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Pubs Under Pressure: Planning’s Role in the Pub Sector

Pubs Under Pressure: Planning’s Role in the Pub Sector

Lara Baughan 14 May 2026
Last year, on average, one pub closed every day[1]. This year, the Times[2] has suggested up to 3 licensed premises could be closing per day, with the UK hospitality market in severe crisis, driven by soaring energy costs, high wage inflation, and reduced consumer spending with thousands of venues at risk and operators citing mounting unsustainable debt. Behind this headline figure lies a deeper structural shift, with changing consumer habits[3], rising operating costs[4] and growing viability pressures[5] reshaping the pub market.
However, while much of the debate focuses on taxation, business rates and energy costs, planning policy also plays a significant, and sometimes overlooked, role. As the market evolves, a question emerges of whether planning policy remains wholly aligned with today’s shifting trends and economic reality, or whether policy is operating on assumptions that no longer hold true?
This blog considers the national picture before focusing on London’s policy framework and reflecting on how policy can both protect those most valued pubs and enable adaptation in a changing market.

The National Picture

During 2024 and 2025, hundreds of pubs were demolished or converted to alternative uses, contributing to almost 2,000 net losses over the past five years[6]. While closures are not a new phenomenon, the pace and persistence of decline reflect deeper structural challenges rather than a temporary market correction.
Operators are contending with a convergence of cost pressures which are significantly affecting viability. Sharp uplifts in rateable values have pushed up business rates, while rises in the National Living Wage have added to staffing costs in an often labour‑intensive and competitive sector. At the same time, energy prices and supply chain costs remain elevated, and alcohol duty increases continue to erode margins[7]. These pressures coincide with reduced consumer spending, as households absorb higher mortgage repayments and rental costs, limiting the frequency and scale of expenditure alongside structural and generational shifts in drinking and greater interest in health and fitness.
Although recent government announcements on business rate relief[8] may provide some short-term support, they do little to alter the structural economics facing many operators. In certain locations, particularly high-value urban areas, the residual land value of alternative uses can significantly exceed the use value of a pub, intensifying pressure for redevelopment. As this viability gap widens, the role of planning policy becomes more pronounced: should it act as a firm brake on change, or adapt to ensure that protection is both proportionate and sustainable?

London: A Changing Market

This tension is particularly pronounced in London.
Historically, London’s pub culture has been closely linked to office-based working patterns and a strong after-work social scene. However, hybrid working has reduced weekday footfall[9], while broader cultural shifts, including reduced alcohol consumption among younger demographics[10], are reshaping demand.
In areas where multiple pubs once thrived on consistent weekday trade, operators now compete for a smaller and more volatile customer base. The result is increased fragility, particularly for pubs without a distinctive offer, strong heritage identity or clear community function.

The London Plan: Protection as the Default

Against this backdrop, the London Plan adopts a strongly protective stance. This stance is often mirrored elsewhere as the default for pub protection.
The London Plan Policy HC7, Protecting Public Houses, requires boroughs to protect pubs where they have heritage, cultural, economic or social value.
“A In Development Plan Documents, town centre strategies, and planning decisions, boroughs should:

1) protect public houses where they have a heritage, economic, social or cultural value to local communities, or where they contribute to wider policy objectives for town centres, night-time economy areas, Cultural Quarters and Creative Enterprise Zones

2) support proposals for new public houses where they would stimulate town centres, Cultural Quarters, the night-time economy and mixed-use development, taking into account potential negative impacts.

B Applications that propose the loss of public houses with heritage, cultural, economic or social value should be refused unless there is authoritative marketing evidence that demonstrates that there is no realistic prospect of the building being used as a pub in the foreseeable future.

C Development proposals for redevelopment of associated accommodation, facilities or development within the curtilage of the public house that would compromise the operation or viability of the public house use should be resisted.”
The intention is clear and widely supported; pubs can act as important community anchors, contribute to the night-time economy and often hold heritage value. However, in practice, the breadth of the policy  and notably its application presents challenges.
The criteria (heritage, cultural, economic or social value) are wide-ranging and often difficult to disapply. It can be argued that almost all pubs contribute in some way socially or economically. This, in combination with often some local objection (we all have our favourite pub!) means protection is often the default position irrespective of viability context or market change. The placing of pubs within a ‘sui generis’ class means it can often be difficult to convert, even to other town centre / hospitality uses.
This creates a key question particularly for the emerging London Plan, but also for other Plans: should all pubs be protected equally, or should policy distinguish more clearly between those of strategic or exceptional value to preserve the best, but not to protect the all?
A blanket approach risks dispersing investment thinly across struggling assets, rather than focusing protection where it delivers the greatest public benefit.

