Planning matters blog

Your First Home – where could it make a difference?

Edward Clarke & Dominic Bowers 11 Nov 2026

“Hope starts with a home” was how the new Chancellor framed the formal unveiling of Your First Home (YFH) in his first Budget speech on 28^th October 2026.[1]

The policy was first announced in September,[2] and further details of how the scheme will operate were published on 3^rd November, including local price caps.[3]

YFH is designed to provide the demand-side support that many in the sector have been calling for over the last few years. Although the policy was largely welcomed on its initial announcement, the OBR’s assessment anticipates only a marginal effect on housing supply, albeit within a wider downgrade on the forecast level of housebuilding due to weaker demand, construction costs and wider regulatory and fiscal environment challenges.[4]

In this blog we explore the potential effectiveness of the scheme. The critical distinction – in exploring the impact of the policy – is between purchases supported by YFH, purchases that would not otherwise have occurred, and additional homes built as a consequence: those numbers will not be the same.

YFH is modest in scale, supporting 10,000–15,000 sales a year, well below Help to Buy at its peak. Our analysis suggests its biggest effect on affordability is likely to be in a ‘mid-market’ band across central England, the South West and parts of the North West, rather than the Greater South East, where price caps bite, and that many of those areas are now subject to the presumption in favour of sustainable development, suggesting the supply response there could be stronger than a national view suggests.

What does YFH promise?

Your First Home is expected to be opened for applications from April 2027. The five-year funding package of £4.7bn government-backed lending is set to provide around £700 million of equity loans annually, rising to £1 billion in 2028/29, supporting between 10,000 to 15,000 first-time buyer (FTB) sales each year. This compares with the £24.7bn total value of its predecessor Help to Buy over the ten years (average of £2.47bn each year) which supported the purchase of (at its 2018-2019 peak) 52,000 homes each year.

YFH offers first time buyers – who can put down a 2.5% deposit – a 20% equity loan subject to a household-income cap of £110,000 (outside London), which would improve mortgage access and monthly affordability for eligible households.[5]

The aim of the policy is to support more people into homeownership and boost housing supply[6]. The recently published evaluation of the Help to Buy scheme found that “developers reported building more homes due to increased confidence, in turn increasing their build pace and number of sites” due to the scheme.[7] Although YFH is more modest than the original H2B programmes, the Government will be hoping for the same kind of response.

A developer contribution applies to the final sale price for each sale supported by the scheme ratcheting up to 4% on each YFH sale for housebuilders selling more than 250 homes each year. The 4% is an additional margin cost on every YFH sale, which would need to be overcome by the hoped-for faster sales rate. This makes the net effect on build out uncertain. Housebuilders' share prices fell on the day of the Budget, with analysts reflecting that the reality of the scheme fell short of its predecessor with regard to a later than expected rollout and higher developer fees.[8]

What do the YFH price caps do?

Access to YFH will be subject to property price caps, set “to ensure the scheme supports access to modest homes”. Last week, detail on the price caps in each local authority was published (see Figures 1a and b).[9]

The formula used to set the local authority price caps has not been made public,[10] but the stated intention has been to focus support on a new build ‘modest home’ of the type normally bought by FTBs while recognising variation between local housing markets.[11]

The variations in price caps for the policy are substantial. The variation correlates with the first time buyer house price (0.85 R²) as well as with median incomes (0.74 R²). However, there are curious anomalies; for example, the price cap in Mole Valley of £330,000 is £40,000 below the average first time buyer average house price (£370,000), whereas in neighbouring Guildford the cap of £505,000 is £103,000 higher (£402,000); median resident incomes are also only slightly higher in Guildford (£45,900 compared with £42,900). It is not obvious why the price cap for Brentwood (£385,000) is so much lower than Braintree’s £435,000, when the median first-time property value in these areas is £397,000 and £315,000 respectively.[12]

In most areas, the median FTB house price is lower than the YFH price cap, meaning the policy would likely have an effect for those that it targets, however there are some 13 exceptions. Figure 1b shows these 13 local authorities (largely in the functional economic area around London but also Trafford, Southampton and Gosport) where the YFH price cap is below the median house price for FTBs in the area, meaning it will support only the purchase of lower than average priced properties. A further 19 authorities have caps less than 10% above the median. Of course, the caps bite harder because the first time buyer medians cover mostly second-hand homes while YFH only applies to new builds, which usually cost more.

Figure 1a and b: YFH price cap by LPA and ratio of price cap to median first time buyer price

Source: MHCLG / ONS / Lichfields analysis

Where could YFH make the biggest difference?

YFH will increase the number of properties that become affordable based on local incomes to first time buyers in most of the country outside of the Greater South East (Figure 2). To understand the level of this impact, we used median household income[13] multiplied by a 4.5x mortgage income multiple, assuming a 95% LTV mortgage without YFH. We then repeated the exercise under YFH, allowing for the 20% equity loan and 2.5% buyer deposit, subject to the relevant local price cap.

We then analysed five years of transactions[14] to derive a modelled sample of the number of house purchases that would be affordable to a first time buyer without (Figure 2a) and with (Figure 2b) YFH, shown as a slider.

The scheme will have its most significant effect in areas where local incomes are sufficient to support a house purchase, but house prices are not so high as to exceed local price caps or only be affordable on incomes that are higher than the scheme’s income caps. Due to the local price caps, the highest share of homes affordable on a median wage do not necessarily benefit the most from the scheme. In these areas, house prices are not the main barrier for FTBs; the constraint instead being the smaller number of potential buyers with sufficiently high incomes or access to deposits.

Figure 2a and b: Share of transactions that are affordable given median household income with or without YFH support

Source: MHCLG / ONS / Lichfields analysis

Consequently, the largest increases in the number of homes made affordable by YFH are concentrated in a ‘mid-market’ band across central England, the South West and areas of the North West. In these areas – where house prices are only marginally too high for local incomes – the policy could have a significant effect. Using our modelled sample of five years of property transactions adjusted to reflect first time buyer prices, we calculate that YFH increases by more than 20 percentage points the share of transactions falling within ‘purchasing capacity’ in most Local Authorities, given local incomes. This would suggest an upward pressure on the demand for new homes falling in this price band and, with all being equal, an expected increase in supply (Figure 3).

