NPPF 2024 vs 2026: The Essential Planning Changes

 

NPPF 2024 vs 2026: the changes at a glance

 

The August 2026 National Planning Policy Framework did far more than move a few paragraphs around. It replaced the December 2024 Framework with a new policy architecture, separated plan-making from decision-making and rebuilt the presumption in favour of sustainable development.

The December 2024 Framework ran from paragraph 1 to paragraph 243. The August 2026 Framework has 20 numbered chapters, although Chapter 1 is introductory and expressly contains no substantive policy. The policies themselves sit in Chapters 2 to 20, use lettered codes rather than one continuous run of paragraph numbers and are supported by six policy annexes.

 

The 2026 NPPF separates plan-making from planning decisions

 

In the 2024 NPPF, one paragraph could speak to both the preparation of a local plan and the decision on an application. That sometimes encouraged people to quote a plan-making instruction as though it were a development-management test.

The 2026 NPPF draws a much clearer line. It begins with procedural plan-making policies PM1 to PM17 and procedural decision-making policies DM1 to DM10. Each later subject chapter then separates its plan-making policies from its national decision-making policies.

The Framework says:

• plan-making policies should be read as a whole
• national decision-making policies should be read as a whole
• plan-making policies should not be used to determine development proposals
• the annexes are national planning policy
• the short boxed objectives at the start of chapters are context, not policy

This sounds like document housekeeping, but it changes how a planning statement, officer report or appeal statement should be structured. For an application, the correct national decision-making policy matters. A neighbouring plan-making policy may explain the wider approach, but it is not an extra refusal test.

 

Paragraph 11 has gone: S3, S4 and S5 now control the route

 

The largest day-to-day change is the replacement of the former paragraph 11 decision-taking mechanism.

Under the December 2024 NPPF, paragraph 11(d) applied where there were no relevant development plan policies or the policies most important for determining the application were out of date. Permission was then to be granted unless a protected-policy reason applied or the adverse impacts would significantly and demonstrably outweigh the benefits.

That route was commonly called the tilted balance. A failure to demonstrate a five year housing land supply, or a Housing Delivery Test result below 75%, could make the relevant housing policies out of date through footnote 8.

The August 2026 NPPF starts somewhere different: location. Our guide to the presumption in favour of sustainable development examines the S3, S4 and S5 route in more detail.

• S3 sends proposals within settlements to S4
• S3 sends proposals outside settlements to S5
• where a site crosses the settlement boundary, S4 and S5 are applied to the relevant parts before an overall conclusion is reached

S4 says development within settlements should be approved unless the benefits would be substantially outweighed by adverse effects when assessed against the national decision-making policies.

S5 identifies the forms of development which should be approved outside settlements, subject to the same substantially-outweighed balance. The list includes agriculture, rural businesses where the location is necessary, certain work to lawful permanent buildings, redevelopment of previously developed land, limited infilling within groups of houses, exception sites, traveller accommodation meeting the policy tests, development near a well-connected station, allocated land and development meeting evidenced unmet need.

A proposal outside the listed categories needs exceptional circumstances. In that route, the benefits must substantially outweigh the adverse effects, including harm to countryside character and sustainable movement patterns.

 

The development plan still comes first

 

The new S4 and S5 balances are powerful, but they have not repealed section 38(6) of the Planning and Compulsory Purchase Act 2004. The development plan remains the statutory starting point, and the NPPF remains a material consideration.

Annex A does, however, sharpen the treatment of some older local policies. It says that a development plan policy, or part of a policy, which is materially inconsistent with a national decision-making policy should receive very limited weight. That rule does not apply where the policy was examined and adopted, or the neighbourhood plan made, against the August 2026 Framework.

Other local policies do not lose weight simply because they are old. The useful questions are therefore:

1. What does the statutory development plan say?
2. Is the relevant local policy materially inconsistent with a national decision-making policy?
3. Does the Annex A exception apply?
4. What other material considerations point towards or away from the development plan?

That is more precise than saying that the NPPF automatically overrides the local plan. It does not.

 

Plan-making has become a different system

 

The December 2024 NPPF was built around strategic and non-strategic policies, a minimum strategic horizon of 15 years and the familiar five-year review cycle.

The August 2026 NPPF is written for the new plan-making system. It gives separate roles to spatial development strategies, local plans, minerals and waste plans, policies maps, supplementary plans and neighbourhood plans.