A Practical Example: Reconfiguration Over Retention

Recent experience demonstrates that a more nuanced approach can be possible and can add to vitality and viability in town centres.
Lichfields supported an application at 10 New Bridge Street in the City of London, involving the reconfiguration of an existing public house. The proposals included a reduction in overall pub floorspace, with the removal of upper floor areas that functioned largely as circulation and ancillary space.
While this technically conflicted with Policy HC7 due to the net loss of pub floorspace, the scheme materially improved the quality and functionality of the retained space. The reconfigured layout delivered a more efficient, commercially viable and operationally coherent ‘pub’ offer, but with significantly enhanced food capability, transforming an almost exclusively wet trade to an all-day coffee / food hub based destination.
This was not without objection, but at the decision making stage, the City of London recognised that the proposals enhanced the long-term sustainability of the use, and provided a destination which would enhance place and provide a destination, despite the numerical reduction in floorspace.
The case illustrates an important principle, whereby viability and functional optimisation can, in some circumstances, better secure a future than rigid adherence to quantitative floorspace retention.

 

Image credit: PixelFlakes

 

Towards a More Targeted Policy Framework

With the next London Plan expected to be adopted in 2027[11], there could be opportunity to refine the policy approach.
This is not an argument against pub protection. Rather, it is a case for more targeted and evidence-based evaluation that reflects the structural shifts affecting the sector and which seeks to preserve the best. A more nuanced framework could distinguish more clearly between pubs of exceptional heritage, architectural or community significance and those whose contribution, while valued, is less strategically critical. In doing so, policy could prioritise safeguarding assets that genuinely function as heritage examples, community and cultural anchors or key components of the night-time economy.
Importantly, policy could also provide more explicit support for evolution, flexibility and reconfiguration proposals that often help safeguard operational sustainability. As demonstrated in practice, retaining nominal floorspace does not necessarily secure a pub’s future if the space is inefficient or poorly configured. Allowing flexibility where proposals demonstrably improve functionality, quality and long-term resilience could better align policy objectives with commercial reality.
Finally, there may be merit in acknowledging hybrid or complementary models that maintain a pub presence while diversifying income streams. In a sector increasingly characterised by adaptation, whether through food-led offers, workspace integration or mixed-use redevelopment, policy that enables carefully managed evolution may ultimately deliver stronger and more durable outcomes than rigid preservation. Ultimately this could be through reform of Permitted Development or, more widely, through the Use Classes Order.
Such refinements would not dilute protection; rather, they would ensure that it is applied where it delivers the greatest public benefit.

Looking Ahead

Pubs remain an important component of our social and economic fabric. However, the market in which they operate has changed over the past decade, with a ‘perfect storm’ of economic challenges and social and structural changes.
As planning policy evolves, there is a need to balance protection with pragmatism. Ensuring long-term resilience may, in some cases, require adaptation rather than strict preservation.
For applicants, operators and decision-makers alike, the key challenge will be navigating this tension, demonstrating when protection remains justified, and when carefully considered change better secures sustainable outcomes.

 

Footnotes

 

[1] https://www.theguardian.com/business/2025/dec/31/one-pub-a-day-closed-permanently-in-england-and-wales-in-2025

[2] The Times 27 April 2026

[3] https://www.cbre.co.uk/insights/articles/how-are-uk-pubs-adapting-to-modern-drinking-trends

[7] Since Duty Reform in 2023, the Duty on Wine has increased by up to 49% and beer and spirits up to 18%

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Achieving Well-designed Places: A Brave New World or Business as Usual?

Achieving Well-designed Places: A Brave New World or Business as Usual?

