NPPF 2026: What It Means for Developers

What the NPPF is and how the 2026 version works

The NPPF does not replace the local plan. Planning law says applications must be decided in line with the development plan, "unless material considerations indicate otherwise". Chapter 1 calls the Framework "a material consideration of critical importance". In practice, the local plan is read first and the NPPF decides how much weight its policies get.

The 2026 version looks different. Paragraphs are now numbered within each policy, not in one run through the document. It has 20 chapters and six annexes, and each policy has a code. These are the ones a developer meets most often.

Each chapter splits plan-making policies from decision-making ones. Paragraph 8 of Chapter 1 is clear: "the plan-making policies should not be used when making decisions on development proposals". On an application, only the decision-making policies count.

The Framework applies to England only. Scotland, Wales and Northern Ireland have their own national planning policy.

The presumption in favour and five-year supply

Policy S3 keeps the presumption in favour of sustainable development, but splits it by location. Inside settlements, policy S4 applies. Outside them, policy S5 applies. Anywhere, a scheme that meets an up-to-date plan and the Framework "should be approved without delay".

S4 is the most important line for urban sites. Development within settlements "should be approved unless the benefits of doing so would be substantially outweighed by any adverse effects". The burden sits on the harm, not on the scheme. A settlement includes towns, cities and land already allocated or permitted to become part of them.

S4 lists when harm is likely to win. It names a substantial adverse impact on land allocated or safeguarded for another use, or on Local Green Space. It also names failing a national policy that says to refuse.

Outside settlements, S5 allows only listed forms of development. For developers, these are the useful ones:

1. Previously developed land. Redevelopment, including a change of use to homes, under S5(1)(d).
2. Existing buildings. Reuse, extension or a like-for-like replacement under S5(1)(c).
3. Station sites. Homes within reasonable walking distance of a well-connected station under S5(1)(h).
4. Unmet need. Schemes meeting an evidenced unmet need, well related to a settlement, under S5(1)(j).

The five-year supply now feeds into S5(1)(j). If a council cannot show five years of deliverable sites, that counts as unmet need for housing. Annex D sets the Housing Delivery Test consequences.

There is a safeguard in Annex A. A council with a five-year supply and a test result above 75% is protected for five years after adopting its plan. A higher standard method figure alone is not then evidence of unmet need.

Grey belt and Green Belt changes

The core Green Belt rule sits in policy GB6. It says inappropriate development "should not be approved except in very special circumstances". What matters is the list in GB7 of development that is not inappropriate.

Grey belt is defined in Annex B. It covers Green Belt land that is previously developed, and other Green Belt land. In either case, the land "does not strongly contribute to any of purposes (a), (b), or (d)" in policy GB2. Those purposes are checking sprawl, stopping towns merging and preserving historic towns.

A grey belt scheme is not inappropriate under GB7(1)(g) if all four tests are met:

1. The land is grey belt. It must not fundamentally undermine the purposes of the remaining Green Belt across the plan area.
2. There is an evidenced unmet need. For homes, that means no five-year supply, or a Delivery Test result below 75%.
3. The location is sustainable. The test points to the transport policy, TR3.
4. Major housing meets GB8. These are the Golden Rules.

GB7(1)(h) adds a second route: homes near a well-connected station. The glossary sets the bar at four trains or trams an hour overall, or two in one direction, in the daytime. Reasonable walking distance is "around 800 metres".

The Golden Rules apply to major housing in the Green Belt or on land released from it. Major means 10 or more homes, or a site of 0.5 hectares or more.

The Golden Rules also need infrastructure improvements and new or better public green space. Footnote 43 exempts sites released through plans adopted before 12 December 2024 and permissions granted before that date.

Brownfield land, density and building upwards

Policy L2 gives "substantial weight" to the benefits of brownfield schemes. An officer has to put that weight into the planning balance.

L2(1) lists four kinds of scheme that earn that weight:

1. Remediation. Cleaning up despoiled, derelict, contaminated or unstable land.
2. Vacant and underused space. Empty homes, space above shops, old retail and business sites, car parks and lock-ups.
3. Temporary uses. Using previously developed land until a planned scheme is ready.
4. Airspace and infill. Extra homes above buildings, mansard roofs, filled gaps in a roof line and taller corner buildings.

