A SWOT analysis of the August 2026 National Planning Policy Framework

A new look, with material weight 

Before we delve into some specifics, it is worth a brief nod to some of the overarching amendments. Perhaps most notable of these is the new style. Gone are the old paragraph numbers and instead each section starts with a relevant objective, followed by a set of numbered policies. 

Each policy being delineated so clearly should aid navigation, particularly for a document that is promoted as being clear and rules based. 

But the changes are much more than cosmetic. For almost every topic there are now policies clearly aligned to plan making, and separate policies for decision making. Although the government did not introduce statutory National Development Management Policies, the NPPF is arguably the closest policy equivalent. The national decision-making policies in the NPPF are a material consideration when determining planning applications and the NPPF further states that any local plan policies which are “materially inconsistent” with the NPPF policies should be given “very limited weight”, unless they have been examined and adopted against the NPPF – in which case they should be consistent anyway. 

This results in a clear centralisation of policy making power and means not only that the NPPF has real teeth in terms of decision making but also that there should be greater predictability for applicants in respect of the key matters set out in the document. 

Geographical distinctions and the new “universal tilt” 

The new document provides a key evolution in terms of the presumption in favour of sustainable development, which now differentiates how it applies to development within and development outside settlements (which are defined to include cities, towns, villages and other predominantly built-up areas), although in all locations, proposals which accord with an up to date development plan and the NPPF should be “approved without delay”.  

If the proposal is within a settlement, policy S4 states that it should be approved unless the benefits would be substantially outweighed by any adverse effects, with examples of when that might be the case. 

In comparison, if a proposal falls outside a settlement, policy S5 states that only certain forms of development should be approved - although the list is actually quite broad including, for example, previously developed land, development for agriculture or rural businesses including tourism, and the reuse or replacement of buildings. Again, this applies “unless the benefits of doing so would be substantially outweighed by any adverse effects”. However, any development not on the (lengthy) list, should only be approved in exceptional circumstances, where the benefits of the proposal would substantially outweigh the adverse effects, including to the character of the countryside and in relation to promoting sustainable patterns of movement. 

At its core, this policy reflects that “default yes” to development that Labour keep referring to, which has since been upgraded to a “universal tilt” in favour of development, as per a letter from Matthew Pennycook on 6 October. It sets an emphatic and positive tone in favour of development from the get-go. 

A commitment to the grey belt 

It’s worth noting that policies S4 and S5 do not apply to proposals in the Green Belt; instead policy GB7 should be considered. Policy GB7 sets out the categories of development which are not inappropriate in the Green Belt, within which grey belt still gets a mention. The simplification of the definition of grey belt, as suggested by the 2025 consultation, removing list of specific types of protected areas and assets of particular importance which could not be grey belt from a footnote, makes the interpretation of what does constitute grey belt a bit simpler and reduces duplication.  

Whilst the fundamentals of the approach to green and grey belt have not changed, this in itself is a strength, not only because the development industry craves some consistency, but because it indicates an ongoing to commitment to the concept of the grey-belt, indicating that it is here to stay. 

But for all this clarity of both form and vision, there are a number of areas where the revised document fails to deliver for developers.

Mind the gaps

When the first NPPF made its way into the world, the intention was to simplify and cut back planning policy into a relatively light-touch, standalone document (albeit supported by the PPG). Over time that objective has been diluted, as the document has grown in length and the reliance on guidance to supplement the policy has increased. This iteration continues that trend despite the fact that it has grown considerably itself. Aside from the fact that this reliance on guidance requires cross reference to different sources, this also creates issues around predictability, given that guidance can be updated with far more speed, and far less transparency than the NPPF itself. 

The issues regarding reliance on guidance are further compounded when the relevant guidance does not yet exist…

The viability gap

Number one, in a long list of issues currently challenging most developers, is viability. The approach of the NPPF to viability was therefore always going to be of great interest. Fortunately, the final version abandons the approach suggested in the consultation of embedding standardised inputs into the Framework itself, but there are still plenty of other points to give developers pause for thought. 