Sarah Goy 12 May 2026
While the Government considers the responses that were submitted in respect of the draft National Planning Policy Framework (NPPF) 2025, and we await publication of the new policy, it is useful to take stock of some of the topics that were subject to less scrutiny during the consultation period. Focusing on design and the delivery of well-designed places, this blog considers the direction that national policy is taking and considers what this may mean going forwards. It forms part of a suite of commentary based on the draft NPPF prepared by Lichfields. 
An initial review concludes that there are few significant changes between the current NPPF Chapter 12[1] and Chapter 14 of the 2025 Consultation Draft[2], with there still being an overarching presumption that poorly designed proposals should be refused.
Alongside the draft NPPF, four previous guidance and coding documents have been consolidated into one document; the Design and Placemaking Planning Practice Guidance (DPPPG)[3] will provide a single point of reference for applicants and decision makers – providing greater clarity in the interpretation of design standards.
But is that all there is to it, or does this deserve more than a very short blog?
 
 
Plan-making and decision-making
While the current NPPF promotes a combined plan-making and decision-making approach, Chapter 14 of the draft NPPF makes a distinction between plan-making (DP1 and DP2) and decision making (DP3 and DP4), an approach that has been applied to the whole policy document.
Paragraph 135 of the current NPPF sets out a series of design tests which are to be addressed in the formation of policy and the determination of planning applications, while the ten characteristics of well-designed Places requires users to cross refer to the accompanying National Design Guide. Within the draft NPPF the seven key principles for well-designed places are clearly set out within the decision-making policies section of (Policy DP3), highlighting that development proposals should respond to both their context and the key principles. This policy effectively provides a list of fundamental features that proposals must address. The seven principles are described more fully in Part 1 of the DPPPG, where they are introduced and described as ‘features’, each with their own sub-principles. Reference is also made to the seven principles within the plan-making policies section concerned with setting out clear design expectations; Policy DP1(c) “Set[s] out locally-specific design policies or standards which are necessary to add further detail to the principles in policy DP3,..”  Therefore, while the draft NPPF introduces national development management policy relating to achieving well-designed places, it also provides a mechanism by which locally specific policies can also be established in local plans.
It remains to be seen to what level the seven principles are used within the decision-making process, how effective the approach of including these in national policy is in delivering well-designed places and whether the inclusion of additional site-specific policy will result in either repetition or, indeed, conflict. Lichfields will continue to monitor this to provide future insight.
 
  
Design objectives, characteristics and principles
A quarter of a century has passed since By Design, Urban design in the planning system: towards better practice[4] was published by the (then) Department of the Environment Transport and the Regions and the (former) Commission for Architecture and the Built Environment. The aim of the guidance was to “promote higher standards in urban design”. It was the first major national design guidance of its kind in England and was based upon seven objectives supported by a series of considerations related to aspects of development form. These objectives were set out as a series of aims to promote better urban design. Two decades later the National Design Guide’s ten characteristics provided a series of features to “nurture and sustain a sense of community…. and address environmental issues..” In the most recent draft the seven principles effectively provide a series of rules to achieve well-designed places.  Collectively, this reflects a shift from initial design ambitions to a defined set of criteria that set out what is expected. Further comparisons between the NDG and the DPPPG are made within Charlotte Walker’s blog.
While there is still a degree of cross referencing to DPPPG to provide a more comprehensive explanation of the principles, as there is currently with the NDG, the key shift in the latest iteration is that the principles of achieving well-designed places will be set out clearly within national policy – listed within DP3 and referenced directly within DP1, providing greater emphasis on achieving good design quality.
However, as illustrated in Figure 1 below, the seven key principles represent an effective distillation of the ten characteristics as set out in the National Design Guide. Within DPPPG each ‘feature’ (principle) has an introductory paragraph related to context, highlighting the importance now given to context as an overarching thread. As with the current NPPF and associated guidance, both the draft NPPF and the DPPPG seek to ensure that proposals are sympathetic to local history, features and character while not precluding appropriate innovation and changes. But the main addition is the inclusion of the principle of ‘Climate’ and, in particular, the references to how proposals should “contribute to climate change mitigation and adaption and the transition to net zero...” In the context of the other amendments that do not really move the dial in terms of the focus on design, this is important in showing how design can be used to contribute to the delivery of the Government’s climate change and decarbonisation aspirations.

 


Figure 1: Features of Well-designed Places

 
 
Design coding
Both the current and draft NPPF highlight the necessity of design guides and codes to deliver successful, well-designed places. However, the draft version focusses upon where the use of such guidance would be most appropriate, highlighting “significant site allocations and areas of change”. It no longer specifically references “area-wide” codes or the potential role of Neighbourhood planning groups in “identifying the special qualities of each area”. The change in focus between ‘area-wide codes’ and ‘areas of change’ is more significant than it might initially appear. It indicates a move away from broader geographic areas to more targeted sites, and the associated potential to tighten-up guidance. It remains to be seen whether the local authorities, such as Buckinghamshire Council and Dover District Council, that have started to prepare area-wide codes will continue to do so, or whether they might shift their focus to align with national policy in coding for specific allocations within their area.
 