Figure 3: Change in share of transactions that are affordable given median household income with YFH support

Source: MHCLG / ONS / Lichfields analysis

What type of buyer might YFH help?

Analysis by Bank of England staff finds that equity loan schemes (such as Help to Buy) typically benefit potential buyers that could not access funds for a deposit (most typically from ‘the bank of mum and dad’[15]). A similar analysis (Figure 4) of mortgage data finds that the cohort of home buyers that have increased most markedly over the last twenty years, has been those which are buying using “high leverage and low income”.[16] This group is described as “borrowers [that] are younger, with lower incomes and smaller deposits” and the group includes a “significant share of first-time buyers”. High leverage in the BoE analysis is a loan to value percentage of more than 75%.

Figure 4: First-time buyer share over time by BoE Typology groups

Source: Bank Underground

Under YFH, the shared equity element will reduce the mortgage leverage for those with lower deposits. Revealed preferences from further Bank of England analysis would suggest that house purchasers are relatively price insensitive: as house prices change, they continue to seek the same type of home, adjusting the value of loan rather than maximise the proportion of equity they own or minimise monthly payments per se[17]. The implication is that some of the support may be capitalised into higher new-build prices, as research on Help to Buy found in tighter markets such as London – it is this risk that the price caps are designed to contain.

Where might YFH lead to more homes being built?

Our 2025 blog on the case for demand-side support made the point that schemes such as Help to Buy have the greatest impact on supply – and are less likely to drive house price inflation – where planning allows for more land to come forward such that the build out of homes can increase in response to the increased demand. Our assessment is that, in today’s planning context, higher housing need figures via the Standard Method and the latest, pro-development NPPF policies mean that there are more opportunities for the housebuilding industry to respond to increases in demand than when Help to Buy was operational. For most of the period of its operation, the combined housing target of local plans in England was around 230,000 with a Housing Delivery Test (HDT) figure of 259,000; when combined with the number of areas where development was restricted by Green Belt, it can be no surprise housing development peaked at 248,590 in 2019-20.[18]

YFH will operate under the 2026 NPPF which has the ‘universal tilt’[19]. This means the presumption in favour of sustainable development operates permanently within settlement boundaries, and operates outside settlements where, inter alia, there is unmet need for housing, including in Green Belt areas, based on there being no five-year land supply and/or an HDT failure. This means there is a generally permissive approach in principle across many parts of the country (see Figure 5).

Figure 5a: LPAs where presumption in favour of sustainable development applies under Policy S5(1)(j) or GB7 and 5b: Presumption status in areas where YFH is expected to make the greatest change to affordability

There is no correlation between the size of the impact of YFH and whether that authority is or is not subject to the presumption in favour of sustainable development, as independent variables this is to be expected. However it is notable that there are almost twice as many authorities (96) that are both subject to the presumption and have a 16% or higher change in number of homes that become affordable with YFH for median earners, than the 52 authorities that are impacted by YFH but do not have these looser restrictions on supply. It is these 96 authorities, that – on the policy’s own terms (to support more people into homeownership and boost housing supply) – represents an obvious ‘sweet spot’ for YFH: places where our analysis indicates a material improvement in purchasing capacity coincides with a more permissive planning position, albeit that does not automatically mean development will occur.

Conclusion

The Government's planning reforms – notably the Standard Method and the latest NPPF – represent what is probably the most positive supply side planning regime for decades. What this could achieve was clearly undermined by the absence – for the first time in decades – of meaningful demand side support. YFH helps to address that gap.

However, the reality is that these policies must align with other conditions necessary for a functioning housing market and viable development; this includes other regulatory requirements, the macro-economic and geo-political environment that all affect the choices and ability for individuals to buy a home and developers to build them.

YFH will be seen by many as a welcome return of demand-side support but – at well below Help to Buy’s scale and with a developer contribution attached – it will not on its own deliver a step change. Its greatest impact will be in the areas at the sweet spot where sufficient potential buyers are newly able to buy homes, and whereby the housebuilding market industry can respond by increasing supply. Our analysis suggests these are in mid-market areas outside the greater South East, many of which are now subject to the presumption in favour of sustainable development outside settlement boundaries.

The OBR may or may not be right about a modest national impact on the supply of new homes, but our analysis shows that the actual effect will be driven by the aggregated supply elasticity in particular local markets where YFH has most traction.

Footnotes
[1] HMT, Budget 2026 Speech, 28^th October 2026 [2] MHCLG, New first-time buyer scheme to be confirmed at Budget, 26^th September 2026 [3] MHCLG, Guidance: Your First Home, 3^rd November 2026 [4] OBR, Economic and fiscal outlook – 28^th October 2026 [5] MHCLG, Guidance: Your First Home, 3^rd November 2026 [6] MHCLG, Your First Home press release, 26^th September 2026 [7] MHCLG, Evaluation of the Help to Buy scheme: evaluation findings report, 16^th September 2026 [8] Reuters, UK homebuilders slump as budget's first-time buyer scheme disappoints, 28^th October 2026 “The homebuilders sector index fell more than 6% after the minister's budget speech, reversing a rally of about 9% since the government announced the scheme in September.” [9] MHCLG, 2026, Your First Home: local authority property price caps [10] It has been suggested that it is based on a three-year trend of values for new homes purchased by first time buyers in each local authority area; in a period of low supply and a poor market it is thus susceptible to localised and anomalous patterns of new build activity in those years, e.g. small apartments in the town centres rather than small houses. [11]MHCLG, Your First Home Guidance, 3 November 2026 [12] ONS, 2026 First time buyer mortgage sales; Table 3b, Median purchase price for first time mortgage sales [13] ONS, 2026, Median Household Income levels by LSOA, we used population weighted modelling to derive median Household income levels at the Local Authority level. [14] Land Registry, 2026, Price Paid Data for all transactions July 2021- July 2026 adjusted by inflation to April 2026 prices. For all homes built before 2020 but sold in this period, we add a premium of 5% to reflect the ‘new build premium’ whereby new homes sell for higher values than average sales, based on the Help to Buy evaluation, which found this premium to be 5% (MHCLG, 2026, Evaluation of the Help to Buy scheme: evaluation findings report). [15] Bank of England, 2025 Credit constraints and the redistribution of housing wealth – Bank of England Staff Working Paper No. 1,147 [16] Bank Underground, 2026 Demographics, deposits and data: using machine learning to segment UK mortgages – Bank Underground [17] Bank Of England 2024, Staff Working Paper No 1,086, Housing-consumption channel of mortgage demand. [18] MHCLG, Housing supply: net additional dwellings, England: 2024 to 2025, 20^th November 2025 [19] A term used by the Minister in this letter to PINS,

