport strategy, with movement assessed proportionately to the type and scale of the scheme. Travel plans should also include fallback measures if initial proposals do not achieve the expected outcomes.

“Severe” remains the key refusal test for network impacts, but the policy shifts the focus from the road network to the wider transport network and expands the factors to account for. The policy states that “assessments should consider reasonable future scenarios, accounting for relevant times of day, cumulative impacts, sustainable travel and delivery of the vision”. Sustainable transport is also presented as an important way to address impacts, with measures that support sustainable movement patterns identified as appropriate mitigation. The test is also stated to apply both during construction and completion, giving greater emphasis on construction impacts.

In terms of key design considerations and standards, policies TR2 and TR4 function together to provide this framework. There is now more flexibility in setting maximum parking standards, no longer only acceptable with clear and compelling justification. Instead, maximum parking standards are encouraged and should be set where they will support encouragement of sustainable modes of travel and optimise density in well-connected locations. The criteria for setting local parking standards includes more emphasis on the location of sites, reducing vehicle parking requirements and opportunities for sustainable modes of travel. The policy also acknowledges the need to suitably plan for new forms of transport with standards needing to account for electric cycles and e-scooters.

 

Brookbanks View:

The NPPF (2026) is a positive step that strengthens vision-led transport planning and reinforces the importance of sustainable accessibility in shaping development. The enhanced role of the Connectivity Tool supports a more robust, evidence-led approach to site selection and appraisal, while increased recognition of mixed-use development and efficient use of infrastructure aligns with delivering sustainable growth. The updated policies provide greater flexibility in transport assessments and parking standards, shifting focus from highway capacity towards broader transport, place-making and sustainability outcomes.

There is uncertainty around how local authorities will define thresholds for “significant movement” but the overall direction is clearly stated. well-connected developments that support sustainable travel and are underpinned by a strong transport vision will be best placed to meet future policy expectations.

Brownfield Land and Efficient Use of Land

The NPPF (2026) continues the Government’s commitment to prioritising previously developed land but goes further than the 2024 Framework by placing greater emphasis on land optimisation and urban intensification. Through Policies L1-L3, the NPPF (2026) seeks to maximise the contribution of brownfield land towards meeting development needs, whilst encouraging authorities to make more effective use of underutilised sites within existing settlements.

A key change from the 2024 NPPF is the much stronger emphasis on density and urban intensification. The 2024 Framework promoted efficient land use, but the 2026 NPPF clearly outlines that development should optimise site capacity. Policy L1 requires authorities to identify opportunities for redevelopment and intensification on sites of all sizes, whilst Policy L3 establishes a presumption that residential and mixed-use development within settlements should increase density unless there is a clear justification otherwise. The Framework also introduces minimum density requirements around well-connected stations, reinforcing a shift towards higher-density development in sustainable locations as a means of maximising housing delivery and reducing pressure on greenfield land.

The policy direction in the NPPF (2026) places greater emphasis on making the most efficient use of land, with redevelopment, intensification and higher-density development expected to play an increasingly important role in meeting development needs. Whilst the 2024 Framework promoted the effective use of brownfield land, the NPPF (2026) embeds land optimisation and higher densities as core policy objectives. Through Policies L1 and L3, the emphasis is now on ensuring the maximum possible contribution to meeting development needs.

 

Brookbanks View:

The revised NPPF (2026) strengthens the position of brownfield and underutilised sites, particularly those located within settlements or in highly connected locations. For developers and landowners, opportunities are increasingly likely to arise not only through traditional brownfield redevelopment but also through the intensification of existing urban landholdings, estate regeneration projects and sites capable of accommodating higher densities. However, the stronger emphasis on efficient land use is also likely to result in increased scrutiny of schemes that fail to optimise site capacity.

 

Development Viability and Developer Contributions

Policy DM5 reinforces that viability should be considered largely at the plan-making stage rather than repeatedly revisited application by application. DM5 strengthens the approach that developments complying with adopted policy requirements are viable, placing greater emphasis on robust evidence during local plan preparation and reducing scope for post-purchase viability challenges.

DM5 also makes it clear that land values and option agreements are not justification for reducing policy compliance. This should encourage greater discipline in land acquisition strategies and more realistic assumptions around affordable housing and infrastructure contributions. For developers and landowners, the focus should shift towards understanding true development costs, risks and constraints before land transactions are completed.

In contrast, Policy E1 reflects a much more proactive approach to economic growth, requiring planning authorities to actively support investment, modern industries and strategically important sectors. It recognises the changing nature of the economy by specifically referencing uses such as data centres, laboratories, gigafactories, logistics facilities and digital infrastructure, helping ensure planning policy keeps pace with business demand.

