There is yet to be a material change in the number of sites gaining planning consent under the new NPPF, but more positive signals are coming through the appeals process
Any Moment Now…
The number of full planning consents for housing granted annually in England has fallen by a third since 2021. Sweeping changes to the National Planning Policy Framework (NPPF) introduced in December last year are intended to reverse this trend, creating more opportunities to deliver new homes, and working towards the ambition of delivering 300,000 per annum by the end of Parliament.
Early indications suggest that these changes will be slow to take effect, but a shift in narrative is beginning to emerge, particularly through the appeals process. Changes to Green Belt policy and upward adjustments to housing need are creating more routes to a planning consent, and the presumption in favour is holding more and more weight in the decision process.
A slow start
General industry consensus is that the revised NPPF has unlocked a wave of planning activity, but this has yet to be picked up in the stats. The start of the year actually saw a decline in the number of applications submitted for new homes, falling from a peak of over 50,000 in the three months to January 2025 to 45,000 over the first quarter of 2025. This should not be too surprising, however, given the average time between applying and gaining consent (which has increased over the past decade), combined with the recent decline in applications, a large increase in the number of sites and homes gaining planning permission will likely appear only later in 2025 and into 2026. The apparent contradiction in heavy workloads amid falling output highlights the long timescales involved in planning and the fact we are only at the start of a series of reforms, not the end.
We’ve also yet to see any major shift in the type of applications submitted. The split between greenfield and brownfield land has remained reasonably consistent, and in line with historic trends recorded even before the consultation on the revised NPPF. Since the start of 2023, 52% of homes in applications submitted were on brownfield land. This trend has continued, with an almost identical split (53%) observed in the first quarter of 2025.
Nor has there been any change in the size of applications. There remains a reliance on larger sites, with almost 75% of the total potential capacity on sites with capacity for 100 homes or more. This is despite smaller sites tending to progress through the planning system more quickly, and also starting on site sooner after receiving consent.
It’s not easy being green
A key change from the revised NPPF is in the approach to Green Belt. LPAs will be compelled to consider development proposals on Green Belt land when all alternative routes for meeting local housing need have been exhausted, with particular priority given to previously developed land and sites that do not meet the five purposes of the Green Belt. Potential sites should also meet the Golden Rules for Green Belt release, most notably providing 50% affordable housing. Many expected that this would serve as a trigger point for increased planning activity, unlocking sites in key locations and driving growth in some of the less affordable markets in England.
However, early indications suggest that the policy changes are yet to have a major impact. The first quarter of 2025 showed no major departure from previous trends in applications on Green Belt land. The most common site size is still somewhere between 50 and 150 homes, with no notable boost in confidence (yet) towards larger sites. Similarly, higher value markets are viewed no more favourably than they were in 2023 and 2024, despite the fact that these are the areas most likely to be able to viably deliver 50% affordable housing requirements, to comply with the Golden Rules. The PPG was updated in February 2025 to assist with what may constitute Grey Belt land, whilst a number of LPAs received government funding to progress Green Belt Reviews by March 2026. This may increase certainty and the shared evidence base to trigger further activity.
There is also yet to be a marked shift in the volume of planning consents being granted. Based on data from the Home Builders Federation, we have estimated that consents were granted for just over 45,521 homes in the first quarter of 2025. This is a 25% fall compared to the quarterly average in 2024, according to the HBF pipeline report. Some of this fall is likely to be due to the low volumes of applications submitted in early to mid-2024, when activity was suppressed due to a weaker sales market, the former NPPF and policy uncertainty surrounding the general election.
This drop, combined with the weaker volume of planning applications in the first quarter suggests that the 2024 NPPF reforms may not be enough to increase delivery towards the Government’s aspiration of 300,000 homes per year in the near future. Other approaches, such as the recent proposal to streamline the process for small and medium sites, also need to be considered.
Setting a new standard?
Despite these discouraging early indicators, we are beginning to see a positive shift in approach through the appeal system, which does suggest that in the medium to long term, the flow of consented land should increase.
The total volume of appeal decisions had been declining in recent years, reflecting a fall in applications submitted since 2021. But in the first quarter of 2025, a clear signal towards positive decision-making has been set by planning inspectors, according to PINS appeal data. 80% of the residential capacity determined through the appeal process in Q1 2025 was granted planning consent, compared to an average over the last ten years of 57%. The number of successful major appeals (sites of more than ten homes) in the first quarter of the year has already exceeded 50% of the annual average yearly total for 2021–2024, and the proportion of total residential consents that was granted via appeal is higher than any year since the first introduction of the NPPF in 2012.
The reinstatement of higher mandatory housing targets is the key driving force behind the uptick of success for developers across planning appeals. But the increased flexibility for releasing Green Belt land if sites meet the “Golden Rules” is also contributing to increasing volumes of planning consents.
In Q1 2025, 36% of appeals for residential schemes in the Green Belt were successful, compared to an average success rate of 24% over the previous five years. The proportion of successful appeals rose to over 40% for major schemes (those larger than ten residential units). Most of the successful appeals have been located in the Green Belt around London and in the South East, where developers have been able to agree provision of 50% affordable housing.
Successful sites have included 135 homes near Bagshot in Surrey; although only a small part of the site was previously developed land, the inspector accepted that the site could be considered Grey Belt as it did not make a strong contribution to Green Belt purposes. Consequently, under paragraph 155 of the NPPF, development should not be considered inappropriate, and given the large shortfall in housing land supply, the presumption in favour of sustainable development was engaged. Similarly, the inspector determining an appeal for 57 homes and a nursery in Tonbridge and Malling stated that “in complying with the Golden Rules, having regard to paragraph 158 of the Framework, the proposed development should be given significant weight in favour of the grant of permission”.
Thus, after initially subdued interest, promotors, planners and officials are beginning to realise the potential of the “Grey Belt” rules as a route for unlocking and progressing sites, especially in areas such as the South East, where there is considerable unmet demand for housing and many potential sites currently constrained by Green Belts.
Encouragingly, the interpretation of the revised NPPF set by planning inspectors is filtering through to LPA decision-making. Solihull Council has recently granted outline consent for up to 450 homes in Green Belt land, with officers stating that the required “very special circumstances” did exist to justify the development of Green Belt land, including an “exceptional need for housing”.
Summary: Cautious Optimism in a Challenging Market
- The NPPF changes are yet to have a material impact on the size, type, location or volume of applications submitted, but this may change over the next twelve months as the industry and LPAs grapple with updated guidance and evidence (notably on Grey Belt).
- Low levels of planning consents to date and weaker market conditions, however, could act as a limit on growth into 2026.
- Clear signals are being sent through the appeals process. Planning inspectors are undoubtedly embracing the revised NPPF positively, and setting an example to other planning decision-makers in the process.
- Strengthened targets and land supply requirements will begin to feed into local decision-making. Combined with further reform, this has the potential to offer an unprecedented opportunity for acquiring and progressing sites over the next few years.
To read more of our research, please visit our Housing, Development and Research hub
Read the articles within Spotlight on Planning 2025 below