Assessing the need for visitor accommodation

Jade Scott-Meikle & Roisin Kingsbury 09 Nov 2026

As destinations respond to changing visitor expectations, travel trends and economic priorities, understanding where accommodation is needed, what form it should take and the value it can deliver is increasingly important. An evidence-led approach therefore has an important role to play in helping destinations adapt and plan for the future, and we are increasingly being asked to undertake visitor accommodation needs assessments for a range of projects across the UK.

In Scotland, for example, the shift towards more flexible working patterns following the pandemic has created opportunities to repurpose vacant or redundant office space for hotel use, leading to a growing number of planning applications for changes of use from offices to hotels. This trend, coupled with significant growth in short-term let accommodation, has contributed to a perception in some locations that the visitor accommodation market is becoming saturated. Robust, locally specific evidence is therefore important in understanding whether further accommodation is needed and in making the case for development and investment.

In response to growing demand for this type of analysis, we have developed Accommodate, a toolkit designed to assess the need and demand for visitor accommodation.

Accommodate in action: insights from Edinburgh’s hotel market

As Lichfields’ Edinburgh office can attest, although autumn in Edinburgh can feel like a bit of a breather between August’s Fringe Festival and the festive period, there is never really an off-season for the city’s visitor economy.

In 2024, Edinburgh attracted an estimated 5.05 million overnight trips, with visitor spending around £2.57 billion in the city. Recent studies point to continued growth in demand, estimating that an additional 10,406 hotel and serviced apartment rooms will be needed by 2040 to accommodate future visitor levels.

Recent analysis by Lichfields takes a closer look at how Edinburgh’s hotel market is performing, including how demand has changed over the past decade and whether new accommodation is keeping pace.

A closer look at Edinburgh

Between 2015 and 2024, annual demand for hotel bedspaces in Edinburgh increased by 30.3%, almost twice the rate of growth across Scotland as a whole. Hotel occupancy in Edinburgh also reached 84.5% in the latest year of data, compared with 79% across Scotland, with occupancy levels remaining above the city’s pre-pandemic peak.

The growth is also reflected in hotel performance. Average daily room rates in Edinburgh increased by 36.8% between 2015 and 2024, after adjusting for inflation, while revenue per available room (RevPAR) grew by 41.9%. Both measures outpaced growth across Scotland over the same period.

Looking beyond the market as a whole, analysis of occupancy rates by market segmentation highlights that strength of growth in demand for hotel bedspaces has been most pronounced in economy and midscale hotel types between 2015 and 2024, with midscale hotels recording a 34.5% increase in annual demand for bedspaces. Revenue per available room in midscale hotels grew by 47.2% over the same period, compared with 11.7% across Scotland.

While city-wide data provides a useful overview of market performance, more localised analysis also offers an understanding of how demand varies across different parts of Edinburgh. Analysis of the Edinburgh Park sub-market, for example, found hotel occupancy rates to be approaching 90%, highlighting the strength of demand beyond the city centre, where business activity and transport connections play an important role in supporting hotel performance.

Is supply keeping up?

In short – no.

Lichfields’ analysis found that demand has grown faster than the available supply of hotel bedspaces over the past decade, with Edinburgh’s hotel supply growing by 25.7% between 2015 and 2024, compared with demand growth of 30.3%.

At the average rate of room delivery observed between 2015 and 2024 – around 362 rooms per year – the city is falling short of its identified longer-term accommodation needs. The rate of delivery would need to almost double over the remaining period to 2040 to meet the implied requirement.

In terms of future supply, our analysis identified 2,530 hotel rooms under construction across Edinburgh at the time of the study, not including further schemes with planning permission that were yet to begin construction. While these will add significantly to the city’s accommodation supply, increasing the rate of delivery will be important if Edinburgh is to accommodate the continued growth in visitor demand anticipated over the coming years.

Edinburgh’s experience highlights how demand, supply and market conditions can shape the case for visitor accommodation. However, the picture will vary from place to place, and locally specific analysis is essential to understanding accommodation needs, informing investment decisions and supporting proposals through the planning process. This applies not only to proposals for new accommodation, but also to investment in existing facilities and decisions about the retention of existing provision.

Making the case with Accommodate

Accommodate provides a flexible, evidence-led approach to assessing the need and demand for visitor accommodation. Combining market analysis, planning policy and an assessment of the wider economic and social benefits of development, our methodology brings together five complementary stages:

Understanding the context – establishing the relevant planning policy context and wider visitor economy objectives.
Establishing the local position – examining the characteristics and performance of the local visitor economy to understand patterns of demand.
Understanding the existing supply – considering the availability of existing accommodation and the potential for additional provision.
Establishing the need – bringing together market evidence to assess the case for additional visitor accommodation.
Reinforcing the case – using our other tried and tested toolkit methodologies, we assess the wider economic and social value of a proposal.

Together these stages provide a rounded understanding of how a proposal responds to local market conditions, addresses an identified need and contributes to the wider visitor economy.

Our approach can be applied across a range of visitor accommodation types and tailored to the specific needs of individual projects, proposals and locations, to support a range of clients, including:

Developers and investors – to establish market demand and support development and investment decisions;
Hotel operators and asset owners – to demonstrate the case for expansion, refurbishment or diversification;
Landowners: to understand the potential for visitor accommodation development; and
Local planning authorities – to assess accommodation needs and inform planning policy and development decisions.