From a development perspective, the policy should provide greater certainty around the allocation of employment land and supporting infrastructure. Importantly, it also recognises that barriers to growth are often linked to wider issues such as housing delivery, utilities capacity and transport infrastructure. This more integrated approach could help unlock development opportunities that have historically been constrained by infrastructure limitations rather than market demand.

In Policy DP3, design quality is much more central to the decision-making process. Whilst good design has long been a core planning objective, the DP3 introduces a clearer framework covering liveability, climate resilience, nature, movement, built form, public space and identity. This provides applicants and decision-makers with a more structured basis for assessing what constitutes a well-designed development.

 

Brookbanks View:

From a cost and commercial perspective, we predict there will be an increased expectation on schemes to demonstrate value beyond standard compliance for planning requirements. Development proposals will need to show how they contribute to placemaking, sustainability and long-term community outcomes. While this may increase upfront design and coordination requirements, it should provide greater certainty by setting out more clearly the characteristics that planning authorities expect successful schemes to deliver.

View of a power plant with smoke emissions under a cloudy sky, depicting industrial energy production.

New Water and Renewable Energy Policies

Policy W1 unsurprisingly elevates energy and water infrastructure to a strategic planning priority. W1 encourages plan-making that anticipates future energy and water demand, supports the transition to net zero, improves water efficiency and resilience, and ensures sufficient infrastructure capacity is planned alongside growth. The policy is working towards integrating resource security and climate resilience more directly into local plans and development strategies. In some parts of the country, demonstrating sufficient electricity and water capacity could be extremely difficult and could be a significant hurdle for some rapidly growing or particularly constrained areas.

Additionally, policy W4 strengthens the planning framework for water supply, wastewater and wider water infrastructure, recognising increasing pressures from growth, climate change and water scarcity. W4 places greater emphasis on water efficiency, resilience, infrastructure capacity and long-term adaptation to drought and flood risk, helping to ensure that development is aligned with sustainable water resource management. There is limited scope for developers to influence this, with the management of networks largely the responsibility of water companies. It is more likely that reduction of water demand will be used to demonstrate the protection of existing networks, with the implementation of either on-plot or communal greywater harvesting likely to have the biggest impact in the medium term.

The NPPF (2026) further strengthens support for renewable and low-carbon energy generation, and the infrastructure needed to connect it to the grid. It looks to promote technologies that help offset the impact of new development on the grid, encouraging further the use of renewable generation and energy storage to support decarbonisation. It also provides stronger support for individual renewable energy proposals and associated network infrastructure. Compared with previous policy, there is a clearer presumption in favour of renewable and low-carbon energy developments where impacts can be appropriately addressed, reflecting the increased importance of clean energy generation, storage and transmission in meeting national climate targets.

 

Design Quality and Well-Designed Places

The NPPF (2026) makes design quality a key requirement of the planning process and whether a development is approved. The Framework requires all proposals to respond positively to their context while supporting innovation, sustainable growth and higher-density development where appropriate.

The policy is structured around seven core design principles:

  • Liveability
  • Climate
  • Nature
  • Movement
  • Built Form
  • Public Space
  • Identity

A key update is planning applications could now be refused where they fail to meet these principles, local design codes or adopted design standards without clear justification. On the flip side, significant weight will be given to schemes that demonstrate outstanding or innovative design, particularly where they improve sustainability or raise design standards within an area.

 

Brookbanks View:

The NPPF (2026) outlines that good design is no longer optional, as Planning authorities are being given greater justification to refuse poor-quality schemes while actively supporting developments that deliver exceptional design, sustainability and placemaking outcomes.

For clients, successful development will depend on embedding design thinking from the earliest stages of site promotion, masterplanning and feasibility work. Those who invest in high-quality, design-led development are likely to be best placed to navigate the planning process, secure consent and create places that deliver long-term value.

Flood Risk and Sustainable Drainage

The NPPF (2026) also places stronger emphasis on addressing flood and coastal change issues at the plan-making stage, with Local Plans expected to be supported by up-to-date Strategic Flood Risk Assessments that consider both current and future climate-related risks. It also reinforces the need to take account of advice from the Environment Agency and other flood risk management authorities.

For developers and landowners, the practical point is that flood risk constraints should be understood at the allocation stage rather than left until application. Future climate change effects and wider consequences of flooding are likely to feature more prominently when authorities decide which sites should come forward.

Policy F3 significantly strengthens the plan-making approach to coastal change. Coastal Change Management Areas will need to take account of Shoreline Management Plans and the National Coastal Erosion Risk Map, cover relevant estuaries and tidal rivers, and consider risk over a 100 year period.

For coastal development, this means a longer-term view needs to be taken when assessing land. Sites which may not appear constrained today could still be affected by future erosion or coastal change and may therefore require a different development strategy or be unsuitable for certain uses.