Among the headline changes:

• spatial development strategies should plan for at least 25 years and address broad growth, housing apportionment, strategic infrastructure and the general extent of Green Belt
• a new-system local plan is expected to be prepared and adopted within 30 months of the Gateway 1 self-assessment
• a local plan should contain no more than ten measurable outcomes
• allocations and designations should cover at least ten years from adoption
• work on the next local plan should begin no later than five years after adoption, or earlier where circumstances require it
• plans should not duplicate, substantively restate or conflict with national decision-making policy unless the Framework directs otherwise
• supplementary plans are limited, examined development-plan documents rather than a replacement name for every old supplementary planning document

This creates an unavoidable transition period. Older local plans and supplementary planning documents still exist, and some emerging plans continue under the December 2024 Framework. A page or report which describes one undated system as though it applies to every plan will be misleading.

 

Applications, validation and viability have new national rules

 

The 2026 DM policies are more directive than the old decision-making chapter.

DM1 expects major proposals to be informed by early engagement with the community, the local planning authority, consultees, infrastructure providers, registered providers of social housing and other relevant bodies where appropriate. A major proposal should be accompanied by a concise planning statement explaining policy compliance, engagement and the intended use of planning obligations.

DM2 and Annex C create a national information framework. A local validation list should include the information required by the national decision-making policies. Additional local information should only be required where a development plan policy calls for a specific further assessment, and the demand should be proportionate rather than applied automatically.

DM5 tightens application-stage viability. An assessment may be justified where, for example, the development type or site characteristics differ materially from what was tested at plan-making, unforeseen site costs arise or site or economic circumstances have changed significantly. The price paid for land or an option is expressly not a justification for failing to comply with policy.

DM6 and DM7 add clearer rules on planning conditions, model obligations and changes required by other regulatory regimes. Where another regime requires a later change to an approved scheme, that change should be approved unless it makes the development unacceptable against the development plan and national decision-making policy.

DM8 brings intentional unauthorised development into the Framework. Where it is concluded from evidence that unauthorised development was intentional, that fact should be given substantial weight when deciding whether to grant retrospective planning permission, including through an enforcement appeal.

DM10 replaces the old split test for Article 4 directions. The separate 2024 requirement for some non-residential-to-residential directions to avoid wholly unacceptable adverse impacts has gone. A direction should now be necessary to protect local amenity or the wellbeing of the area, be based on robust evidence and cover the smallest area required to mitigate the evidenced harm. The examples expressly include over-concentration of small HMOs.

 

Housing need, land supply and delivery work differently

 

Housing policy is substantially expanded and some material which used to sit outside the NPPF is now inside it.

Annex D contains the standard method for assessing local housing need, housing supply calculations and the Housing Delivery Test consequences. The important supported comparison is that the method has moved into national policy. It should not be assumed, merely from that move, that every figure or formula is different from the guidance which applied in December 2024.

The five year housing land supply and Housing Delivery Test still matter, but their policy job has changed:

• failure to demonstrate the required supply is evidence of unmet need for S5(1)(j)
• a Housing Delivery Test result below 75% is also treated as evidenced unmet need for S5(1)(j)
• within settlements, S4 already provides the national decision route
• the familiar HDT consequences remain: an action plan below 95%, a 20% buffer below 85%, and below 75% both measures apply alongside the S5(1)(j) unmet-need consequence

HO7 is a new standalone decision policy. It gives substantial weight to the benefits of homes which contribute towards evidenced accommodation needs, including the needs of particular groups. That can matter for affordable housing, older people, disabled people, supported accommodation, students, military housing and traveller accommodation, not only for an undifferentiated housing number.

Other notable changes include:

• local plans should allocate land to accommodate at least 10% of the housing requirement on sites no larger than one hectare and a further 10% on sites between one and 2.5 hectares
• development plans should require no less than 40% of homes on major housing proposals to meet M4(2) accessible and adaptable standards, subject to the policy’s exemptions
• specialist accommodation and large-scale shared living have dedicated national decision policies
• traveller need, sites and definitions are integrated into the NPPF rather than relying on a separate Planning Policy for Traveller Sites
• the definition of deliverable now asks for clear evidence that homes will be delivered on certain sites within five years, rather than that completions will begin within five years

 

Settlement status, plots and density now carry more weight

 

Settlement status and settlement boundaries are now a national policy fact, not just a label used by the local plan. The glossary definition covers cities, towns, villages and other predominantly built-up areas, together with allocated or permitted land which will form part of the built-up area. Most hamlets and scattered groups of houses are excluded unless the development plan identifies them as settlements, and some Green Belt villages are excluded.

That definition matters because it controls whether S4 or S5 applies.

L2 then gives substantial weight to four broad benefits: remediation, better use of vacant or underused land and buildings, temporary use of previously developed land and additional homes or floorspace within settlements. It expressly addresses airspace, mansard roofs, roofline gaps, higher corner buildings and additional units within residential curtilages.