If you’re considering a visitor accommodation project or would like to explore the need and demand within a particular market, get in touch with our team to discuss how Accommodate could help.

Also, our recent blog by Clare Catherall considers the planing policy for visitor accommodation in London.

Look out for a forthcoming blog, where we’ll explore how visitor accommodation needs assessments can help inform local planning policy.

Planning for hotel development in London

Clare Catherall 05 Nov 2026

London’s visitor and business economy relies on having the right hotel accommodation in the right places. National and strategic policy broadly supports hotel growth, but the position at borough level across London is more nuanced: our review found that 24 of the 34 London planning authorities assessed (71%) have a bespoke hotel or visitor accommodation policy.

We reveal growing policy support for hotel developments in the CAZ under the emerging draft London Plan, and at the local level, a varied policy landscape in which location, competing land uses and the quality of the proposed scheme can determine whether a planning application for a hotel is likely to succeed.

National and regional context

National policy supports hotel development as an important part of the visitor economy and a driver of economic growth. The Government’s ambition to attract 50 million international visitors a year by 2030 underlines the need for sufficient infrastructure and accommodation capacity. This direction is reflected in the National Planning Policy Framework (NPPF), which recognises tourism’s contribution to economic growth and encourages planning authorities to support sustainable visitor accommodation in appropriate locations. The NPPF classifies hotels and other visitor accommodation as main town-centre uses and promotes a town-centre-first approach, directing development towards town-centre and edge-of-centre locations where possible.

At a strategic level in the capital, the emerging London Plan places greater emphasis on supporting the capital’s visitor economy by providing additional hotel accommodation in well-connected, sustainable locations. The draft policy approach recognises tourism as a major contributor to London’s economy and seeks to secure sufficient hotel capacity while balancing impacts on housing delivery and local communities. It gives particular support to locations within the CAZ, town centres, high streets and locations with good public transport links (see box below); reflecting the wider objective of accommodating economic growth in a sustainable manner.

The next London Plan – Draft Policy GLE6 Visitor infrastructure

… “Development of serviced visitor accommodation should be supported in the CAZ, town centres and high streets. Elsewhere in London, serviced visitor accommodation development should only be supported in locations that are well-connected by public transport and in line with the national sequential test for town centre uses”…

Central London - growing support for larger hotels within all areas of the CAZ

Under adopted London Plan policy, ‘strategically significant’ hotels over 20,000sqm in the CAZ (Central Activity Zone) are directed to Opportunity Areas, with the intensification of hotels of all sizes resisted where it would harm amenity or upset land-use balance. In comparison the draft London Plan moves away from this tightly controlled CAZ and size-based approach, supporting the development of serviced visitor accommodation (of all sizes) across all areas of the CAZ.

Figure 1 illustrates the Opportunity Areas within the CAZ where current London Plan policy directs significant hotel development (grey) and the expanded wider areas of the CAZ where the principle of hotel development is afforded greater support under the draft London Plan (green).

Figure 1: Central Activities Zone (CAZ)

London boroughs and the local policy picture

The demand for, and delivery of, new hotels in London is not just limited to Central London and the CAZ. Outside of the CAZ we are seeing increased interest in the delivery of new hotels across Inner and Outer London boroughs. It is important to understand how Local Plans seek to control proposals for new hotels and the specific policy nuances that apply in each borough. As such, we have undertaken a detailed review of each borough’s local policy regarding hotels and visitor accommodation.

Of the 34 London planning authorities reviewed (32 London boroughs, the City of London and the OPDC), 24 (71%) have a bespoke hotel or visitor accommodation policy. A further six (18%) address hotels through overarching town-centre, tourism or employment policies. Bespoke policy coverage is therefore established and widespread: hotels are rarely treated simply as an ordinary commercial use.

Figure 2: Local Plan approaches to hotel policy

As is illustrated by figure 2, the boroughs without a separate hotel policy (or where hotel development is addressed through wider town-centre, employment or cultural policies) are all located in outer London (Barnet, Ealing, Hillingdon, Merton, Sutton, Croydon, Greenwich, Bexley, Havering and Waltham Forest). All inner London boroughs and the remaining outer London boroughs have bespoke hotel policies. This includes areas containing major visitor attractions or significant transport hubs, which may generate particular development pressures requiring a dedicated policy response.

Principle of hotel development and locational requirements

Our research found that, at the borough level, hotel development is generally supported in Local Plans where it is appropriately located. Policies frequently direct hotel development towards:

Town centres
Areas with high PTAL or strong public transport accessibility
Opportunity Areas
In some cases, the Central Activities Zone (CAZ) or locations close to specific visitor attractions or transport hubs

Hover over the authority name in the map below for additional locational criteria.

Figure 3: Local Plan variations in locational criteria for hotel development

As can be seen from Figure 3, locational requirements vary significantly between boroughs. Some Local Plans identify specific growth areas, attractions or venues where hotel development will be supported. Other boroughs direct hotels towards town centres but still allow proposals in specified (or, in some cases, more general) locations outside of town centres where defined criteria are met.

We anticipate that the wider locational support for hotel development suggested by the draft London Plan will begin to be applied to individual boroughs with greater standardisation of policy by borough as local plans conform with the London Plan. In the meantime, the picture remains mixed and Local Plan specific.

Additional policy tests

Although Local Plan policies generally support hotel uses, a significant number of boroughs apply one or more additional tests that hotel developments must satisfy. These tests are intended to ensure that proposals are fully justified, do not displace priority land uses (most commonly C3 housing) and they do not contribute to an overconcentration of hotels:

41% prioritise and protect other uses, such as housing or office space before hotel uses are accepted;
15% require applicants to demonstrate evidenced need for hotel development;
12% seek to limit an overconcentration of hotels; and
62% detail specific additional design considerations for hotel developments, including accessibility requirements, amenity standards, servicing strategies and/or active frontages.

The distribution of these considerations across different boroughs is illustrated in the plans below.