F4 brings the requirements for site-specific Flood Risk Assessments into one clearer policy and directly references the Flood Map for Planning. It largely consolidates existing requirements which were previously spread between the 2024 NPPF and its footnotes. The important development point is that Flood Zone 1 should not automatically be treated as meaning there is no flood risk issue. Surface water, groundwater, ordinary watercourses and future flood risk need to be considered where relevant. Therefore, early flood risk appraisal remains important even where there is no mapped fluvial or tidal constraint.

One of the most useful changes from a development perspective is, Policy F5 as it gives much clearer guidance on when a Sequential Test is and is not required. Where surface water flooding is the issue, a Sequential Test may not be required if a site-specific FRA can demonstrate that the layout, design and mitigation will keep the development safe for its lifetime.

This should help sites where mapped surface water flooding affects a relatively limited or manageable part of the land. Rather than automatically creating a wider alternative sites exercise, there is greater opportunity to resolve the risk through masterplanning, levels, drainage design and exceedance routing.

F5 also clarifies that the geographical area used for a Sequential Test should reflect the likely catchment of the development’s occupiers or users. This should help prevent unnecessarily wide search areas being applied moving forward.

Also helpfully, Policy F6 brings the Exception Test into a clearer standalone policy and links it directly with the flood risk vulnerability classifications now included within the draft NPPF (2026) itself. This is a useful change as allocated sites which have already passed the Exception Test during plan making should not normally have to repeat the exercise at application stage unless flood risk has materially increased or a more vulnerable use is subsequently proposed.

Policy F7 sets out a clear management test that a development must remain safe throughout its lifetime and must not increase flood risk elsewhere. Where the criteria cannot be met, the policy is explicit that the development should be refused.

With a greater focus on how schemes actually function during flood events, finished levels, safe access, residual risk, exceedance routes and the location of vulnerable uses will all need to work together to demonstrate that a drainage system can accommodate a design storm.

One of the most important changes for drainage design is that going beyond the well trodden path of expecting SuDS to be provided, crucially, those systems should now be designed in accordance with the National Standards for Sustainable Drainage Systems.

One of the most important changes for drainage design is that going beyond the general expectation for SuDS to be provided, crucially, those systems should now be designed in accordance with the National Standards for Sustainable Drainage Systems. This will push drainage further into the front end of masterplanning. The National Standards place emphasis on managing water close to source, water quality, biodiversity, amenity, climate resilience and long-term maintenance. F8 also introduces stronger policy against enclosing watercourses and supports de-culverting and re-naturalising river channels.

Policy F9, strengthens the controls applied to developments at risk from coastal change. Importantly, sites identified as being at risk on the National Coastal Erosion Risk Map will be subject to the same tests as sites within formally designated Coastal Change Management Areas, even where the local authority has not yet incorporated them into one. The policy also makes it explicitly clear that permanent new residential development, including through change of use, is inappropriate within these areas.

The key consequence is that developers should not rely on the current Local Plan designation when assessing coastal land. National erosion mapping and long-term coastal change will need to be considered at the earliest appraisal stage, particularly where a site’s future depends on continued coastal defence.

 

Brookbanks View:

Flood risk, drainage and climate resilience are becoming key planning and site selection considerations not just application-stage technical matters. Much of the NPPF (2026) consolidates and clarifies existing requirements, but emphasis on early assessment, integrated masterplanning and compliant SuDS design should now provide greater certainty for well-planned sites. Developers who identify flood constraints early, embed blue-green infrastructure within their proposals and demonstrate a clear strategy for long-term resilience will be best placed to navigate policy, and have successful site promotion and delivery.

Top view of vibrant foliage and winding paths in a park in Curitiba, Brazil.

Nature Recovery, Biodiversity and Green Infrastructure

In the NPPF (2026), nature recovery is now an integral part of new developments, moving from avoiding harm to actively contributing to environmental improvement. While biodiversity net gain (BNG) remains a statutory requirement, the NPPF (2026) provides guidance on how developments should support wider ecological networks, biodiversity enhancement and nature recovery objectives.

Key changes from the previous 2024 NPPF are:

  • New requirement for development proposals to strengthen and connect ecological networks beyond the site boundary.
  • Greater emphasis on conserving and enhancing existing natural features such as established trees and hedgerows.
  • Explicit requirement to use green infrastructure and nature-based solutions to deliver multiple benefits including biodiversity, drainage, climate resilience and recreation.
  • New expectation for developments to incorporate integrated nest boxes (swift bricks) unless there are compelling technical reasons not to do so.
  • New requirement for new streets to be tree-lined unless there are strong reasons why this would be inappropriate.
  • Clear statement that local plans should not generally require biodiversity net gain above the statutory level, except for specific site allocations where a higher requirement is justified and deliverable.