For residential-curtilage development, the national starting point is that the proposal should:

• occupy no more than twice the footprint of all existing buildings on the site
• retain at least 50% of the non-developed area within the curtilage of the existing buildings

There is an express exception where further development can be accommodated without harm to overall character, taking account of infrastructure and the sustainability of the location. The baseline is the buildings existing on 17 August 2026.

This does not turn residential gardens into previously developed land. The garden exclusion remains in the glossary. L2 is a separate positive policy route.

L3 is also more prescriptive. It expects residential and mixed-use development within settlements to increase the surrounding density unless there is clear justification why that is inappropriate or impossible. Around a qualifying well-connected station, the minimum is generally 35 dwellings per hectare across the net developable area, rising to 45 where the service is at least twice the minimum frequency. The policies use a reasonable walking distance of around 800 metres, or around ten minutes where the route and physical conditions make that a better measure.

 

Green Belt and grey belt have been recast

 

The 2026 Green Belt and grey belt chapter is organised as GB1 to GB8 and Annex E now provides a national method for local Green Belt assessments.

The core rule remains familiar. Inappropriate development is harmful by definition and should not be approved unless very special circumstances clearly outweigh Green Belt harm and any other harm. Substantial weight is given to Green Belt harm, including harm to openness.

But there are important changes around the edges.

The grey-belt definition is wider in one respect. The December 2024 definition excluded land where another footnote 7 protected policy would provide a strong reason for refusing or restricting development. That exclusion has gone from the August 2026 definition. A site can therefore be grey belt in definitional terms even where heritage, habitat, flood or landscape constraints later make development unacceptable. Classification and acceptability are separate questions.

GB7 adds a separate station-led category. Residential or mixed-use development within reasonable walking distance of a well-connected station can be not inappropriate where the detailed relationship, infrastructure and comprehensive-development tests are met. This route is separate from grey belt and does not itself require evidenced unmet need. Major development must still comply with the Golden Rules.

GB8 narrows site-specific viability. The policy identifies limited circumstances in which an assessment may be used, including previously developed land carrying unaccounted former-development costs, a strategic site or a proposal wholly different from the development type tested at plan-making. A significantly reduced affordable-housing contribution is acceptable only in exceptional, fully evidenced cases.

There is also a drafting distinction worth keeping straight. Under S5, an extension or alteration must not result in a disproportionate increase in size compared with the building as it stood on 17 August 2026, while a replacement building must be for the same use and not disproportionately larger. Under GB7, extensions and alterations are judged against the original building, while a replacement must be for the same use and not materially larger. The wrong baseline or adjective can change the answer.

 

Flood risk policy now sits with a full Annex F framework

 

The 2024 NPPF had a flood-vulnerability annex, but the 2026 Framework brings flood zones, vulnerability classes and compatibility outcomes together in Annex F and connects them directly to policies F4 to F8.

F5 changes a common shorthand used for the Sequential Test. The area of search should not be greater than the anticipated catchment of the development in terms of likely occupiers or users. That does not give every proposal the same small search area; it means the geography must be reasoned from the proposal rather than assumed to be the whole local authority area.

F5 also provides an exception where surface-water risk can be dealt with safely through layout, design and mitigation without increasing risk elsewhere. F8 requires a statement showing how national sustainable-drainage standards have been met where applicable, together with long-term maintenance and, where possible, removal of culverts and renaturalisation of watercourses.

 

Nature policy restricts some higher local BNG requirements

 

N1 puts Local Nature Recovery Strategies at the centre of plan-making. A higher local biodiversity net gain standard should be limited to specific site allocations, fully justified and shown to be deliverable. It should not be extended to development which is exempt from the statutory biodiversity-gain regime.

N2 goes further at decision stage. A development plan policy requiring a gain above the statutory framework should receive no weight unless it is a valid site-allocation policy meeting N1. N2 also expects suitable opportunities to strengthen ecological networks, retain established features, use nature-based solutions and incorporate integrated nest boxes, often called swift bricks, unless compelling technical reasons make them unsuitable or ineffective.

N6 integrates Environmental Delivery Plans and the nature restoration levy into the routes for habitats sites and Sites of Special Scientific Interest. That is new machinery, but it does not erase the wider hierarchy protecting designated sites and irreplaceable habitats.

 

Heritage policy no longer uses “less than substantial harm”

 

The December 2024 NPPF gave great weight to the conservation of designated heritage assets and expressly divided harm into substantial harm, total loss and less than substantial harm.