The protection of housing and other uses is a common issue in local hotel policy. Many boroughs require applicants either to demonstrate that there will be no net loss of homes or to show that hotel development will not compromise land needed for new housing, including on allocated sites and sites with residential planning permission. Given the GLA’s and boroughs’ focus on housing delivery, this can be a significant barrier where a site is also suitable for residential use, particularly when that potential is identified in the Local Plan.

Employment uses receive less explicit protection in bespoke hotel policies, but they are often protected through other employment Local Plan policies covering employment land. Where a proposal would convert an office or other commercial site to a hotel, a key hurdle can be demonstrating that there is insufficient demand for the existing office use (typically through marketing evidence) and clearly explaining the hotel’s local employment benefits.

Presenting clear evidence of the need for hotel accommodation is cited in local plan policy by a number of authorities, including the inner London Boroughs of Hackney, Tower Hamlets and Lewisham, which are often attractive locations for operators. In such locations, Lichfields' newly launched ‘Accommodate’ toolkit can be used to help demonstrate the need and demand for new hotels, support investment in existing assets, or assess the loss of existing stock.

Design & operational considerations

Finally, our analysis identified several recurring design themes within hotel policies. As identified above, 62% of boroughs expect hotel schemes to address one or more of these matters, identifying them as the key design considerations for hotel development:

Access and servicing – provide safe, convenient access for guests, staff, deliveries and servicing, with clear arrangements for vehicles (sometimes coaches), taxis, cycles, waste collection and loading that minimise impacts on surrounding streets and neighbouring uses.
Amenity standards – protect the living conditions of neighbouring occupiers and provide a good environment for guests by managing noise, privacy, overlooking, lighting, hours of operation and the effects of plant and equipment.
Accessibility – embed inclusive design throughout the building and its approaches, including step-free access, accessible shared facilities and the often-stated requirement for 10% wheelchair-adaptable accommodation.
Active frontage – create an attractive and welcoming street presence through well-designed entrances, transparent and animated ground-floor uses, and layouts that contribute to natural surveillance and the vitality of the surrounding area.

Five boroughs (15%) also require ancillary amenities and facilities within hotel developments to be available for wider public use. In Southwark, for example, 10% of a hotel development’s floorspace must provide ancillary facilities for public use and employment. Lambeth and Newham similarly expect leisure facilities to be accessible to non-hotel visitors. These requirements can introduce additional operational and management considerations for hotel schemes.

What does this mean for your hotel development?

For developers, the key message is that London remains supportive of hotel growth, but the prospect of a successful planning outcome is heavily dependent on identifying the right site and understanding and addressing borough-specific policy requirements from the outset. Proposals are most likely to succeed in town centres, the CAZ, Opportunity Areas and other locations with strong public transport accessibility.

Our key takeaway messages are:

Test the location early: confirm whether the borough directs hotels to particular local centres, growth areas or transport-accessible locations, and establish whether a sequential assessment is needed and, if so, whether that assessment will present compelling evidence.
Address competing land uses: demonstrate that the scheme will not displace existing or planned housing, undermine employment land or conflict with other protected uses. A period of marketing evidence or an assessment of local demand may be required where an existing commercial use would be lost.
Build the evidence base: where relevant, provide a robust assessment of hotel need, ensure the hotel scheme is differentiated from other existing/emerging hotels, and explain why the proposal would not result in overconcentration of visitor accommodation.
Design for operation as well as appearance: resolve access, servicing, deliveries, waste, noise, lighting, inclusive access and active frontage requirements at an early stage. Public access to ancillary facilities may also be expected in some boroughs.

Conclusion

London’s policy framework is positive about the development of new hotels and visitor accommodation, but support is neither uniform nor unconditional. The strongest prospects are in accessible, well-connected locations where a proposal complements and strengthens town-centre activity or a recognised growth area. Applicants must show that schemes will not undermine housing or employment priorities, and they will not contribute to an overconcentration of hotels or fall short on design and operational matters.

Early policy analysis is essential. Understanding the borough-specific position, and responding clearly to its location, land-use and design requirements, can help identify risks, shape a stronger proposal and build a more persuasive planning case for development.

Please do get in touch if you would like to discuss your hotel and visitor accommodation projects in London with our team.

The local application of the national scheme of delegation

Jennie Baker, Sean Farrissey & Ross Raftery 03 Nov 2026

The national scheme of delegation for planning decisions came into force on 31 October. Application types included in ‘Schedule 1’ can no longer be determined by planning committees[1]. For all applications on ‘Schedule 2’, planning committee determination is possible, but should be exceptional, according to statutory guidance[2].

This blog explores the local procedures being established to encourage a smooth transition and considers whether local triage will lead to determination by committee being the exception. We discuss:

why understanding local constitution and triage arrangements is key
some local triage examples
local examples of what might ‘pass’ the gateway test
a picture of emerging local authority triage criteria flowing from those examples
implications for Councils that have not changed their constitutions to reflect the national scheme
the initial conclusions that might be drawn and what might lie ahead

Background

Our June blog ‘Delegation default: power to the Chief Planner’ explained the statutory context[3] and how the proposals had evolved. We also included this decision making flowchart, discussed below, and the list of applications on either Schedule 1 or 2. Some application types are not included on either schedule and some will be ‘own-interest’ applications. The statutory guidance sets out the ‘gateway test’[4] that an application must pass to be referred to a Planning Committee for decision by the nominated officer and nominated member (nominated persons):

“At a minimum, at least one of the following statutory criteria must be met for a referral to committee to be considered to meet that threshold:

A. where the application raises an economic, social or environmental issue of significance to the local area

B. where the application raises a significant planning matter having regard to the development plan and any other material considerations”

However, before reaching this statutory test, planning authorities can set local triage arrangements as a mechanism intended to avoid overwhelming decision-makers and delaying decisions. This provides the only scope for local variation and is where we have focused our analysis in this blog.

The Regulations will not apply to development corporations, Homes and Communities Agency, National Park Authorities or the Broads Authority[5], because they are not “relevant planning authorities”[6]. These authorities have not needed to amend their constitutions, committee sizes or decision-making processes.

But what of the relevant planning authorities who have not amended their local schemes of delegation to comply with the new legislation? We discuss this at the end of this blog, as hopefully this will be a short term position and soon clarified.

