Not since the first publication of the National Planning Policy Framework in 2012 has there been meaningful change for the high street and town centre uses, during which time the way we use, experience and value our town centres has changed fundamentally. Against this backdrop of economic, technological and structural transformation, the current consultation on the NPPF presents a timely opportunity to reassess how planning policy can better respond to evolving retail patterns, support mixed-use centres, and encourage new forms of development that can help underpin healthier high streets.
While the draft NPPF introduces a number of changes to retail policy that may appear unremarkable at face value – with the key retails tests that we are already familiar with remaining in place – there are subtle but significant shifts proposed that will impact on planning within town centres and the uses found within them.
Acknowledging change and supporting repurposing
At a high level, the draft NPPF recognises the evolution of town centres and retail uses and the changing societal ways that we engage, shop and work. There is a clear acceptance that centres are no longer defined solely by their traditional role as destinations to shop and that their long-term vitality depends on a broader mix of uses. Encouragingly, the framework continues to support the repurposing of existing buildings, reflecting the vital role this often has in sustaining town centres.
This flexibility is welcome, particularly in the context of long-term vacancies, surplus retail floorspace and the ongoing shift towards experiential, leisure, community and residential uses within central locations. All of this is manifested in draft Policy TC2 which proposes that ‘substantial weight’ is given to proposals which support the overall vitality and viability of a centre; a big win for those seeking to reoccupy or repurpose vacant spaces.
Traditional retail still matters
Despite this recognition of change, the draft NPPF makes clear that traditional retail remains important. The policy framework continues to support the protection of town centres as the focus for main town centre uses and retains the core mechanisms that have underpinned retail planning for decades: the sequential test and retail impact assessment.
However, the accompanying consultation document explicitly questions whether the sequential approach should continue to be applied in its current form, particularly following the introduction of Use Class E in 2020. The document acknowledges that this more flexible use class has made it significantly easier for retail uses to be delivered in out-of-centre locations without the need for planning permission, potentially undermining the effectiveness of the sequential test.
From “primary shopping areas” to a broader town centre protection?
One of the more substantive policy changes for retail proposals is the proposed removal of the concept of “primary shopping areas”, which is proposed be replaced with a broader definition of “town centres”. Alongside this, the glossary definition of edge of centre (for retail proposals) within the NPPF has been extended to 300 metres from the town centre boundary.
The implications of this shift are significant. By broadening what is considered to be “in centre”, the pool of sites that must be considered as part of a sequential assessment for a retail proposal is likely to increase. For applicants, this could mean a more extensive and potentially more complex site search exercise. It will also strengthen policy protection for existing retail assets that may previously have fallen outside the primary shopping area but within the wider town centre. It also provides more explicit policy support for expansion on town centre sites that were previously located outside of the primary shopping area.
A return to disaggregation?
Another notable change is the potential reintroduction of disaggregation within the sequential assessment process. In line with previous legal judgements, the current NPPF does not expressly mention disaggregation and simply requires applicants to demonstrate flexibility in terms of scale and format, which has generally been considered a reasonable and logical approach. However, proposed new Policy TC3 suggests that, moving forward, applicants will be required to consider whether a proposal could be accommodated across multiple smaller sites within a town centre, rather than on a single, consolidated site:
TC3 “….it is not necessary to demonstrate that a potential town or edge of centre site can accommodate precisely the sale and form of development proposed, and it should be considered whether the type of development proposed could be accommodated across multiple sites”
Assuming Policy TC3 makes it through to the final document, it is likely to open up new debate around the viability and practicality of multi-occupier schemes and, indirectly, act as a brake on investment; directly contrary to the wider aspirations of Government to promote economic growth, wherever possible.
Hot food takeaways and fast-food outlets
The current NPPF seeks, at paragraph 97, to restrict the location of new hot food takeaways and fast-food outlets within walking distances of schools – and other places where young people congregate – unless they are in the town centre. This was a new policy approach introduced in December 2024 without any consultation on either the thrust of the policy or the specific policy wording.
Paragraph 97 is carried forward into the new NPPF under draft Policy HC5 with only a very minor change which seeks to provide ‘clarity’ in inserting that any walking distances should be ‘reasonable’ – without providing any guidance as to how a reasonable walking distance might be defined. It also provides no further clarification as to whether the restrictions apply to both primary as well as secondary schools – or how ‘other places where children and young people congregate’ should be defined. These are issues which applicants and local planning authorities alike have been grappling with since the first introduction of the policy in 2024.
While the consultation document invites views on whether further clarity is required to improve the application of this policy, the opportunity has been missed to consult on a more clearly defined policy approach.
Roadside facilities
Outside of town centres, roadside facilities finally receive some long-overdue attention. Draft Policy S5 explicitly recognises such facilities as acceptable in principle outside settlement boundaries, subject to meeting the requirements of draft Policy TR5.
Draft Policy TR5 provides positive support for new and expanded roadside services where they would meet an unmet need or improve access to electric vehicle charging and alternative fuels. This is a welcome acknowledgment of changing travel patterns and the role these facilities play in supporting the transition to low-carbon transport.
However, the draft policies are notably silent on the retail and food and drink elements that typically form an integral part of roadside facilities. While it might be assumed that such uses fall to be tested against the relevant policy tests, this would seem to be a missed opportunity to clarify, for example, that small scale retail uses proposed as part of new roadside services / infrastructure (e.g. EV charging provision) should be treated as acceptable in principle and this omission risks creating uncertainty for schemes that rely on a mix of uses to be commercially viable.
Final thoughts & next steps
While the consultation draft NPPF carries forward a broadly similar policy approach - requiring local authorities to remain focused on the long term vitality and viability of town centres and applicants to satisfy the impact and sequential test - it does, on closer analysis, propose subtle but potentially significant changes which are likely to have a major bearing on the approach taken in relation to applications for retail and other town centre uses. In other respects, it represents a missed opportunity to provide greater policy clarity – particularly in relation to hot food take away uses and ancillary retail uses which form part of new roadside infrastructure.
If you would like to understand more about the draft NPPF and how the proposed changes could affect your retail or town centre developments, or if you would like assistance in preparing representations to the consultation, please do get in touch.
The consultation closes to representations on 10 March 2026.
