The new NPPF: Key takeaways

The new National Planning Policy Framework (NPPF), published on 17 August 2026, introduces some of the most significant changes to national planning policy in recent years.

The reforms include the return of strategic planning through Spatial Development Strategies (SDSs), a new policy approach to development within and outside settlements, a strong presumption in favour of development around well-connected railway stations, and a more restrictive approach to viability assessments at application stage.

In this article, we examine these key reforms and consider what they mean in practice for developers and other stakeholders across the planning system.

Spatial Development Strategies

One of the most significant reforms introduced by the NPPF is the revival of strategic planning at a sub-regional level through Spatial Development Strategies. Under policy PM1, SDSs will look ahead for at least 25 years and are intended to sit ‘above’ local plans, addressing issues which are often difficult to resolve through individual local plans alone, including: housing requirements, the distribution of growth, and the type, extent and the broad location of strategic infrastructure needed to enable development and serve existing communities (including transport, utilities, renewable and low-carbon energy, electricity networks, telecommunications and water and wastewater infrastructure).

The intention is that local plans will then serve to support the delivery of the relevant SDS rather than revisit its principal strategic choices. In areas with a mayor or another strategic authority, this may mean that some decisions traditionally debated at local authority level are increasingly taken at the strategic level.

If the new arrangements work as intended, local plans should be able to focus more closely on site allocations, the policies map and genuinely local matters, rather than seeking to reopen debates about strategic growth, housing distribution or major infrastructure provision that have already been addressed through the relevant SDS.

The practical significance of this for stakeholders is that engagement at the SDS stage may prove to be just as important as participation in the subsequent local plan process. Developers should therefore keep a close eye on developing SDS proposals and seek to provide representations and input at the appropriate stage, as there are likely to be limited opportunities to influence strategic direction once an SDS is adopted (noting their 25-year minimum applicability).

Default yes, default no: Clearer starting points for approvals/refusals

A clear theme running through the NPPF is the Government’s move towards an increasingly ‘rules-based’ planning system, with a number of areas of national policy now providing a clearer starting point to guide decision-makers as to whether development should normally be approved or refused. There are now specific policies relating to development within/outside of settlements, and development taking place in relative proximity to railway stations, for example.

For unallocated sites that fall outside of a settlement, Policy S5 adopts what is effectively a “default no, unless” approach, with permission generally to be refused unless the proposal falls within a list of defined exceptions, including: developments on previously developed land, the reuse of an existing building, housing and mixed-use development within reasonable walking distance of a qualifying well-connected railway station (more on this below), and development which would address an evidenced unmet need. Where an exception applies, then the proposal should be approved unless its benefits would be substantially outweighed by adverse effects, when assessed against the national decision-making policies.

On the other hand, where development is proposed within settlements, the starting point under policy S4 is a default ‘yes’ (noting that this applies only to the part of a proposed development that falls within the relevant settlement), requiring that proposals should be approved unless the benefits of doing so would be substantially outweighed by any adverse effects when assessed against the national decision-making policies.

Similarly, housing and mixed-use development within reasonable walking distance of a well-connected railway station providing a high level of connectivity to jobs and services but which falls outside of a settlement (policy S5 sub-paragraph h) will also benefit from a default ‘yes’. The NPPF introduces a couple of definitions in the Glossary at Annex B which provide some assistance in applying this policy, being:

• “Reasonable walking distance” in this context is around 800 metres, or around ten minutes’ walking time (where topography, route availability or quality, or physical barriers would prevent or discourage walking from up to 800 metres). Again, it is important to note that where only part of a site falls within the relevant walking distance, the relevant policies apply only to that part (as confirmed by the Glossary definition of 'reasonable walking distance'). As such, site layout and the method used to measure accessibility to the relevant station are likely to become important, and this distinction has the potential to create difficulties where a station catchment cuts across a development site.

• A “well-connected railway station” is defined as railway stations and underground, tram and light rail stops located within a Travel to Work Area which falls within the top 80 in England by gross value added. Under the normal weekday timetable, the station must be served (or have a reasonable prospect of being served) through planned upgrades or agreement with the operator, throughout the daytime by at least four trains or trams per hour overall, or at least two per hour in any one direction.

It's also worth noting that where this default ‘yes’ is being relied upon in relation to station-proximate development, policy L3(2)(c) (‘Achieving appropriate densities’) introduces an expected minimum density of 35 dwellings per hectare, with this increasing to 45 dwellings per hectare in proximity to stations with at least twice the minimum qualifying service frequency (unless that would be inappropriate or not possible, or where the development comprises a traveller site). These minimum densities should be exceeded where possible, particularly in areas of high connectivity.

This policy is relevant to land within settlements and outside of settlements, (noting that the requirement to demonstrate very special circumstances still applies where any such development is proposed within the Green Belt).

The policy creates valuable support for station-led development, ensuring that housing is provided in areas of high connectivity, but it doesn't remove the need to address infrastructure capacity, physical relationship to the station, site-specific constraints and the other national decision-making policies. As noted above, promoters will also need to examine carefully whether the entire site, or only part of it, falls within the qualifying walking distance to ensure that they can benefit from the default ‘yes’ position for the entirety of the development, and where this is not the case, that the application is framed appropriately for those areas of the site.

