Change is the only constant in life…
In December 2024, the Government announced the roll-out of a new plan-making system, enabled by the 2026 Regulations and to be guided by the draft NPPF 2025, anticipated to be policy later in 2026. Under the new system, local authorities are expected to prepare and adopt a plan within a clear, time-limited process, with a 30-month programme from start to finish. Alongside the new system, the Government outlined transitional arrangements for plans currently emerging under the system defined in the 2023 and 2024 NPPF, referred to as the ‘legacy system’.
The different options for plan progression will affect timings for plan adoption and the scale of housing land required for allocation in local plans. Areas that miss the December 2026 deadline for submission of their emerging plans under the 2024 NPPF, may benefit in the longer term with an up to date plan based on updated housing needs and national policy, but in the short term risk the presumption in favour of sustainable development continuing to apply across all decision-making as they embark on preparing a plan under the new system.
The shift in local plan policy towards a more efficient system with higher, stricter housing targets will create opportunities for applicants, as local authorities look to establish a robust land supply pipeline. However, with major applications now typically taking over a year to gain consent, according to Savills analysis of Glenigan data, applicants should be ready to move quickly to ensure their projects are at the front of the queue for an early decision.
Which pathways are local authorities taking?
There are 39 local authorities on the first pathway, which requires them to start plan-making under the new system by the end of June 2026. An additional 39 local authorities had already submitted their emerging plans for examination under the legacy system at the time of our analysis, 10 of which had already been adopted. Having met the end-of-year deadline, these plans are currently confirmed on Pathway 2.
A further ten local authorities published their plans before the end of April and stand a good chance of meeting the year-end deadline. We have categorised these as being on Pathway 2, but this may change depending on how quickly each area can progress to submission. Four local authorities had withdrawn their draft plans from the legacy system at the time of analysis, and more are anticipated to join them before the year end. If these areas are to meet the December 2026 deadline to continue preparation under the legacy system, consultation on final draft plans will need to start very soon.
We have categorised the remaining 204 local authorities into Pathway 3. Most of these areas are required to start plan-making under the new system by the end of this year, as their existing plan will expire at this point. Approximately 44 local authorities have adopted their local plans recently and will have a bit more time before they need to move forward under the new system; the latest of these has until 2029.
We expect some movement from Pathway 2 to Pathway 3, as some local authorities may decide they cannot adhere to the programme and withdraw plans, while others may miss the end-of-year submission deadline. The number is likely to be relatively small, particularly given the differences in housing need and policy requirements between the two planning systems.
Seizing the opportunity
There are 204 local authorities that will have out-of-date local plans by the end of the year if they are unable to adopt under the legacy system. Taking out those on Pathway 2 that have submitted or published their plans already, this number falls to 142. Even after accounting for those that manage to submit by the December 2026 deadline, the high volume of local authorities going into 2027 without an up-to-date plan will result in a situation where they are having to make decisions on planning applications based on the presumption in favour of sustainable development.
Those on Pathway 2 that successfully submit by year end will be the last to commence plan-making under the new system, with some projected to start as late as 2031, assuming plans are adopted in late 2027.
Not all local authorities will wait until their deadline. The City of York adopted its current plan under the legacy system in February 2025, and therefore has until October 2029 before it is necessary to start a plan under the new system. However, the council has decided to commence work on a new plan as early as summer 2026. This decision has been made on the basis that early action will help maximise community benefits and ensure development is better aligned with up to date national policy, alongside infrastructure provision, including transport, education and healthcare. It remains to be seen whether the plan is delivered on programme to realise these benefits.
One advantage of progressing a plan under the legacy system is that it will operate under the lower housing targets relative to the new Standard Method in the 2024 NPPF, though the consistency of some of those policies would then need to be judged in decision-making against the new NPPF, with weight applied accordingly.
Those progressing via Pathway 1, which all submitted before the mid-March 2025 deadline, are allowed to proceed under the Standard Method contained in the 2023 NPPF. This has the effect of setting a total housing requirement that is 42% lower than it would be if the Standard Method in the 2024 NPPF were to apply. It is important to note that areas with adopted housing requirements less than 80% of the new housing need figures will need to demonstrate a six-year land supply.
Some plans in Pathway 2 will also have lower housing targets through this same mechanism, with the total housing requirement across these areas around 24% lower than the 2024 Standard Method.
Pathway 3 comprises a high share of out-of-date plans, with the current housing requirement sitting 37% below the level prescribed by the 2024 Standard Method. These areas do not have the option to progress a plan using housing need figures prescribed by the 2023 Standard Method. As a consequence, many local authorities will be adopting new housing requirements much higher than their existing targets, as the 2024 Standard Method will have to be applied. There is a significant amount of new residential development that needs to be planned and allocated against this context across these areas. The next 30 months will be pivotal for applicants looking to take projects forward on the basis of higher housing need figures, particularly considering the current timeframes for achieving consent.
Timing is everything
Given the extensive policy changes around plan production, many local authorities across the country will soon be pushing forward new local plans within tightly planned timelines for adoption set by the 2024 NPPF. The effect of this will be to increase housing targets against current levels for many areas across the country, thereby creating opportunities for the submission of planning applications to address the increase in housing land requirements.
One clear route to gaining permission is through the appeals process. Applicants who have been unsuccessful at the level of local determination have managed to secure positive appeal outcomes over the past year through this route. The implementation of a stricter, digitally led appeal process in 2025 has accelerated the programme for decision-taking, with a median decision time in March 2026 of just 18 weeks, down from a peak of almost double that in mid-July 2023. Since 2021, the likelihood of an appeal being allowed has steadily increased. In 2025 the balance of appeals allowed against those dismissed was positive, a trend which is continuing into 2026.
Decision times for the determination of applications at the local level have moved in the opposite direction, with the median full application in England taking almost 57 weeks in the final quarter of 2026. Lack of resourcing in local authority planning teams remains a key constraint for progressing submissions at pace, along with delays caused by input from statutory consultees and other stakeholders. An increase in public opposition has also slowed down planning at consultation stages, with an emerging trend in artificial intelligence being used to generate responses, often adding complexity.
Local Government Reform
A further complexity in some areas is ongoing Local Government Reform. The Government has made clear that new local plans should be produced, though in some cases the local authority leading on those plans is being abolished and a new principal authority created.
Alongside this, new powers for strategic authorities, whether mayoral or otherwise, to prepare strategic plans known as Spatial Development Strategies (SDS) will, in time, add a new higher tier of plan-making with which local plans would need to be consistent, as reviewed in our third article on Strategic Planning.
The complexities this will create cannot be fully judged at this time. It is anticipated that some of the new merged councils will have to continue with the plan-making of the former district or borough areas – as appears to be the case in Surrey. Some of the new councils have already been confirmed, with others likely to come through in 2027 and 2028.
To read more of our research, please visit our Housing, Development and Research hub
Read the articles within Spotlight on Planning 2026 below
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