The glossary defines previously developed land tightly. Residential gardens in built-up areas are excluded, and so are agricultural buildings. Land where the old structure has blended into the landscape no longer counts either.

Infill in a garden is still possible under L2(1)(d)(iii), within limits. It must not occupy "more than twice the footprint of all the existing buildings on the site". At least 50% of the undeveloped part of the curtilage must remain. For upward schemes, see our airspace development guide.

Density is a test with teeth. Policy L3(2)(c) sets at least 35 dwellings per hectare near a well-connected station. That rises to 45 where trains run at least twice the minimum frequency. L3(4) is blunt: proposals that do not use land efficiently "should be refused".

Viability and affordable housing tests

Policy DM5 starts from a fixed point. Where proposals accord with up-to-date plan and national policies, "they should be assumed to be viable". A viability assessment is the exception, and it has to earn its place.

DM5(2) lists when an assessment may be justified:

• The scheme is materially different from the types the plan's viability study tested.
• The site is materially different from those the plan assumed.
• The scheme carries costs the plan's study did not take into account.
• Site or economic conditions have changed significantly, meaning a recession or similar shock.

DM5(3) closes a common argument. "Neither the price paid for land, nor the price intended to be paid through an option agreement" justifies missing policy. Overpaying for a site does not buy a lower affordable housing figure. Every assessment should follow the guidance inputs and be made public.

Policy HO8 sets the affordable housing test. A scheme should meet or exceed the plan's proportion and tenure mix, including Social Rent. Delivery is on site, unless off-site homes would be better or a cash payment can be "justified robustly".

Two points help developers. Where a scheme reuses a vacant building, the contribution falls in proportion to the existing gross floorspace, under HO8(4). Abandoned buildings do not qualify. Under HO8(3), a policy-compliant scheme gets flexibility on bedroom numbers in its market homes.

The safest viability case is a scheme costed before it is drawn. At Allitsen Road in St John's Wood, a vacant corner building became four costed schemes with a planning strategy in four weeks. For the obligations themselves, see CIL and Section 106 explained.

How officers use the NPPF on your application

An officer's report usually follows the same order. It reads the scheme against the local plan, then weighs the NPPF policies that apply. Then it states the planning balance. Knowing the codes lets you answer each test in the planning statement before the officer raises it.

Chapter 3 sets the rules for the process:

1. DM1, preparing the scheme. Major schemes should engage early and submit "a concise planning statement" covering policy, engagement and planning obligations.
2. DM2, information. Validation lists should ask only for what national or local policy requires, in proportion to the scheme.
3. DM3, determining it. Councils should work positively, consult only where necessary and "not refuse applications for development which should clearly be approved".
4. DM4, prematurity. Refusal because a new local plan is coming is allowed only in narrow cases.
5. DM6, conditions. Each condition must be necessary, relevant, precise and reasonable. Pre-commencement conditions should be avoided without clear justification.
6. DM8, enforcement. Development found to be intentionally unauthorised gets "substantial weight" against a retrospective application.

Housing schemes gain from HO7. It gives "substantial weight" to the benefits of homes that meet evidenced local needs. Under HO13(2), officers may also consider a shorter time limit to start work.

If the council refuses, the Inspector applies the same policies. A statement built around them is also the start of a strong planning appeal. The full route to a decision is in our guide to the planning permission application.

What the NPPF means for London sites

The Mayor of London prepares London's spatial development strategy, the London Plan. Under policy HO2, a spatial development strategy should set the housing requirement for each authority in its area, which in London means each borough. Borough local plans then plan for that level. An officer weighs the London Plan, the borough plan and the NPPF together.

Most London sites sit inside a settlement, so S4 applies. The question for a London scheme is rarely the principle. It is the harm: heritage, daylight, density, design and affordable housing. Chapter 20 and the statutory duties for listed buildings and conservation areas apply on top.

1. Test density first. Near a well-connected station, L3 sets a floor, not a ceiling.
2. Use L2 openly. Upward extensions, mansards and underused car parks earn substantial weight.
3. Check the borough's supply. It matters for any site at the edge of the Green Belt.
4. Raise issues at pre-application. Pre-application advice shows how officers read S4 locally.

Our Development Director, Rob Barton, took 10,000+ homes through planning in his previous roles. Holding a London site, or one elsewhere in England? Send us the address and get a free site appraisal. You will know whether grey belt, density or building upwards works for it or against it.