Episode 206 - Consultation on NPPF Reform

This week we are going to walk through the Government’s latest consultation on reforms to the National Planning Policy Framework, published in December 2025, and explore what it might mean for the built environment profession. This episode content meets PC3 - Legal Framework & Processes of the Part 3 Criteria.

Resources from today's episode:

Website:

• https://www.riba.org/campaigns/share-your-views-on-changes-to-the-national-planning-policy-framework/
• https://assets.publishing.service.gov.uk/media/697b6bc6aacd0dc9777b4fd2/December_2025_NPPF_Consultation.pdf

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Transcript

Episode 206:

Hello and Welcome to the Part3 with me podcast. 

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I am your host Maria Skoutari and this week we are going to walk through the Government’s latest consultation on reforms to the National Planning Policy Framework, published in December 2025, and explore what it might mean for the built environment profession. Todays’ episode meets PC3 of the Part 3 Criteria.

So last time the NPPF was updated was last February in 2025. Now the government is seeking to update it again one year on. 

We will structure todays episode around four themes:

• First starting by looking at what the Government is trying to achieve with this new consultation on the framework. 
• Second, we will look at the overall structural changes to the NPPF and what this might mean for the plan‑led system. 
• Third, we will go through the twelve headline policy shifts that the consultation flags, pausing on the ones that feel most relevant for practice. 
• And finally, we will look at how the RIBA is responding, and what this means for how you might engage with the consultation in your own role or as you prepare for your Part 3 interview and exam.

So starting with the first theme, why is the Government seeking this consultation again on an updated National Planning Policy Framework so close to the previous update, and why now:

The consultation document sets the scheme that England has a long‑running housing crisis, driven by decades of failing to build enough homes, which in turn constrains economic growth, pushes ownership out of reach, drives up rents, and increases the numbers in temporary accommodation. 

In response, that’s why the Government moved within 3 weeks of entering office to consult on changes to the NPPF with an initial update in December 2024 that restored and raised mandatory housing targets, strengthened support for social and affordable housing, reinforced a brownfield‑first approach and introduced the now well known concept of “grey belt” within the Green Belt.

This new, December 2025 consultation, is presented as the next stage in that programme, moving from quick fixes to what is described as a fuller and more definitive update of national planning policy. The Government places this within a wider package that includes the Planning and Infrastructure Bill, expected to receive Royal Assent before the end of the year, new settlements recommended by a New Towns Taskforce, and what it calls New Home Accelerators to unlock housing in key growth areas, alongside a £39 billion Social and Affordable Housing Programme.

The consultation has been live since 16 December 2025 and will be closing on 10th of March 2026. The Government has been very explicit that, having moved at speed to regear the system, it now wants a period of stability in the second half of the Parliament where planners, local authorities and developers focus on delivery rather than continuous policy churn. That framing is important, because it explains why a lot of the changes are about clarity, certainty and making the system more rules‑based.

So that’s in nutshell what the government is aiming to achieve with this consultation.

Now, lets move on to the second theme of today’s episode. Looking at the overall structural changes of the new NPPF:

One of the most significant shifts in the consultation is not about any single policy, but about how the NPPF is structured and how it is meant to operate. The Government is, therefore, proposing for the first time to set out a clear distinction between policies for plan‑making and national decision‑making policies, within a single framework.

The draft Framework will retain the idea of topical chapters, but reorganises them so that Chapter 2 deals with plan‑making and Chapter 3 with decision‑making procedures, followed by subject‑specific chapters beginning with sustainable development and climate change, then topics that steer development, and then those that deal with creating sustainable places and conserving the environment. New chapters are also proposed on planning for energy and water, and on managing flood risk and coastal change, with annexes that bring into the NPPF certain elements previously held in Planning Practice Guidance, such as the standard method for Local Housing Need and additional material on flood zones and viability inputs.

This structural change reinforces several core principles:

• First, it restates that the system remains plan‑led, the Government is clear that development plans remain the cornerstone of the system, and that the ambition is for universal plan coverage so that development does not come forward in a piecemeal or speculative way. 
• Second, it strengthens the expectation that national decision‑making policies will cover generic issues so they do not have to be restated in every local plan, which in theory should simplify and speed up plan preparation.

There is also an important legal nuance around National Development Management Policies. The Levelling Up and Regeneration Act 2023 created powers to give certain national policies statutory status, but the consultation explains that the Government has chosen not to commence those powers for now. Instead, it proposes to achieve similar effects through clearer national policies, a requirement that those policies not be repeated in local plans, and an explicit statement that local policies inconsistent with national decision‑making policies should be given very limited weight from day one. For practices, that signals an intent to give national policy considerable immediate weight without re‑opening the statutory hierarchy of development plan versus other material considerations.