Inconsistent local plan policies

Paragraph 2 of Annex A of the NPPF now provides that development plan policies (or parts of those policies) which are materially inconsistent with national decision-making policies should be given very limited weight. The only exception is where they have been examined and adopted, or a neighbourhood plan made, against the August 2026 NPPF. It's worth noting that this wording is narrower than that in the consultation draft, which referred to policies that were inconsistent “in any way", with the final wording requiring a material inconsistency, not simply a difference in drafting or emphasis.

This provision doesn't mean that every local plan adopted before August 2026 is automatically ‘out of date’ or to be given reduced weight. The relevant question will be whether the substance of the particular local policy is materially inconsistent with a national decision-making policy (provided that the relevant policy does not fall within the exception set out above).

This is likely to be one of the most closely tested parts of the new NPPF and is likely to increase the scope for planning appeals and challenges across the board. Applicants may seek to rely on Annex A where an existing policy is more restrictive than the corresponding national policy, and moving forwards applicants and their advisors should be looking to identify the relevant national decision-making policies and consider carefully whether any development plan policy is materially inconsistent with them. Local planning authorities will also need to get up to speed with the most recent updates to the NPPF and familiarise themselves with areas where the local plan may be materially inconsistent with the same, and ensure that decisions are being taken in line with the national position to avoid costly appeals and challenges which will serve to further delay much needed development (particularly housing).

A tighter approach to viability at application stage

Viability is addressed expressly in policy DM5. The underlying premise is that viability should primarily be considered at the plan-making stage, rather than repeatedly reopened when individual applications are determined.

The NPPF envisages that, at application stage, a viability assessment may only be used to support a non-policy-compliant proposal in limited circumstances, including where:

• The development is materially different from the development types considered in the plan-stage assessment.

• The characteristics of the site are materially different to those considered in the plan-stage assessment.

• The development is demonstrably burdened by costs which were not taken into account in the plan stage assessment.

• Site or economic circumstances have changed significantly since the plan stage assessment.

The policy therefore points towards viability discussions being the exception rather than the norm and it will likely be harder for developers to reopen viability. The application will need to explain why the particular circumstances take the proposal outside the assumptions which were tested when the plan-stage viability assessment was prepared.

The Government consulted on including standardised inputs for viability assessments directly within the NPPF itself, but this approach has not been taken forward. Instead, policy DM5(4) requires all viability assessments to reflect "the recommended approach in planning practice guidance, including the standardised inputs", and where an application-stage assessment is justified, the appraisal will need to be prepared in accordance with that guidance alongside the applicable development plan policies and available evidence.

Green Belt viability and the golden rules

There is a separate and important relationship between viability and the Green Belt ‘golden rules’ in policy GB8 of the new NPPF. In broad terms, the golden rules require that major housing development on Green Belt land (or land released from the same through plan preparation or review) delivers:

• Affordable housing in accordance with the development plan policies (or in the absence of any such policies, a contribution which is 15 percentage points above the highest existing affordable housing requirement which would otherwise apply to the development, subject to a cap of 50% (and where there is no pre-existing requirement, a 50% contribution will apply by default).

• Necessary improvements to local or national infrastructure.

• New or improved accessible green space.

The NPPF identifies three circumstances in which an application-stage viability assessment may demonstrate that compliance with these golden rules is not possible, being where the proposed development is:

• On previously developed land which is demonstrably burdened by costs associated with that previous development which were not taken into account as part of the viability assessment at plan stage.

• On a strategic site (defined in the Glossary at Annex B to the NPPF as “a site for residential, commercial or mixed-use development which would be delivered in multiple phases, has significant infrastructure requirements and requires a masterplan. For a residential-led development, a strategic site will typically have capacity for at least 1,500 homes (although it is noted that the scale may vary according to the mix of uses)”).

• Development which is wholly different from that assessed at plan stage.

The express recognition and definition of strategic sites is significant as this gives national policy a distinct category for large, phased schemes with significant infrastructure requirements, and recognises that these may need to be treated differently from conventional sites (which will be particularly welcome to master developers).

Conclusion

The new NPPF represents a clear shift towards a more strategic and increasingly rules-based planning system. Through the introduction of SDSs, the new approach to development within and outside settlements, stronger support for development around well-connected railway stations and tighter controls on viability arguments at application stage, the Government is seeking to provide greater certainty over where development should take place and how planning decisions should be reached.

Whether these reforms deliver the intended increase in housing and infrastructure delivery remains to be seen. What is clear, however, is that developers, landowners, promoters and local planning authorities will need to adapt quickly to a materially different policy landscape. Understanding how the new decision-making policies interact with existing development plans, engaging early in the preparation of SDSs and identifying opportunities presented by the new settlement and station-led development policies are likely to be key to navigating the new regime successfully.

As always, the real test will be in the application of the policy on the ground, with a number of the new provisions likely to be tested through appeals and legal challenge.

If you have any questions on the new NPPF, get in touch.

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