Understanding local constitution and triage arrangements is key

Our decision-making flowchart has, at its centre, some complicated options for how an authority might decide which determination route a Schedule 2 application might follow.

This is because the green boxes in the diagram reflect potential, optional, local arrangements. The statutory guidance says:

“Where local planning authorities anticipate that there may be a significant number of Schedule 2 or own-interest applications which may need to be considered for referral to committee they may wish to put in place a triage system to ensure that the nominated officer and nominated member of the committee are not overwhelmed and to avoid any unnecessary delays in planning decision making”.

Many local planning authorities have established or are in the process of establishing varying approaches to local triage.

Some local triage examples

We have reviewed a few different proposed[7] approaches to triaging applications, which have been presented to a committee or full Council. We cannot say how commonplace different approaches will be, as there can be many different local triage procedures, but the below provides an indication as to what can be expected. In addition to the examples emerging, the Planning Advisory Service has provided some hypothetical worked examples of how to deal with Schedule 2 applications in practice.[8]

We outline below what we consider to be interesting elements of proposed local arrangements[9], rather than summarising the examples in full. A summary of the emerging position follows the examples.


	London Borough of Bromley[10]: A weekly list will identify whether applications are Schedule 1 or Schedule 2. A Councillor (not just the relevant Ward Member or Planning Committee Member) has three weeks to ‘call-in’. The nominated officer and member will decide which of these goes to committee by applying the gateway test. Informal guidance to be issued to all members to help with understanding the new restrictions and processes
	London Borough of Merton[11]: Schedule 2 application should be determined by officers, unless the Nominated Member and Nominated Officer or their authorised substitute agree to refer it to committee under the gateway test within 28 days of the date of the valid registration of the application. The Gateway Test must be applied to a ‘Residual Schedule 2 Application’[12], to decide whether it needs to be reported to Planning Committee in a list of 15 circumstances including “Where conflict arises between the officer's recommendation and the advice issued by Historic England, the Environment Agency or other body with similar statutory status”
	East Suffolk Council[13]: Two routes for Schedule 2 to be determined by committee – Referral Panel and Call-in The Referral Panel is comprised of the Chair and Vice-Chair of the relevant Planning Committee as well as two nominated Planning Committee members. Operates where officer recommendation is contrary to material planning consideration comments received from a Town or Parish Council, Ward Member or a statutory consultee. The Planning Referral Panel may conclude that a ‘Relevant Schedule 2 application’[14] should be referred to the Planning Committee, which is an advisory to the Nominated Member, but the final decision on the determination route will be made by the Nominated Officer. Call-in process is triggered if within the 21-day consultation period Town/Parish Council and Ward Member(s) position is contrary to the officer recommendation – or Ward Member requests committee determination. Notification is sent to Planning Committee – a member must respond within 5 days saying it should be considered by the Committee and setting out how they consider it meets the gateway test. A call-in request bypasses the Referral Panel, albeit the advisory position of the call-in is still subject to the application of the gateway test by the nominated persons.
	Wakefield Council[15] The nominated officer is not authorised to determine a Schedule 2 application where the nominated officer and nominated member agree that the application passes the Gateway Test
	North Somerset Council[16] The nominated persons will consider whether an application should be referred to the Planning and Regulatory Committee by applying the Gateway Test when either nominated person considers it necessary or a Ward Councillor, in accordance with the Code of Practice, submits a formal written request using the prescribed form.
	Stockton-on-Tees Borough Council[17]: A Schedule 2 application will receive a referral assessment where one or more of six circumstances applies, including more than 10 qualifying individual letters or emails express a view contrary to the case officer’s proposed recommendation (except tree applications). And/or the nominated officer considers that the application may pass the Gateway Test.
	Sunderland City Council[18]: The gateway test will always be considered in relation to a list of six applications types, provided they fall within Schedule 2 of the Regulations, including where accompanied by an Environmental Statement and where there is an objection from a Statutory Consultee and the Local Planning Authority are minded to approve the application. In addition, all other Schedule 2 applications (with the exception of own interest applications) will be subject to a triage process to assess whether, based on the identified impacts, there is a requirement to proceed to the gateway test.
	Colchester City Council[19] Colchester City Council has produced a ‘referral process at a glance’, which includes scope for member referral requests to be considered:


	Gateway test – local examples of what might ‘pass’ Paragraphs 23 and 24 of the statutory guidance provide examples of what ‘significant’ or ‘significant planning matter’ are in the gateway test. Some Councils are providing their own examples, including Colchester City Council: “Examples may include: Novel or complex policy interpretation. Significant departures from development plan policy. Development raising substantial heritage, transport, environmental or design considerations. Proposals involving major planning judgement. Matters are less likely to constitute significant planning matters where: Development broadly complies with adopted allocations and relevant planning policy. Consultees' concerns have been satisfactorily addressed through amendments or conditions. The issues raised are routine development management matters”. Milton Keynes City Council is to require[20] that all Schedule 2 applications that pass the gateway test are not determined by officers. But the example of what might pass appears to raise the bar higher than in the guidance and requires Member action: “Ward Councillors, Town/Parish Councils and members of the public, when submitting consultation responses, should highlight the following factors for those applications they consider should be referred to Planning Committee: Application raises one or more issues of economic, social or environmental significance to the local area, for example the application is considered to be controversial due to the: Scale and nature of the proposed development (e.g. an outline application covering a strategic urban extension that has been allocated in the Development Plan); Planning history of the site (e.g. where there is a significant and complex history of relevant previous applications on the site that includes decisions allowed on appeal); Sensitivity of the site (e.g. where the proposal could result in significant harm to an asset that is designated for its heritage, biodiversity or landscape importance); and/or That the application raises significant planning matters, for example there is a material conflict with the Council's approved planning policies”. Both the Colchester and Milton Keynes examples leave scope for flexibility in application.

Emerging local authority triage criteria

From the examples above, early emerging criteria include:

Member call-in remains – despite not being anticipated by the statutory guidance,[21] this is a primary feature of the examples above. Indeed, for Bromley this is the triage approach. While a ‘call-in’ will not guarantee referral to committee (still being subject to the gateway test and nominated officer/member agreement), this procedure clearly seeks to keep the local peace by replicating existing political pathways to the planning committee.