Our guide to heritage significance and harm explains the current decision route in more detail. The August 2026 Framework reorganises the sequence:

• HE5 requires the effect to be assessed as positive, none, harm, substantial harm or total loss
• HE6 applies to designated heritage assets and says any harm is a matter of considerable importance and weight
• HE6 retains the stricter refusal rule for substantial harm or total loss
• HE7 provides the decision route for non-designated heritage assets
• HE8 and HE9 contain dedicated World Heritage Site and conservation-area policies

The phrase less than substantial harm does not appear in the 2026 NPPF. It would nevertheless be wrong simply to replace that phrase with the word harm throughout an old assessment. Significance and effect must first be assessed under HE5, the relevant designated or non-designated policy must then be applied, and the stricter rule remains where substantial harm or total loss is found.

The weight word also changes from great weight to substantial weight. The Framework does not provide a numerical table showing that one expression is greater or smaller than another, so the current wording should be quoted rather than converted into an invented scale.

 

Economy, rural development, energy and minerals

 

Several changes which may look specialist can be commercially important.

• E2 gives substantial weight to specified economic benefits, including business investment, expansion and adaptation, and to farm modernisation supporting food production, animal welfare and the environment
• E4 gives more detailed support to rural businesses, agriculture and equestrian development, with examples including reservoirs, greenhouses, polytunnels, farm shops, livestock accommodation and ancillary seasonal-worker accommodation
• W1 to W4 create a distinct energy and water chapter, with substantial weight for specified energy-security, renewable, network, water-supply, drainage and wastewater benefits
• TR1 to TR6 embed a vision-led transport approach, the Connectivity Tool, walking, wheeling, cycling, public transport and reasonable future scenarios
• M5 says peat extraction at new or extended sites should be refused, while coal or onshore oil and gas development should be refused unless one of the policy’s narrow stated exceptions applies

This is a good example of why a simple old-to-new paragraph concordance is not enough. Material has been split, combined and strengthened in different parts of the Framework.

 

Why the December 2024 NPPF still matters

 

For planning decisions, the August 2026 national decision-making policies became material considerations on publication on 17 August 2026. An application submitted earlier but decided afterwards normally needs to be assessed against the current Framework.

Plan-making is different. The transition rules mean that:

• new-system local plans, minerals and waste plans and supplementary plans use the August 2026 Framework
• spatial development strategies use the August 2026 Framework
• neighbourhood plans submitted on or before publication continue under the December 2024 Framework unless withdrawn and updated
• neighbourhood plans not yet submitted must comply with the August 2026 Framework
• other legacy plans can continue under the December 2024 Framework and its own transitional provisions

That can produce a perfectly legitimate dual-policy situation: a live application is determined using the August 2026 national decision-making policies while the emerging local plan is still examined against the December 2024 Framework.

 

A practical NPPF 2024 vs 2026 checklist

 

For a new application, appeal or policy review, work through the following in order:

1. Confirm which NPPF applies to the decision and, separately, to any plan being prepared or examined
2. Identify the statutory development plan and any materially inconsistent local policy
3. Establish whether the site is within or outside a settlement under the current definition
4. Apply S4 or the exact S5 category, splitting a cross-boundary site where necessary
5. Keep Green Belt and Local Green Space separate from the ordinary S5 route
6. Check the relevant national decision-making policies, definitions and annexes
7. Identify every express refusal instruction and whether its exception is met
8. For housing, establish supply, delivery, evidenced need and group-specific need
9. For land near a station, evidence the TTWA, service frequency, walking route and net developable area
10. For a major proposal, address DM1, DM2 and every applicable Annex C information requirement
11. Use the exact current weight wording rather than importing the 2024 phraseology
12. Conclude under section 38(6), explaining how the development plan and material considerations interact

 

Important cautions when comparing the two Frameworks

 

• “Substantially outweigh” is not automatically the same legal test as “significantly and demonstrably outweigh” simply because both are positive planning balances
• “Substantial weight” is not a number and should not be placed into a made-up hierarchy against “great weight” or “significant weight”
• The NPPF is policy, not legislation and does not displace statutory duties
• Plan-making policy is not an application test unless the Framework separately provides a national decision-making policy
• Definitions can control the route, especially settlement, grey belt, reasonable walking distance, well-connected station, net developable area and existing or original building
• Older decisions remain useful but need their policy context, because an inspector or court applying the 2024 wording was not deciding under the 2026 architecture

 

Sources used for this comparison

 

This page compares the National Planning Policy Framework, December 2024, as amended on 7 February 2025, with the National Planning Policy Framework: Plan-making and national decision-making policies, August 2026. It has also been checked against the implementation and transition provisions in Annex A and the relevant policy annexes. The NPPF timeline and archive contains every published Framework from 2012 onwards.

No comparison page can replace the current policy text, legislation, statutory duties, Planning Practice Guidance or fact-specific professional advice. The exact policy and definition should always be checked for a live proposal. The Government also maintains the official NPPF collection on GOV.UK.