The Historic Environment Policy for Scotland is being rewritten, with a new public consultation opening on 8th October 2026 to clarify how heritage is considered in planning and other decisions. Historic Environment Scotland (HES) is seeking views on proposed changes to the policy used whenever decisions may affect Scotland’s historic environment. The closing date is 3rd December 2026.
The proposed revision is particularly relevant to planning authorities, applicants, conservation officers and consultants. HES says the updated policy aims to explain its relationship with National Planning Framework 4 (NPF4), simplify the way its principles are expressed, and give greater prominence to climate change, nature and people’s experience of historic places.
This is a consultation on a draft policy, not a change that has already taken effect. The existing 2019 Historic Environment Policy for Scotland (HEPS) remains the relevant published HES policy pending any final replacement. Practitioners should distinguish this proposal from adopted NPF4 policy, development plans and the statutory tests governing individual consent decisions.
Historic Environment Policy for Scotland: what is changing?
The new HES consultation identifies three principal directions for the revision. First, it seeks to make HEPS’s role in decision making clearer, including its interaction with NPF4 and other relevant guidance. Secondly, it aims to make the policy easier to navigate by simplifying language and structure. Thirdly, it seeks to incorporate the climate and nature crises more explicitly while giving greater prominence to access and people’s relationships with the historic environment.
These changes matter because questions about how national heritage principles should be applied routinely arise alongside planning permission, listed building consent and wider public investment decisions. A policy that is difficult to place within the planning hierarchy can be misunderstood or given either too much or too little weight. HES is therefore consulting on how its guidance can be clearer and more usable, not announcing that all heritage controls are being rewritten.
The 14-page draft Historic Environment Policy for Scotland (PDF) proposes seven policies, compared with six in the current 2019 document. They address understanding cultural significance, benefits for future generations, sustainable development, impacts on people and communities, strategic decisions, managing change and minimising unavoidable adverse effects.
Importantly, the draft expressly describes HEPS as non-statutory national policy and a material consideration in planning decisions affecting the historic environment, as well as in listed building and scheduled monument consent decisions. It refers directly to NPF4 Policy 7(a). These are proposals, not a newly operative legal test, and must be read alongside the full draft.
Readers should compare the proposed wording with the 2019 policy before responding, rather than assume that a summary captures every change.
Why the relationship with NPF4 matters
Scotland’s NPF4 has a statutory development plan role. HEPS is HES’s national policy statement about decisions affecting the historic environment. Both may be relevant to proposals involving historic buildings, conservation areas, designed landscapes, archaeology and the setting of protected places, but they are not interchangeable documents.
The distinction is important in development management. A planning decision still needs to apply the development plan and any relevant legal requirements, then consider material considerations as appropriate. A clearer Historic Environment Policy for Scotland could help explain heritage significance, options for managing change, and the reasoning behind conservation advice. It would not, simply by being revised, grant planning permission or override the legislative framework.
Applicants and agents should also be careful about terminology. A Historic Environment Policy for Scotland consultation does not mean that NPF4 Policy 7 has been amended, nor does it mean that the 2019 HEPS has ceased to apply. Any definitive change to national heritage policy will depend on the outcome of this consultation and subsequent publication of an adopted document.
Earlier feedback shaped the new draft
The October consultation follows an earlier pre-drafting consultation, which closed on 29th June 2026. HES published a feedback summary on 6th October 2026. Respondents called for clearer explanations of HEPS’s role in decision making, stronger links between the policy and its implementation, better accessibility, and more attention to contemporary pressures.
HES reports that respondents frequently use NPF4, the Managing Change in the Historic Environment guidance series and local development plans alongside HEPS. They were particularly concerned about the practical purpose of HEPS in the planning system and wanted greater clarity on how these documents work together.
The feedback summary also describes a restructuring of the draft. Material on understanding the significance and value of historic places is refined into targeted principles. A section on people and places is moved earlier to give that subject greater prominence, while the managing change section has been reorganised to focus more on implementation and the assessment of impact.
HES says engagement through its Talking About Heritage project also influenced the draft, especially by highlighting the ways people experience heritage and the cultural significance of places. These consultation findings explain the direction of travel but do not establish the final policy wording.
Climate, building reuse and difficult planning choices
Historic buildings often sit at the intersection of conservation, energy efficiency, climate adaptation, housing supply and the reuse of existing structures. Works such as alterations to roofs and windows, insulation, extensions or conversions can raise questions about historic character, significance and practical sustainability.
The revised policy is intended to address climate and nature issues more directly. That is potentially useful for applicants who must explain why a proposal preserves important historic fabric, what alternatives were examined, and how any harmful effects might be avoided or reduced. It is also relevant to planning authorities balancing heritage impacts against wider development objectives.
However, the consultation does not itself create a new exemption for retrofit projects or relax consent requirements. Scheme-specific decisions will still depend on the applicable legislation, NPF4, local policy and the significance of the assets concerned. Planning Geek’s heritage and conservation resources provide background on the issues that can arise when working with protected buildings and areas.
A separate review of conservation area advice closes earlier
There is a second, distinct HES exercise that practitioners should not overlook. Following withdrawal of the former Scottish Government Planning Advice Note 71: Conservation Area Management, HES opened a review of advice on conservation area management on 14th September 2026. Responses close on 31st October 2026.
That exercise asks what future conservation area guidance should cover and how it can meet the needs of practitioners, local communities and decision makers. It is about the scope of potential advice, whereas the newly opened HEPS consultation concerns a draft overarching policy statement. Responses to one should not be treated as submissions to the other.
The potential overlap is nevertheless significant. Conservation area character appraisals, management plans, the treatment of incremental alterations and the quality of evidence supporting decisions could all benefit from clearer guidance. HES has not yet published a final replacement for PAN 71 through this exercise, so existing statutory duties continue to require proper consideration.
What should planning professionals say in their responses?
For planning agents and local authorities, the most useful consultation responses are likely to provide real examples of uncertainty. These might include situations where HEPS and NPF4 appeared to be read differently, where guidance was difficult to apply to a modest alteration, or where the significance of an undesignated historic place was poorly explained.
Responses could also identify whether the proposed text gives enough practical direction on balancing conservation and climate adaptation, demonstrating reasonable alternatives, community involvement and recording the reasoning behind decisions. Specific wording suggestions are more useful than a general statement that heritage protection is important.
HES is also offering two online workshops in November, alongside the web questionnaire and arrangements for submitting feedback by phone, email or online meeting. Contact details and the draft document are supplied on the official consultation portal.
Deadline and practical consequences
The main HEPS consultation opened on 8th October 2026 and closes on 3rd December 2026. The separate conservation area guidance review closes on 31st October 2026. Both are Scotland-only processes: neither changes the heritage planning framework in England, Wales or Northern Ireland.
The practical position today is unchanged. Applicants should continue to assess relevant historic assets, their setting and any lawful consent requirements under the current framework. For proposals likely to remain in the system while a final policy is developed, keeping track of the review may help teams identify emerging expectations and avoid unnecessary redesign later.
The central question for practitioners is whether the replacement Historic Environment Policy for Scotland will make decisions clearer and more consistent without blurring the legal relationship between policy, guidance and statutory consent. The October draft offers the first opportunity to test that proposition against the actual wording.
Official sources: HES HEPS 2026 consultation; HES pre-drafting feedback; current HEPS; conservation area guidance review.
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