Gateway test is the triage too – where an officer is not permitted to determine any application that passes the gateway test (as set out in the 'Background' section above).

Previous referral criteria become new triage criteria – to provide consistency, some planning authorities are simply recreating existing referral criteria as triage criteria. In Stockton-on-Tees, for example, the number of consultation responses received is not irrelevant.

Defining significant – the legislative gateway tests (and accompanying statutory guidance) give broad scope for major applications to be referred to committee where issues of ‘significance’ are raised – some authorities are already trying to narrow this with their own examples of what significant means for their area.

Statutory consultee influence – in at least two of the example arrangements a statutory consultee concern is a reason for considering referral.

Defining deputies broadly – some LPAs have defined which officers are deputies broadly e.g. “Team leaders” so as to seek to ensure that an officer is always available.

Understanding these triage arrangements, particularly in the case of reserved matters approvals, might lead to altering a planning strategy, depending on the decision-maker and their degree of support. However, given that the decision-maker determination route examples all have a political angle, it will take some time and a build-up of consistent decisions on procedural route before such a strategy could be confidently devised.

We are also aware of local authorities that, at least in the short term, will be taking applications to planning committee because they fall into Schedule 2 and a gateway test will be applied in all cases, whereas under the superseded local arrangements they would have been determined via delegated authority.

Councils not changing their constitutions to reflect the national scheme?

Planning magazine[22], Local Government Lawyer[23] and local press (there are likely to be others) have covered four councils who have refused to amend their constitution: Central Bedfordshire, Bolton, Tameside and Fenland.

Wiltshire[24] has also done so, in favour of an amended resolution “That the Council continues to lobby Government to express its opposition to these changes and restore democracy to the local planning system”. However, according to a local newspaper[25] “Councillors were told that if they rejected the proposal, powers existed allowing council lawyers to make the necessary constitutional changes regardless”. We are aware of other Councils in this position – i.e. officers already had authority to amend the constitution to reflect changes to legislation.

There may be authorities who have not yet amended their constitutions, even though officers must seek councillor approval to make amendments.

Simon Ricketts has covered this in his Simonicity blog “What Will Happen If LPAs Miss The 31 Oct NSD Deadline?”. This provides a thorough run through of the legislation and discusses potential implications:

“Local planning authorities have a statutory duty from 31 October to make arrangements that are consistent with the Regulations. It seems to me obvious that any local planning authority which fails to comply is in breach of statutory duty and therefore susceptible to judicial review, in relation to which the remedies available to the High Court include making a declaration that it is in breach, quashing any resolution to make arrangements which are in breach and/or a mandatory order to secure compliance. Such proceedings could be brought by any party showing a sufficient interest in the issue.”

Simon concluded:

“Final word of warning: There is much legal speculation in all of the above”.

Such a conclusion is likely to make us all sit up and question – what is the position?

As non-lawyers we cannot solve that, but we have looked at other contributions to the discussion.

A 21 October Local Government Lawyer (LGL) article[26] included the following:

“Commenting on the trend, a spokesperson for the Ministry of Housing, Communities and Local Government said that where councils have not adopted the constitutional amendments, planning officers will still be able to take decisions in accordance with the new scheme.

The spokesperson said: "These reforms come into force on 31 October and councils will need to comply with the new rules.

"Where committees do not comply, decisions can continue to be taken by planning officers in line with the national scheme."”

Notwithstanding, a follow up LGL article said “Bolton Council has warned that it will be unable to lawfully hold planning committee meetings or determine planning applications from the end of this month”.

Whereas a Biggleswade Today[27] article included a quote from an email from the Chief Executive of Central Bedfordshire, suggesting that they do not consider that applications could not be determined at all because the local scheme has not been amended.

One hopes that instances of councils refusing to amend their constitutions is a short term and relatively small scale problem, but it serves as a further reminder of the need to understand the local position.

In addition, many authorities and/or Councillors are agreeing to the changes to the constitution while voicing their frustration at what they consider to be unacceptable legislation, such as Vale of White Horse and South Oxfordshire[28] and the chair of Colchester Council[29].

Settling in period in the short term, but the politics remain

Anecdotal evidence suggests that the most local authorities will have ensured that their constitutions reflect the 2026 Regulations. Whether or not the authorities that have not done so are permitted to determine applications is not clear – albeit the Government has been quoted as saying that they can do. Therefore, we consider this to be the position – and likely to be both the intention and reading of the Regulations.[30]

Our straw poll of local arrangements and review of press coverage suggests that, in some areas at least, it is likely to be a few weeks until we see a settled picture and it will take longer for best practice to emerge. The Local Government Association is already calling for an early 2027 review of the new procedures, rather than 2028 as required by the Regulations.[31]

Implications, including potential changes to committee frequency

Understanding the local constitution and/or triage arrangements will be critical for anyone considering whether an application needs to be determined by Committee and what that might mean for determination timescales. However, there are several examples of the new arrangements for determining who the decision-maker is being made to reflect the old arrangement, as far as possible.

From a local authority perspective, applying the new procedures consistently will be very important. This will be a frustrating fresh challenge for the authorities that might find themselves sending more applications to Committee than they do at present (or at least considering sending more), because the new triage arrangements are linked to Member referral requests. Will the typical 3-5% of applications being determined by Committee change?[32]

In the coming weeks planning committees and sub-committees may be moved or cancelled, either due to lack of applications or (as in one example we are aware of) having insufficient time to triage Schedule 2 applications. The latter suggesting that there is already some initial overwhelm.

A key concern for the future is that where there are fewer applications going to planning committee, those committees will meet less often, meaning delays in sending potentially significant applications to committee, when they would have been heard by a Committee under both the old and new procedures.

Going forward

One of the last Government’s objectives in bringing forward the national scheme of delegation was to:

“allow planning committees to focus their resources on complex or contentious development where local democratic oversight is required and a balanced planning judgement is made”.