The new iteration of the NPPF retains the base assumption of its predecessor that proposals which accord with relevant up to date policies should be assumed to be viable. Alongside this there is now a list of tightly framed examples of when a viability assessment may be appropriate, in each case requiring a demonstration that the assumptions underpinning the viability appraisal which informed the development plan no longer hold good. This places an onus on applicants to not only show that the numbers don’t stack up, but that there has been an acceptable change in circumstances which has caused this. 

Additionally, there is real consternation within the industry that key guidance relating to the assessment of viability is yet to materialise. Without this, not only is it difficult to truly assess the impact of the new NPPF as whole on development, but developers and LPAs alike are left shadow boxing the issue. It is highly unlikely that there is any form of guidance which can alleviate the viability problems facing projects up and down the country, but what it could do is provide clarity and some certainty. The absence of these only compounds an already difficult position. 

The importance of the SDSs

The introduction of Spatial Development Strategies (SDSs), facilitating planning at a regional level, is a clear priority of the current government, and so it is little wonder that they play an important role in the NPPF. There is also the potential for them to provide a real benefit for the development industry, providing a clear framework against which decisions should be made, informed by the priorities of the wider region.  

However, it’s likely to be a considerable time until there is significant SDS coverage and, until there is, local plans are left to carry much of the weight which should properly sit with SDSs as part of the new system. This means that for the short term many of the matters which should be approached from a broader strategic perspective will instead be set by through a local lens. At a more practical level, it also means that the promise of quicker, slimmed down local plans remains somewhat out of reach. 

Few in the development industry would dispute that times are tough, and many were pinning their hopes, at least in part, on the new NPPF to provide new opportunities to help kick start development. Given that the government is pinning a lot on development delivering economic growth, it’s not surprising that the NPPF goes some way to delivering on these, beyond just updating the now universal tilt. 

A broader view of need 

In various places, the new NPPF states that substantial weight should be given where a proposal will be satisfying an “unmet need”. The approach to this need is broad, going beyond just a need for housing, although the NPPF is clear that it does include housing, where there is no five year housing land supply. 

In a recent appeal decision, it was confirmed that this policy included meeting an unmet need for affordable housing, even though, in that case, there was no general housing need. This is therefore seen as a significant shift for housing schemes, given that in almost every corner of the country, there is an unmet need for affordable housing. The Framework is clear that the concept of need also includes homes for different groups, including older people, disabled people, families with children and students. 

For other types of unmet need, the Framework suggest that these could be demonstrated, for example, by an undersupply in the market. This means a far wider range of projects can now benefit from evidence that they are meeting unmet demand.

Delivering density 

Another key potential opportunity for developers lies in the approach to density. 

After first requiring LPAs to identify ways to accommodate as much unmet need as possible, and encouraging the setting of minimum residential standard for certain locations, the NPPF then states that substantial weight should be given to benefits where proposals create additional homes or floorspace (again, it’s not all about housing need…) using airspace above already existing residential or commercial uses or through “sensitive redevelopment” or proposals within existing residential curtilages. Having said this, the NPPF doesn’t provide blanket support for such densification and parameters include maintaining access to daylight and sunlight as well as ensuring that at least 50% of the non-developed area in the curtilage remains. 

Elsewhere it goes even further, with policy L3 stating that proposals should make efficient use of land, and that residential or mixed-use developments within settlements should increase the density in the area where they are proposed unless there is a clear justification that this is “inappropriate or not possible”. Whilst the character of an area should be taken into account, this “should not preclude development which makes the most of an area’s potential”. 

Perhaps most emphatic of all is paragraph 4 of L3, which confirms that development proposals that “do not make efficient use of land…should be refused.”  The message is clear – the government expects to see increased density unless there is a really good reason. 

