Savills has responded to the Scottish Government’s newly published Housing Emergency Action Plan with a call for immediate clarity on how planning policy will adapt to support housing delivery.
The Action Plan, released on 2 September, sets out three key objectives: ending children living in unsuitable accommodation, supporting vulnerable communities, and maximising investment in Scotland’s housing sector. Crucially, it signals an “emergency-led approach” to planning decisions - but stops short of confirming whether this will override restrictions on unallocated windfall housing sites under National Planning Framework 4 (NPF4).
A new Notification Direction now requires planning authorities to alert Ministers to any application for ten or more homes on unallocated land within seven days of validation, and to submit full documentation upon determination. While the Chief Planner has described this as a monitoring exercise, the move raises questions about potential Government intervention.
Alastair Wood, Head of Planning at Savills, said: “The housing emergency must translate into real change on the ground. If Scotland is serious about unlocking new homes, we need clear direction - and fast. Developers and planning authorities alike need confidence that applications on unallocated sites will be supported, not sidelined.”
Despite the Government’s stated intent, Savills warns that uncertainty around how the emergency will be weighed against existing policy could deter developers from bringing forward much-needed proposals.
With no further policy changes expected before the Scottish Parliament elections in May 2026, Savills is urging local authorities to take a proactive stance - approving housing applications on both allocated and unallocated land to accelerate delivery.
“This is a pivotal moment,” Wood added. “Councils must be bold. The housing crisis won’t wait for the next election - and neither should planning decisions.”