This is not a threshold to be met, which is fortunate given the subjectivity within it.

Such “complex or contentious” applications, and others passing the gateway test, will be considered by a planning committee, as before. Some may continue to be led there by a politician. At this stage, it looks more like new local rules will maintain routes to committee, rather than it being the exception.

The Parliamentary debate in the Commons regarding the draft Regulations[33], where there was strong opposition to them, suggests that adaptation of local committee call-in procedures is accepted by the Government. The Housing and Planning Minister said:

“it will be open to individual LPAs to triage their schedule 2 applications in ways that are appropriate for them […]. Under those arrangements, it would be open to a local planning authority to include a mechanism for councillors to ask for applications that fall under schedule 2 to be considered under the gateway test, and if they meet that test they can be looked at by committee”.

Referring to the approximately 4% of decisions made by committees, the Minister noted that it represented “a substantial proportion of total units in the planning process” and that in the new system they “might not necessarily” be determined by a committee.

In a debate where MPs observed that officers are not always right, the Minister also said that the Regulations were about finding the right level of trust and empowerment for resolving Schedule 1 applications. Schedule 1 is the key area of change from 2 November and the only true area of certainty.

However, we recognise that these reforms have been introduced outside of typical committee cycles – could we see more streamlined (or bolder) approaches to local delegation arrangements following future election cycles?

While the statutory review is some time away, the Government is very likely to monitor authorities’ interpretation of the legislation and statutory guidance and make contact where it has concerns.

On a more positive note, our limited look at emerging triage systems has uncovered innovative local approaches and clear explanations to Members, by officers, of the legal position. This bodes well at the start of a path on which officers are intended to forge the way.

Footnotes
[1] Unless it is concluded to be an ‘own-interest’ application.[2] Planning Committees and the National Scheme of Delegation of Planning Functions: Guidance for local planning authorities in England, June 2026[3] Primarily, sections 319ZZC – 319ZZF of the Town and Country Planning Act 1990, as inserted by the Planning and Infrastructure Act 2025 and The Town and Country Planning (Discharge of Local Planning Authority Functions) (England) Regulations 2026. Sections of the Local Government Act 1972 and other non-planning legislation are also relevant.[4] The term ‘gateway test’ is only used once in the statutory guidance. Reference to Regulation 5(3) criteria is used more frequently, but for simplicity and because local authority documents tend to so, we have used ‘gateway test’.[5] Throughout this blog we refer to local planning authorities (LPAs), but this should be read as excluding these authorities.[6] Town and Country Planning Act 1990, Interpretation of sections 319ZZC to 319ZZE[7] We have obtained this information from Committee Reports and not all websites show whether the position has been agreed. In any event, the position could change fairly swiftly and should not be relied upon[8] Worked Examples: Dealing with Schedule 2 Applications in Practice[9] At the time of writing minutes were not available for all meetings, to confirm the Committee decision[10] https://cds.bromley.gov.uk/ieListDocuments.aspx?CId=133&MId=8315[11] https://democracy.merton.gov.uk/ieListDocuments.aspx?CId=359&MId=4925&Ver=4[12] A Residual Schedule 2 application is a Schedule 2 application, which is not a ‘Triaged Application’. Advertisement Consent and Tree Preservation Order applications are ‘Triaged Applications’.[13] https://eastsuffolk.cmis.uk.com/eastsuffolk/Decisions/tabid/67/ctl/ViewCMIS_DecisionDetails/mid/391/Id/971c8bea-6f17-4bfd-bb1b-bd10f431e209/Default.aspx[14] does not include listed building consent applications linked to a schedule 1 application, variation to listed building consent or works to listed dwellinghouse[15] Appendix 6 - 3.7 - Officer Delegation Scheme.pdf[16] Committee Report NSC[17] Agenda for Council on Wednesday 23rd September 2026, 6.00 pm - Stockton-on-Tees Borough Council[18] Meetings and Events[19]https://colchester.cmis.uk.com/colchester/MeetingCalendar/tabid/70/ctl/ViewMeetingPublic/mid/397/Meeting/1503/Committee/13/Default.aspx[20] https://milton-keynes.moderngov.co.uk/documents/s30751/Planning%20Committee%20-%20Constitution%20Changes.pdf[21] This political approach does not appear to have been anticipated by the statutory guidance (which we do not think the authorities are breaching):“Under the national scheme of delegation, current practices set out in local authority constitutions, such as the power for ward councillors to require cases to be called in for committee consideration or having trigger points for referral to committee if a certain number of objections is reached, will not be possible”. [22] (£) Planning: Fourth council refuses to amend constitution to comply with government’s national delegation scheme[23] Four councils refuse to adopt constitutional changes required for national scheme of delegation for planning decision-making[24] Wiltshire Full Council, 20 October 2026 (Morning and Afternoon Session) watch from 3:07:20 to 3:12[25] https://www.gazetteandherald.co.uk/news/26657630.wiltshire-defies-government-attack-democracy/[26] Four councils refuse to adopt constitutional changes required for national scheme of delegation for planning decision-making[27] Biggleswade Today, re Central Bedfordshire: Planning decisions could be 'significantly disrupted' as Central Beds Council opposes legal change[28] Councils reluctantly approve constitution changes for new planning process[29] https://www.facebook.com/groups/colchester.community/posts/4740922392901180/[30] It should be noted that we have not fully explored potential interface with other local government legislation, including Local Government Acts, which could place other requirements on authorities.[31] Review planning decision rules a year earlier to assess democratic impact, LGA urges government

[32] The Impact Assessment (see footnote below) refers to 96% of applications being determined by officers. The Planning Applications statistical release for June said “Of the 74,500 decisions made during the quarter, 72,100 (97%) were delegated to officers. This percentage has been stable since 2014, having previously increased from around 75% in 2000” https://www.gov.uk/government/statistics/planning-applications-in-england-april-to-june-2026/planning-applications-in-england-april-to-june-2026-statistical-release

[33] https://hansard.parliament.uk/Commons/2026-06-30/debates/293817ec-30f1-40f8-9694-f104011d520c/DelegatedLegislationCommittee

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