At the end of last year there were a number of announcements touching on planning reform, nature recovery and biodiversity. Taken together, these give a clearer indication of the government’s intended direction, even though much of the detailed machinery will only emerge over the course of this year.
The most significant elements include the enactment of the Planning and Infrastructure Act, the publication of the Nature Restoration Fund (NRF) implementation plan, ministerial statements on Biodiversity Net Gain (BNG), and consultation on a revised National Planning Policy Framework (NPPF).
Some commentary has tended to blur the distinction between enacted legislation, consultation material and forward‑looking ministerial intent. Read together, however, the official documents point towards a more strategic and centralised approach to environmental mitigation, with a conscious move away from fragmented, site‑by‑site solutions.
Following Royal Assent of the Planning and Infrastructure Act in December 2025, the government published its implementation plan for the Nature Restoration Fund (NRF). The foreword by the Ministers for Nature and for Housing and Planning is explicit in its critique of the current system, describing it as one that too often delays development, imposes costly localised mitigation, and ultimately maintains environmental baselines rather than delivering recovery.
The NRF is designed to address this by allowing developers to meet certain environmental obligations through payments into a centrally managed fund, delivered by Natural England via Environmental Delivery Plans (EDPs). Each EDP will relate to a defined geography and one or more environmental features (initially focused on nutrient neutrality, but capable of extending to protected species). The EDP will identify a package of conservation measures to be delivered strategically across the area, funded by pooled developer contributions.
The intention is twofold. First, pooling contributions from multiple schemes should allow Natural England to deliver measures at a scale that is more effective than piecemeal mitigation. Second, where a development falls within the scope of an adopted EDP, reliance on that EDP can substitute for bespoke project‑level habitats assessments or species licensing in relation to the relevant environmental feature.
The implementation plan sets out a structured process for preparing and approving EDPs, including public consultation and approval by the secretary of state, who must be satisfied that the measures proposed will materially outweigh the impacts of development on conservation status by the end of the EDP period. Monitoring, reporting and back‑up measures are integral to the model, with powers to amend or revoke EDPs if outcomes are not being achieved.
In practical terms, the NRF represents a new delivery route rather than a universal removal of environmental constraints. Its relevance will depend on whether an EDP exists for the catchment or species in question and on the scope of that plan. The government’s indicative timetable suggests that consultation on the first nutrient‑related EDPs will take place during spring/summer 2026, with initial plans expected to follow once that process is complete.
Alongside the NRF material, Matthew Pennycook, Minister of State for Housing and Planning, made statements in Parliament on 16 December 2025 in the context of wider planning reform. These included references to forthcoming changes to mandatory Biodiversity Net Gain (BNG), which have since been widely discussed.
The key announcements were the intention to introduce a new exemption from BNG for development under 0.2 hectares, and a commitment to consult in early 2026 on whether smaller residential developments on brownfield land should also be exempt, with potential thresholds up to 2.5 hectares. There was also an indication that further easements are being explored for small and medium‑sized schemes.
Although the government has announced an intention to exempt development under 0.2 hectares from mandatory BNG, this change will require secondary legislation and has not yet been brought into force. At the time of writing, the existing BNG regime continues to apply.
It is notable that these announcements were explicitly framed as part of an ongoing reform process rather than as a final response to last summer’s BNG consultations, which is expected early this year. The overall thrust is therefore an attempt to reduce friction and viability impacts at the smaller end of the market, while retaining the core statutory framework. This is reinforced by the government’s continued intention to commence BNG for Nationally Significant Infrastructure Projects in May 2026.
On the same day as Matthew Pennycook’s Commons statement, the Ministry of Housing, Communities and Local Government (MHCLG) launched consultation on a revised draft National Planning Policy Framework. While this remains a consultation document, it provides a clear signal of policy intent, particularly in relation to biodiversity and Local Nature Recovery Strategies (LNRS).
The draft NPPF positions LNRS as a key part of the evidence base for plan‑making, to be used to steer spatial strategy, allocations and masterplanning, including identifying opportunities for enhancement and ecological connectivity. At the same time, it is explicit that identification of areas as important for nature recovery does not automatically preclude development, seeking to avoid LNRS becoming a de facto constraint map.
On BNG, the draft framework takes a more restrictive approach to local discretion. It proposes that requirements for BNG above the statutory minimum should only be applied to specific site allocations in development plans where fully justified and evidenced, rather than through blanket plan‑wide policies. This appears aimed at curbing current practice in some authorities of setting higher BNG percentages across entire plan areas.
A further, more subtle change is the clarification that decision‑makers should not give weight to other development plan policies which require biodiversity gains beyond the statutory framework, including for development that would otherwise be exempt. This would limit the scope for escalation of BNG expectations through older or more generic local policies.
Taken together, these announcements point to a clear direction of travel. Environmental mitigation is increasingly being treated as a strategic, infrastructure‑like system, delivered at scale through plans, pooled funding and central oversight, rather than as a series of bespoke hurdles to be negotiated on each application.
The NRF is the clearest expression of this approach, but the same thinking underpins the recalibration of BNG and the draft NPPF’s treatment of LNRS and higher biodiversity standards. While much of the operational detail will only emerge during 2026, the direction of travel is towards greater predictability for development and a stronger emphasis on genuinely restorative outcomes for nature, delivered more strategically. There is also increasing recognition of the challenges faced by small and medium sized builders and the need to reduce financial and bureaucratic impediments.
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