The Government’s reorganisation pause must not delay Local Plans in England, MHCLG has told councils in updated guidance.
The instruction applies even where a district council expects a future unitary authority, rather than the district itself, to take its emerging plan through to adoption.
The update, issued on 24th September 2026, closes off reorganisation uncertainty as a reason to postpone plan-making:
“The pausing and review of the local government reorganisation programme is not a reason to delay plan-making.”
The reorganisation pause leaves planning deadlines in place
The Government announced its review on 7th September 2026, following updated legal advice. Decisions on reorganisation in Essex, Hampshire, Norfolk and Suffolk were withdrawn. Plans for 14 other areas, together with Cambridgeshire and Peterborough and West Sussex, were also paused and placed under review.
Surrey is the exception. Its reorganisation remains scheduled to proceed, with East Surrey and West Surrey unitary authorities due to become operational in April 2027.
For planning teams elsewhere, the reorganisation pause has left uncertainty about future councils and boundaries. MHCLG’s updated instruction is to continue plan-making rather than wait for that uncertainty to be resolved.
The guidance, first published on 6th July and updated on 24th September, says councils must start plans by the latest dates set in regulations. Authorities which received Local Plan implementation funding should also meet the milestone dates they committed to.
Those are separate obligations from deciding the future structure of local government. The reorganisation pause has not supplied an extension to the plan-making timetable.
Some councils will start plans they will not adopt
MHCLG explicitly applies the instruction to an authority which will be unable to take its plan through to adoption before a new unitary council becomes operational. That creates a practical handover problem: the authority starting the work may not be the authority completing it.
The department is continuing detailed transition work despite the reorganisation pause. Arrangements will be needed for Surrey, and for any further reorganisations which proceed following the review.
One unresolved question is how a successor authority will progress an inherited emerging plan. Another is how several Local Plans might operate at the same time across different parts of a new unitary area, before a replacement plan covers it as a whole.
MHCLG also intends to address the deadline for preparing that unitary-wide plan. It wants adopted plans to remain in force for their existing geographical areas until they are superseded.
These are intended arrangements, not a completed legal framework. The department says it intends to publish transitional regulations in due course. The guidance itself remains labelled draft and a statement of intention rather than finalised policy.
An October deadline is approaching for some authorities
The Government’s separate rollout guidance identifies a transitional group required to publish its Gateway 1 self-assessment by 31st October 2026. The list includes Epsom and Ewell, Spelthorne and Surrey Heath, as well as authorities in areas affected by the reorganisation pause, such as Great Yarmouth and North Norfolk.
For that group, notice of the intention to prepare a new-system plan was required by 30th June. Publication of the Gateway 1 self-assessment starts the 30-month plan-making timetable.
Other authorities have different deadlines. Under the general rule for councils not submitting a legacy-system plan by the end of 2026, notice is due by 31st December 2026 or when the adopted plan reaches four years and eight months, whichever is later.
The corresponding Gateway 1 deadline is 30th April 2027 or the adopted plan’s fifth anniversary, whichever is later. Separate rules apply in circumstances such as withdrawal of a legacy plan.
The practical point is not that every council must meet one national start date. Each must identify its own deadline, and the reorganisation pause does not remove it. The rollout guidance also says the Government will consider intervention where authorities fail to make progress.
Joint work is possible before a new council exists
Existing councils can prepare joint plans, share evidence and address cross-boundary issues together. That offers a route to coordinate work without waiting for a successor authority to take over.
However, an individual authority has planning jurisdiction only over land within its own area. MHCLG says it cannot start preparing a plan on the basis of a proposed new unitary area before the new authority becomes operational.
For landowners, applicants and communities, the immediate consequence is that plan preparation should continue while the institutional review proceeds. In other words, the reorganisation pause may change which authority eventually adopts the work, but it does not put evidence gathering or emerging-plan consultations on hold.
Our Local Plans guide explains the wider old and new systems separately.
Official sources: MHCLG’s guidance, updated 24th September 2026; the Government’s 7th September review announcement; the new-system rollout and authority-specific deadlines.
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