In May 2024, the Scottish Government declared a national housing emergency, following a series of local declarations by individual authorities. While the political and social drivers behind this move have been widely discussed, its implications for the planning system – particularly in relation to National Planning Framework 4 (NPF4) have received far less attention.
Specifically, questions remain around the delivery of homes on unallocated windfall sites and the weight that can be given to the housing emergency, whether national or local, as a material consideration.
As of September 2025, the Scottish Government has published a Housing Emergency Action Plan, setting out three core objectives:
1. Ending the practice of children living in unsuitable accommodation, as part of the government’s broader commitment to eradicating child poverty
2. Supporting the housing needs of vulnerable communities
3. Maximising investment in Scotland’s housing sector under the banner of “Building our Future”
Under the third objective, the government states: “We are committed to building on this momentum, with a clear expectation of an emergency-led approach to decision making both in the preparation of local development plans and in the determination of planning applications.”
This signals that the housing emergency should now be treated as a material consideration in planning decisions and appeals. However, it remains unclear whether this consideration will override the strict limitations on unallocated windfall housing sites set out in NPF4 Policy 16(f).
In addition, the Scottish Government has issued a Chief Planner letter and a new Notification Direction, both dated 2 September 2025. The Notification Direction requires planning authorities to notify Scottish Ministers of any application for 10 or more homes on land not allocated for housing within seven days of validation. Authorities must also submit detailed documentation upon determination, including environmental assessments, consultee responses, and decision notices.
Although the Chief Planner letter describes this as a monitoring exercise, it raises the possibility of increased ministerial intervention – particularly in cases where applications may not fully reflect the urgency of the housing emergency.
Despite these developments, uncertainty persists. Will these measures be enough to encourage developers to bring forward applications on non-allocated sites? Or are they primarily political signals ahead of the Scottish Parliament elections in May 2026?
What is clear is that the planning and development sector requires greater clarity and confidence. With no further policy changes expected before the election, local authorities must take the initiative. Councils should be prepared to approve housing applications on both allocated and unallocated land if Scotland is to see meaningful progress in the short term.
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