Comment

What the NPPF’s key changes mean for housing, growth and plan-making

This piece offers an overview of key changes in the draft NPPF published for consultation in December 2025 and examines what they may mean in practice, focusing on central themes within housing, growth and plan-making. Deeper dives into housing and economic growth, alongside aspects of the wider thematic chapters, will follow.

So what has changed?

Well, quite a lot and not that much. The document has a completely new look and feel including being arranged as numbered policies rather than paragraphed prose, while much of the content is very familiar. I would liken it to your favourite car getting a snazzy new look and a few new features, while retaining much of what you know and love.

Making a welcome return is a summary of the purpose of the planning system. This includes statements at the start of each chapter – albeit it’s made clear that these are not to be read as policy. The Ministerial foreword to the 2012 version had something similar but this was lost in later iterations.  

Together, these statements provide useful context to the Government’s intended direction of travel. You may be curious to see what it looks like if the contents of those introductory statements were drawn together into a single summary. Well, for those interested – we have done so. Here it is: Inside the draft NPPF: Government intentions at a glance.

Presumption

The purpose of planning is still to achieve sustainable development. This retains familiar economic, social and environmental objectives; and there is still a presumption in favour of it. So far so good.

The presumption as it currently applies to plan-making is no longer called a "presumption" but the requirement for plans to meet their development needs remains (Policy S1).

For decision-making, the presumption has been adapted and helpfully expanded to apply to sites within settlements and those outside them. There is a new definition of "settlement" in the glossary. In essence cities, towns and villages are settlements; hamlets are not. Expect debate (and possibly litigation) concerning the differences between a village and a hamlet.

The changes include mechanisms for the well trailed "default yes" for development of brownfield sites and sites within walking distance of train stations with decent connections to jobs and services. The latter promises to be particularly powerful given it will apply irrespective of whether a site is brownfield, greenfield, grey belt or Green Belt, and addressing ‘unmet need’ is a route to the presumption. 

There is also (defined) scope for proposals outside settlements to benefit from the presumption, but where they don’t there is a strengthening of the presumption against – ‘exceptional circumstances’ being applied in a manner we have not seen before.

A new spatial dimension

Another first in this NPPF is policy for spatial development strategies (SDS) which are given effect by the Planning and Infrastructure Act. These are in essence multi-authority strategies for investment and growth. They will make the big decisions about how much development is to be provided; the apportionment of it to individual authorities; the strategic infrastructure needed to deliver it; and areas that should be protected and conserved.  

It is important to note that these will be very high-level frameworks. Think Structure Plans (for those old enough to remember them). SDS will stay well clear of allocating sites and establishing or reviewing protective designations but should provide guidance on the broad locations for major developments such as new settlements. Site allocations will be for new Local Plans to take forward within the overall parameters of an SDS.

Importantly, the draft NPPF (Policy PM1) confirms that it is the SDS that will determine requirements for housing, employment land and other development.  Once these are decided, Local Plans will not revisit these requirements.  

This will place an imperative on the industry to engage with and present evidence to the early stages of SDS preparation to ensure clear and robust evidence of market needs and deliverability to inform the vision and spatial frameworks of the SDS. It has the potential to significantly streamline the evidence gathering and time taken at Examination to resolve these often vexed questions. 

Soundness

The soundness tests are given something of a makeover. Slightly different tests will apply to SDS and Local Plans. The key difference being that in addition to consistency with national policy Local Plans have to conform to SDS.

There is some rewording of the tests themselves, but arguably to reflect how Inspectors have applied them in practice and to underline recent calls on the Inspectorate to adopt a pragmatic approach that supports full plan coverage.

On the theme of pragmatism there is a very welcome proposed addition (Policy PM14.3) which allows Inspectors to use "reasonable assumptions" about the delivery of infrastructure in the later stages of the plan period. This addresses practical problems experienced in bringing forward long-term projects and will be a huge help to plans that rely on larger allocations or new settlements to meet their needs.