A strategic advantage

The government have been keen to recognise the importance of strategic sites, which is perhaps not surprising as they probably offer the greatest chance of the government getting even close to the promised 1.5 million homes this Parliament. The new NPPF now reflects that these schemes have different pressures and priorities, with strategic site specific provisions including the following:

• Development plans should identify sites for strategic housing-led development.
• The consenting framework for strategic sites should be flexible enough to respond positively to changing circumstances, including change to housing need, infrastructure requirements, viability, and design. 
• Strategic sites (and a few others) now have the flexibility to submit a viability assessment demonstrating that they cannot comply with the Golden Rules for affordable housing delivery in the grey belt, which would usually otherwise require 50% affordable housing.

Maximising residential opportunities around stations  

One of the key opportunities for developers is land near “well-connected” railway, underground, tram and light rail stations. The changes to the NPPF in this regard have caught the attention of many and seem to be the flagship of the government’s “default yes” approach. We’ve already mentioned policy S5 which relates to proposals outside settlements. Well, residential and mixed-use developments which are located near well-connected stations, form part of that broad list of forms of development which should be approved. There’s some quite precise wording which goes alongside this in terms of what is meant by well-connected (spoiler, it relates to the number of trains or trams at the specific station), as well as needing proposals to be, among other things, within “reasonable walking distance” and be “physically well-related to the station or settlement”. While reasonable walking distance is now defined in the NPPF, there is some room for debate as to how this will all be measured in practice. 

These “well-connected” developments are also required to be specific densities, ranging from at least 35 dwellings per hectare at the lower end and at least 45 dwellings per hectare where the related station sees a high frequency of trains. 

The danger of design

Many will recall that the 2024 iteration of the NPPF rejected the notion of beauty, instead heralding the importance of good design. That approach has been retained in the new version, but the implications of design have expanded, with potentially dangerous consequences for applications. 

As well as repeated references to the importance of design throughout the framework, policy DP3 first requires proposals to integrate with and enhance their surroundings, and then provides a surprisingly full list of issues which need to be considered in demonstrating good design, relating to liveability, climate, nature, movement, built form, public space, and identity. 

Crucially, if proposals conflict with the first part or relevant aspects of the second without clear justification, they should be refused. 

Given the subjective nature of many of the issues dealt with in this policy, it runs the risk of undermining the certainty delivered by the more rules-based approach of many of the other policies. Going forward applicants will need to take care to ensure that they have carried out a robust assessment of the scheme against this policy, to avoid handing a ready-made reason for refusal to unenthusiastic decision makers. 

With great change comes great uncertainty 

No matter how clear any government hopes new policy will be, the nature of the beast is that something will lead to unexpected or unavoidable ambiguity, and the position is no different with the new NPPF. Even seemingly innocuous changes are at risk of being poured over for deeper meaning, and early contenders for disputes include:

• When applying policies S4 and S5, it is necessary to consider whether a proposal conflicts with any policy that requires refusal. In practice, it may not always be clear which policies have that effect. In some cases, to benefit from the universal tilt schemes must be (amongst other things) “physically well related to an existing settlement”. However, there’s already debate about what this means. If adjacency were adequate, surely that would have been said, so there must be more, but what that is, isn’t clear.
• The NPPF introduces four categories for heritage impacts: positive effect, no effect on significance, harm to significance, and total loss of significance. Although these categories appear straightforward, they raise questions about how they relate to existing concepts such as “substantial harm” and “less than substantial harm”. This is likely to generate case law on their application in practice.

All in all, the NPPF has some real positives for the development industry. Even where developers may have sought a different landing point, the fact that there is now clarity on what is expected is helpful. There are also opportunities for those in a position to revisit sites previously in the “too hard” pile, for example around stations and the grey belt. 

However, the framework of policy established still needs to be navigated with care, as there are plenty of hazards which could trip up the unwary.