England planning reform: where are we now?

Planning and Infrastructure Bill

The Planning and Infrastructure Bill is currently expected to receive Royal Assent in late 2025/early 2026, once both the House of Commons and House of Lords have agreed amendments. There are a number of measures within the Bill which have provoked sustained debate including: Environmental Delivery Plans intended to implement the Nature Recovery Fund (and how this impacts on the ecological mitigation hierarchy); measures to speed up infrastructure planning (re: Nationally Significant Infrastructure Projects and restricting judicial reviews); and, the ability of local planning authorities to set their own planning fee levels. The Bill also enables the full powers for strategic planning authorities to prepare Spatial Development Strategies.

National Development Management Policies (NDMP) and National Planning Policy Framework (NPPF)

The government’s forthcoming NDMPs will standardise decision-making by replacing detailed development management policies in local plans with a unified national framework. Consultation, originally expected in summer 2025, has been delayed to “before the end of the year”. 

By shifting procedural detail to a national level, local plans should be able to prioritise spatial strategy and design coding. However, while this could accelerate plan-making, it risks diluting local distinctiveness and control over nuanced matters.

Once the NDMPs are published, we can expect a revised NPPF to be published. We anticipate this would be focused on strategic matters and plan-making. This is currently expected in winter 2025 – likely another pre-Christmas break gift for us all.

New Local Plan Preparation Process

The Levelling Up and Regeneration Act 2023 compresses the plan-making timeline from 42 to 30 months, from evidence-gathering through to adoption. Despite detailed regulations and formal guidance for the new process remaining unpublished, several local planning authorities have already committed to producing new local plans under the revised system.

Alongside the anticipated introduction of strategic planning and the NDMPs, the various other ongoing delays in issuing the necessary guidance will simply result in further delays to local plans. As Savills has reported, there is an urgent need for local plans to meet identified development needs in order to help increase delivery.

Green Belt Reviews

The government issued £14.8m of funding earlier in the year to a number of local authorities with green belt land. It is anticipated that a series of Green Belt Reviews would start to emerge from spring 2026. The reviews should identify under-performing/‘grey belt’ parcels suitable for release for development. The evidence will become relevant in the short term, given the predicted number of grey belt planning applications.

Devolution

Six areas in the Devolution Priority Programme (Cumbria, Cheshire & Warrington, Greater Essex, Norfolk & Suffolk, Sussex & Brighton, Hampshire & Solent) will hold mayoral elections in May 2026 and vest Combined Authority powers in April 2027. Outside of these zones, two-tier counties must submit reorganisation proposals by 28 November 2025 for shadow elections in May 2027 and vesting in early 2028. This affects areas like Surrey, for example. 

In theory, local plan timetables should remain unaffected and local planning authorities are being encouraged by the government to continue to progress with any emerging local plans. In practice, resource reallocation and governance transitions will likely result in delays. Clear interim protocols are essential to prevent a planning-by-hiatus during reshuffles of strategic planning responsibilities.

Nature Restoration Fund and Environmental Delivery Plans (EDPs)

The forthcoming Nature Restoration Fund and EDPs will pool developer contributions into strategic, landscape-scale environmental enhancements – moving beyond site-by-site mitigation to coordinated habitat restoration, woodland expansion, and green-space creation.

Natural England will design and oversee EDPs. There are no firm timescales from the government for their implementation but they will only come into force once the Planning and Infrastructure Bill receives Royal Assent and enabling regulations are made. The initiative’s success is likely to depend on timely secondary legislation and bolstered administrative capacity. Drafting and consultation on the first EDP frameworks is likely to take place during 2026, with the earliest plans coming into effect by late 2026 or early 2027.

Local Nature Recovery Strategies (LNRSs)

Under the Environment Act 2021, 48 responsible authorities were charged with producing LNRSs by March 2025 to map priority habitats and set local biodiversity targets. Despite £14m in support, only two strategies were published by the deadline – West of England Combined Authority, and North Northamptonshire Council. More authorities have commenced work and we are expecting to see further LNRSs adopted in the coming months.

Once established, LNRSs will inform local plan habitat policies, guide biodiversity net gain (BNG) compensation, and underpin nature-based flood resilience and urban greening measures. There is a real opportunity to positively influence the work and to assist with BNG associated with new developments.

Section 73B: simplifying amendments to consents

Section 73B of the Town and Country Planning Act 1990, introduced by the Levelling Up and Regeneration Act 2023, will enable broader variations to existing permissions so long as changes are not “substantially different” from the original consent. It aims to consolidate the functions of S73 (which cannot amend the development description) and S93A (limited to non-material amendments), potentially resolving issues from Finney v Welsh Ministers [2019] and Hillside Parks Ltd v Snowdonia NPA [2022].

However, without defined secondary legislation on the “substantially different” threshold or a commencement date, it is still uncertain whether S73B will truly streamline the amendment regime.

New Towns

The New Towns Taskforce, launched in July 2024, was charged with recommending a shortlist of locations for the next generation of new towns (10,000+ homes) by summer 2025. The shortlist of recommended sites is due imminently. It will also produce a New Towns Code, outlining design principles and delivery standards, which is expected in late 2025.

Ministers have confirmed that new towns will not count towards local planning authorities’ housing requirements, so this will likely reduce the degree of support from local planning authorities to deliver a new town.

Sequential Test

The long-awaited Planning Practice Guidance (PPG) update on the sequential test has now been published (17 September 2025), having originally expected it at the start of the year. Our initial reading is that it has been worth the wait when it comes to surface water flood risk. NPPF Paragraph 175 states that where built development is proposed in areas at risk of any form of flooding, a sequential test should be applied. Paragraph 027 (Reference ID: 7-027-20220825) of the updated PPG now helpfully clarifies the position and states the following:

“In applying paragraph 175 a proportionate approach should be taken. Where a site-specific flood risk assessment demonstrates clearly that the proposed layout, design, and mitigation measures would ensure that occupiers and users would remain safe from current and future surface water flood risk for the lifetime of the development (therefore addressing the risks identified e.g. by Environment Agency flood risk mapping), without increasing flood risk elsewhere, then the sequential test need not be applied.”

This is good news and hopefully means that schemes with sound surface water drainage strategies do not need to apply a sequential test which will have time and planning balance benefits.

The above reforms seek to reshape England’s planning system to encourage faster infrastructure delivery and strategic planning and environmental gains, yet they risk eroding local distinctiveness, stretching administrative capacity, and creating strategic-planning hiatuses as devolution reshuffles governance. Only time will tell.

Further information

Contact Jessica Graham or Charlie Collins