The introduction also covers some interpretive housekeeping that will be useful in day‑to‑day work. There is a proposal to simplify terminology around “weight”: where the current NPPF uses terms like great, significant and substantial weight, the draft suggests using “substantial” consistently wherever a positive weighting is intended, raising questions in the consultation about whether this aids clarity. It also clarifies how the NPPF sits alongside Planning Practice Guidance, positioning the NPPF as the statement of national policy and Planning Practice Guidance as supporting explanation rather than parallel policy.

So those are broadly the proposed changes to the structure of the Policy document itself. 

Now moving onto the third theme in todays episode, the twelve key reforms: what they say, and why they matter:

1. In the first key reform, the Government proposes what it calls a permanent presumption in favour of suitably located development. The idea is to move towards a more rules‑based system where it is clearly set out what forms of development are acceptable in principle in different locations, with a particular emphasis on urban land and brownfield sites. Building on the December 2024 “brownfield passports” work, the consultation proposes that suitable land in urban areas is acceptable by default, underpinned by a revised presumption in favour of sustainable development that effectively becomes a permanent presumption in favour of development in the right places. For architects, that suggests a stronger starting point for appropriate urban intensification, but also a need to understand precisely how “suitably located” will be defined in local and national policy.
2. Then under the second reform, there is a strong focus on building homes around stations. The consultation proposes “in principle” support, essentially a default yes, for suitable proposals that develop land around rail stations within existing settlements, and around “well‑connected” stations outside settlements, including on Green Belt land. It also proposes minimum densities of 40 dwellings per hectare around all stations and 50 dwellings per hectare around well‑connected stations, to make best use of high connectivity and to support access to jobs and services. This is a major signal in favour of transit‑oriented development, and it raises interesting design challenges around how you achieve these densities in a way that still delivers well‑designed, contextually appropriate places.
3. The third reform, then focuses on driving urban and suburban densification. It talks about maximising the use of land in urban and suburban areas through redevelopment of corner and other low‑density plots, upward extensions and infill development, including within residential curtilages. It also signals that local planning authorities will be expected to set minimum densities in well‑connected locations such as stations and town centres, and to support an overall increase in density within settlements. 
4. Under the fourth reform, there is a strand about securing a diverse mix of homes. The consultation talks about stronger support for rural social and affordable housing, clearer expectations around accessible housing to meet the needs of older and disabled people, and more flexibility on the market housing mix once the required mix of affordable homes has been secured. The subtext here is aligning housing delivery more closely with demographic need and tenure mix.
5. Then the fifth reform, seeks to support small and medium sites. It links this to the broader moves towards clear in‑principle support for development in certain locations, higher densities in existing settlements and stronger support for mixed‑tenure development. Crucially, there is a new category of “medium development”, which is associated with potential policy and regulatory easements designed to create a more proportionate, streamlined system. The Government even floats the idea of enabling developers to discharge social and affordable housing requirements through cash contributions rather than on‑site delivery for certain schemes, and is seeking views on the benefits and drawbacks of that approach.
6. Moving on to the sixth reform, under this reform there is a very practice‑relevant proposal to streamline local standards. The Government wants to promote certainty and speed up plan production by limiting quantitative standards in development plans to cases where local variation is genuinely justified. It also wants to limit duplication of matters already covered by Building Regulations, except where optional technical standards are legitimately used. For architects, that could mean less proliferation of bespoke local standards on topics like internal space or environmental performance, but it also suggests that more weight could fall on national standards and on Building Regulations, which you will need to understand in detail.
7. Next, the seventh reform, talks about boosting local and regional economies. It proposes giving substantial weight to the benefits of supporting business growth, including sectors identified in the Industrial Strategy, AI Growth Zones, logistics, town centres and rural and agricultural development. It also floats the idea of removing the town centre sequential test for some uses, to allow greater flexibility in how retail and leisure demand is met. This connects with questions about vitality and viability of town centres, mixed‑use development, and how you balance commercial growth with place quality and accessibility.
8. Then, under the eighth reform, there is a section on supporting critical and growth minerals, ensuring adequate provision for extraction while tightening restrictions on coal in line with the mission to achieve clean power by 2030.
9. Then the ninth reform, emphasises a vision‑led approach to transport, building on the December 2024 shift away from “predict and provide” models that entrench car dependency. Instead, the NPPF will push for transport planning that supports more sustainable patterns of movement, reduces dominance of the private car and aligns with broader place‑making goals.
10. 10.Now under the tenth key reform, there is a clearer articulation of how planning decisions should address climate change, both mitigation and adaptation, in a way that links across to other chapters such as energy, flood risk and the natural environment. The intent is to give decision‑makers and applicants a more coherent framework for weighing up climate considerations rather than treating them as bolt‑ons.
11. 11.And the eleventh reform, looks at the natural environment, and the consultation proposes changes to reflect Local Nature Recovery Strategies, to recognise and conserve landscape character, to encourage incorporation of swift bricks and similar biodiversity enhancements, and to provide guidance on locally important sites for nature. This is part of the wider move towards embedding biodiversity net gain and nature‑positive design in mainstream planning practice.
12. 12.And lastly, the twelfth and final key reform, aims to take a more positive approach to heritage assets, replacing the current policies that can be hard to navigate with clearer wording that still protects significance but supports appropriate heritage‑related development. For architects working with historic buildings or in conservation areas, this could offer more explicit support for sensitive adaptive reuse and new interventions that sustain heritage values.

