Following the significant revisions introduced in December 2024, this consultation draft amounts to a fundamental rewrite, introducing significant shifts for landowners regarding land release, valuation, and development obligations.
What this means for Landowners:
While the reforms create new opportunities, notably through the introduction of ‘grey belt’ land, they also introduce tighter controls on land value capture, density and affordable housing delivery. With representations due by 10 March 2026, there is still scope to influence the final outcome, but early understanding and proactive engagement will be critical.
5 Key Findings
- Green Belt Reform and the Introduction of ‘Grey Belt’
‘Grey belt’ land is formally introduced within the Green Belt, requiring a sequential approach prioritising brownfield and grey belt sites ahead of other Green Belt locations. Any land released must comply with new ‘golden rules’, including delivering at least 50% affordable housing, necessary infrastructure and public green space.
- Housing Targets and Land Supply Are Now Mandatory
The standard method for housing need is now a mandatory starting point, supported by a compulsory five-year housing land supply with a reintroduced 5% buffer. The framework also promotes higher-density, mixed-tenure development around transport hubs and introduces stronger support for small and medium-sized sites.
- Brownfield Development Density
Brownfield proposals should be approved unless ‘substantial harm’ can be demonstrated, significantly raising the threshold for refusal. The removal of density-based policy constraints further reinforces the push for more efficient use of previously developed land, particularly in accessible locations.
- Land Valuation and Compulsory Purchase(CPO)
New reforms allow for the removal of ‘hope value’ in certain CPO cases and signals a review of benchmark land values through updated viability guidance. This marks a shift away from purely market-led valuation towards greater state influence over land value capture and development viability.
- Renewable Energy and Environmental Risk Gain Greater Weight
Planning authorities must identify suitable areas for renewable energy, with significant weight given to proposals that support net zero objectives. Flood risk assessments are expanded to cover all forms of flooding, while some smaller development sites may be exempt from biodiversity net gain requirements.
A Land and Development Perspective: Implications for Landowners
For landowners, the draft NPPF signals a more interventionist and strategically driven development environment in which policy support does not necessarily translate into higher land values. While brownfield and grey belt sites may benefit from increased allocation opportunities as authorities respond to mandatory housing targets, enhanced affordable housing requirements and emerging valuation reforms are likely to suppress returns compared to historic expectations.
As a result, realistic pricing, careful timing and deliverability will be increasingly important, with some landowners balancing residential promotion against alternative uses such as renewable energy and infrastructure-led development.
Looking ahead
With the NPPF remaining in consultation, early and informed engagement is essential. Landowners should review how their land aligns with grey belt definitions, assess local plan timetables and five-year housing land supply positions, and consider making representations ahead of the 10 March 2026 deadline. As pressure mounts on authorities to allocate deliverable sites, well-prepared land promoted early is likely to be best received. Ultimately, those who adapt quickly, manage expectations realistically and remain open to alternative development models will be best placed to navigate, and benefit from, the next phase of planning reform.