 

Brookbanks View:

Nature recovery measures should be incorporated from the earliest stages of site design and master planning. New residential developments will be expected to include features such as integrated swift bricks, tree-lined streets, and multifunctional green infrastructure that delivers biodiversity, drainage, climate resilience and recreational benefits as mentioned above. Developers will also need to demonstrate how proposals contribute to wider ecological networks and nature recovery objectives beyond the site boundary, rather than focusing on just achieving statutory biodiversity net gain requirements.

The NPPF (2026) also provides more certainty for developers by confirming that local authorities should not generally require biodiversity net gain above the statutory level unless this can be specifically justified for an allocated site, helping to reduce viability risks and promote consistency across planning authorities.

 

Protected Landscapes and Heritage Protection

The NPPF (2026) largely retains the strong protections previously given to National Parks and National Landscapes, but it does introduce clearer wording and a more structured heritage framework. Heritage policies have been reorganised and expanded, providing greater clarity on assessments, significance and decision-making.

Key changes for Protected Landscapes:

  • The policy now explicitly states that major development within Protected Landscapes should be refused except in exceptional circumstances and where it is demonstrably in the public interest.
  • Greater emphasis is placed on conserving and enhancing natural beauty, wildlife and cultural heritage.
  • Additional reference is made to mitigating effects on special qualities such as tranquillity and dark skies where major development is exceptionally approved.

Key heritage changes:

  • Heritage assets must be conserved in a manner proportionate to their significance.
  • Applications affecting heritage assets must now be supported by proportionate significance and impact assessments.
  • The framework provides clearer definitions of positive effects, harm, substantial harm and total loss.
  • Harm to designated heritage assets must be weighed against public benefits, with examples included such as securing the reuse of vacant listed buildings.
  • The policy confirms that substantial harm to Grade I and II* listed buildings, scheduled monuments, registered battlefields and World Heritage Sites should be “wholly exceptional”.
  • Greater emphasis is placed on preserving archaeological heritage assets in situ where feasible.
  • New safeguards require decision-makers to ensure there is sufficient certainty that replacement development will proceed before heritage assets are lost or demolished.

 

Brookbanks View:

These changes strengthen existing policy rather than introduce any significant new constraints. Strong protections for National Parks, National Landscapes and heritage assets remain, but the NPPF (2026) should now provide greater certainty for assessment and decision-making. Success will depend on identifying landscape and heritage considerations early and embedding them within site appraisal, design and masterplanning. Early engagement with conservation officers and heritage consultants is likely to become even more important to reduce planning risk.

Summary of the 2026 NPPF Update

The NPPF (2026) is an evolution of the direction that national planning policy has been moving in, in recent years. In most cases, it reinforces areas where gaps have emerged and helps to accelerate policies that have been slow to make an impact, including housing delivery, sustainable development, climate resilience, infrastructure planning, design quality and place-making.

We can see there is a clear shift towards earlier consideration of constraints and opportunities, to create greater certainty at the plan-making stage and strengthen the emphasis on deliverability. For developers, landowners and promoters, the opportunities the NPPF (2026) creates are likely to be greatest where developments can demonstrate sustainable locations, realistic delivery strategies and clear alignment with wider policy objectives. In areas such as climate change, flood risk, infrastructure provision, design quality and environmental stewardship, these areas are being required to be integrated at the very earliest stages into site promotion, masterplanning and project delivery, rather than being addressed later in the planning process.

The overriding message we get from the NPPF (2026) is that developments will be assessed and accepted through planning on how well they contribute to the creation of sustainable, resilient and well-connected places. We’re pleased that there is greater clarity and a more structured framework for decision-making, with an increased emphasis on evidence-led planning, collaboration and long-term thinking, although some challenges surrounding deliverability remain.

Those that engage early with planning, transport, environmental, engineering and infrastructure considerations, and can clearly demonstrate deliverability alongside wider social, economic and environmental benefits, will be best placed to maximise market opportunities and bring forward successful developments.

 

If you would like to have a chat about how the NPPF (2026) impacts your development or how you can be best prepared for application, reach out to Annabel Le Lohe, our Associate Director for Planning, or any of our specialists team members.

Annabel Le Lohe, Associate Director at Brookbanks
Associate Director

Annabel Le Lohé

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Ben Wakeling, Head of Cost and Commercial at Brookbanks
Head of Cost and Commercial

Ben Wakeling

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Dean Swann, Group Technical Director at Brookbanks
Technical Director, Land, Development and Communities Group

Dean Swann

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Sustainability Director

Katie Glaze

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Melanie A'Lee, Director of Transportation and Highways at Brookbanks
Director of Transportation and Highways / Head of Eastern Office

Melanie A'Lee

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