Transitional provisions

NPPF maintains the transitional provisions in the December 2024 Framework, so while new plans will proceed under the 30-month system there will continue to be many emerging plans to be examined under the 2024 and 2023 versions of NPPF (so don’t erase those paragraph numbers from your memory just yet).

Development management

After the debate around whether national decision-making policies (NDMP) should be statutory or non-statutory was settled in favour of the latter there was concern about how effective they could be. Perhaps in response to this the draft (Annex A paragraph 2) is unequivocal. The policies apply as soon as final NPPF is published and "development plan policies which are in any way inconsistent with the national decision-making policy ..…. will be given very limited weight" (unless they've been examined in light of this NPPF).

The underlining makes the intention very clear: the NDMPs are to take precedence over existing DM policies in (even up to date) development plans.

There is also welcome clarity in relation to any future local plan DM policies. Local plan policy should not "duplicate, substantively restate, or modify the content of" NDMPs (PM6c). This phrase is repeated in the tests of soundness (PM14d and PM15d) and we can expect Inspectors to be vigilant for attempts to impose more stringent local policies.

The draft emphasises the move forward to national consistency. It requires that quantitative standards set through development plans should be limited to "infrastructure provision, affordable housing requirement, parking, and design and placemaking". There is also explicit preclusion of policies on matters covered by Building Regulations (with the exception of accessibility and water efficiency) and the internal layout of buildings.  

These are welcome efforts to achieve clarity and consistency of expectation at national level and should help to shorten and simplify plan-making. Once an SDS has done the heavy lifting on development requirements and strategic distribution and NDMPs are in full effect, we begin to see how cutting the average time taken to prepare a local plan from the current 7 years to an ambitious 30 months might just be achievable. 

A new decision-making rubric

To give effect to its ambition to stimulate economic growth and housebuilding the Government has sought to bring additional clarity on the weight to be given to certain factors (positively and negatively) in decision-making.

The baseline remains that development that accords with the development plan (and now the NDMPs) should be approved without delay. Individual policies indicate where additional weight should be placed on certain objectives.  In doing so there has been some "tidying up" of phraseology.  

Terms such as "significant" and "great" weight have largely been replaced by "substantial" weight.  Let us hope we don't go down the rabbit hole of whether "substantial" is more weighty than "significant". The point is that these identify objectives to which particular importance is attached. Examples include:

• the benefits of meeting housing needs (Policy HO7)
• economic benefits of business growth and domestic food production (Policy E2)
• supporting the viability and vitality of town centres (Policy TC2)
• the benefits of energy security and moving to net zero (Policy W3)
• providing new and improved public service infrastructure (Policy HC4)
• conserving protected landscapes (Policy N4) and
• protecting designated heritage assets (Policy HE6).

There are also attempts to make more explicit the "limited circumstances" where permission should be refused including where this would override the presumption in favour of development. These include:

• significant impact on a town centre (Policy TC3.4)
• not making efficient use of land (Policy L3.4)
• poor design (Policy DP3.2)
• development at risk of flooding (Policy F6); and 
• significant harm to biodiversity or irreplaceable habitats (Policy N6).

Conclusion

In conclusion, a welcome update and remodelling. The opportunity has been taken to emphasise what the Government believes to be most important and to align policy with its pro-growth agenda.  

With the exception of a few well-trailed additions, the contents are largely familiar – albeit with adjustments to address areas of practice that have held up plan-making and decision-taking.  

Some of the new sections lay the ground for the introduction of SDS and the new streamlined local plans. Others give effect to promised policies on “brownfield passports” and making the most of sites close to well-connected railway stations. 

As would be expected, there are areas where further clarity and adjustment may be helpful. The consultation offers the opportunity for our industry to make the case for these. Turley will be considering representations and delighted to help others with theirs.

Contact Dave Trimingham if you would like to discuss implications for particular projects or topics.

22 December 2025