Across these twelve reforms, there is a clear pattern. The Government is trying to steer more development into well‑connected locations, particularly urban areas and around stations, raise densities, simplify generic policy questions by dealing with them nationally, and support growth sectors while still addressing climate and environmental obligations. 

Now, lets move on to the fourth and final theme of todays episode looking at the implications for the plan‑led system and for your role as an architect:

If we zoom back out from individual policy shifts, three big themes emerge that are directly relevant to architectural practice.

The first is the reinforcement of the plan‑led system, but with a sharper national overlay. The consultation stresses that having up‑to‑date plans is essential to avoid speculative development and to secure good outcomes, and it links this to new legislative reforms on plan‑making, including tighter timetables and the introduction of spatial development strategies. At the same time, by treating national decision‑making policies as a comprehensive suite of general policies that should not be repeated locally, and by downgrading inconsistent local policies to very limited weight immediately, it pushes national policy closer to a de facto floor for decision‑making. In practice, this may make the system feel more centralised, even as it talks about local plans as the cornerstone.

The second is the attempt to make planning more rules‑based and predictable. The references to default yes positions for suitably located development, to minimum densities, to clear expectations around certain types of sites such as stations, and to standardised inputs for viability all point in this direction. For clients, that could mean more confidence that, if they meet clear criteria, they are likely to secure permission, which in turn shifts expectations on architects to understand those criteria and bake them into the brief and the design from the outset.

And the third is the integration of climate, nature and heritage into a more coherent policy structure, rather than treating them as add‑ons. By front‑loading sustainable development and climate change, and by aligning natural environment and heritage policies with wider growth objectives, the draft NPPF tries to show that you can pursue growth and environmental stewardship together. As a professional, that means being able to articulate not just that your scheme meets technical standards, but how it responds to these broader policy narratives.

This is also where the RIBA’s views come in. The RIBA has invited members and the wider profession to share their views on the proposed NPPF changes. Their call for input stresses the importance of a planning system that supports sustainable, high‑quality development, with adequate resourcing for planning authorities and a strong focus on design quality, affordable housing and climate action.

If you are currently working on a project that is likely to come forward during or shortly after this consultation period, it is worth discussing within your practice how the proposed changes might affect your planning strategy. For example, if you are working near a station, the proposed minimum densities and default yes stance may support a more ambitious brief, but you will still need to consider local political context, design codes and community engagement.

So how can you engage as a practitioner if you want to get involved:

The consultation sets out several practical points about how to respond, which are themselves useful illustrations of how Government consultations work. Responses are invited primarily through Citizen Space, the department’s online consultation portal, with alternatives via email or post where necessary. The document is explicit that respondents do not have to answer every question, and that they should not simply cross‑refer to earlier answers but instead provide full comments under each There is also a specific invitation to comment on impacts for protected groups under the Public Sector Equality Duty, which is important in light of concerns about how planning outcomes can differentially affect different communities.

So to draw this together and concluding todays episode, this consultation on the National Planning Policy Framework represents a significant moment in the evolution of England’s planning system. It is not a complete break with the past, but it does seek to clarify, codify and in some respects centralise aspects of policy to support housing delivery, economic growth and climate action. For architects, it will shape the environment in which you secure permissions, design for higher densities, respond to stations and other nodes, and negotiate the balance between growth, environment and heritage.

Let’s sum up what we discussed today:

• The Government’s latest NPPF consultation, published in December 2025, aims to move from quick fixes to a more stable, rules‑based planning system, giving practitioners greater clarity and certainty.
• Structural changes now distinguish between plan‑making and decision‑making policies, reinforcing the plan‑led approach while giving national policy more immediate weight.
• Twelve key reforms collectively promote urban intensification, housing around stations, higher densities, and streamlined local standards. All pointing to more predictable development outcomes.
• The new framework integrates climate action, nature, and heritage into a coherent planning narrative, setting clearer expectations for sustainable, high‑quality design.
• For architects, this consultation signals both opportunity and responsibility: to engage with policy change, anticipate how it will shape briefs and planning strategies.