 
Design review
The emphasis placed on the design review process as a means of ensuring design quality has increased between the existing and draft versions. Currently “LPAs should have regard….to recommendations made by Design Review panels”. Within the 2025 draft, Policy DP1 requires development plans to set out the circumstances in which design review will be required, and Policy DP4 requires that “LPAs should ensure that they have access to and encourage the appropriate use of design review…and take into account their outcomes…”. The requirement for monitoring and review processes, to enable adjustment if required, has also been included, resulting in an approach which more strongly embeds the Design Review process within the policy framework.
 
 
Summary
It is apparent that the key principles within national design guidance have not changed much over the last quarter of a century (and even beyond that). The fundamental objectives, characteristics or principles have broadly remained the same, albeit with some rewording and restructuring, and the critical inclusion of climate most recently. It is the Government’s aspiration for the inclusion of the seven urban design principles within national policy for the first time that provides the opportunity to ensure the delivery of well-designed places, as greater weight can now be afforded under proposed Policy DP3 to the fundamental features of well-designed places. In addition, increased emphasis will be placed on design coding (but for site allocations and masterplans, rather than authority-wide areas), and on the design review process.
It remains to be seen how these changes will affect the plan-making and decision-making processes in practice, and whether these proposed changes become an obstacle to the desired streamlining of the planning system to deliver much needed homes at pace.  Ultimately a degree of subjectivity remains, with the potential for variation resulting from the discretion of decision makers. Lichfields will continue to monitor how the new national policy is being implemented in design terms and will provide further insight on this in the future.
Lichfields’ urban design team can assist our clients to address the proposed changes within the draft by:
  1. Ensuring that the seven design principles are addressed through the design stage, informed by a thorough understanding of the site and its context, to create well-designed places.
  2. Articulate how the design principles are to be met through the preparation of design and access statements.
  3. Supporting clients through the Design Review process to reach high quality, viable design solutions.
  4. Preparing design guides, design codes and masterplans that are proportionate to the scale of change and are based upon a thorough appraisal of the local character with a clear understanding of the economic, social and environmental context.
To discuss your urban design requirements please contact Sarah Goy or George Williams. 

 

Footnotes
[1] https://www.gov.uk/government/publications/national-planning-policy-framework--2
[2] https://www.gov.uk/government/consultations/national-planning-policy-framework-proposed-reforms-and-other-changes-to-the-planning-system [3] https://www.gov.uk/government/consultations/design-and-placemaking-planning-practice-guidance/design-and-placemaking-planning-practice-guidance
[4] https://www.designcouncil.org.uk/fileadmin/uploads/dc/Documents/by-design_0.pdf

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Housing and Planning in Scottish election manifesto pledges

Housing and Planning in Scottish election manifesto pledges

Seán Farrissey, Dominic Bowers & Edward Clarke 05 May 2026
The Scottish election is now days away, and, as we set out in our recent insight focus, the (current) Scottish Government have declared a “Housing Emergency Action Plan” to address the challenge of dwindling housebuilding.
As we have grown used to, every political party's manifesto recognises as a political priority, that additional housing is urgently required, but each party offers different commitments and policy proposals to address the issue. These manifesto statements clearly serve as summaries of broader policy objectives, with more detailed information forthcoming from the successful party. However, they offer a valuable outline of each party’s main priorities and overall direction.

 

 

Only the Liberal Democrats and Labour have committed to an overall housing target, both pledging to build 125,000 homes over the next five years (requiring on average 25,000 per year, an increase of 60% from recent housing stats).
Four parties – including Labour – propose an affordable housing target, of which the SNP’s is the most ambitious, followed by Reform and the Green Party, which have set remarkably similar targets for parties whose other policies on housing diverge significantly. Labour’s pledge would assign just over 40 percent of their target as affordable housing.
Only the Conservatives have chosen not to set any form of housing target, banking on deregulation of national planning policy to deliver an increase in housing.
Recent announcements of the housing Emergency Action Plan and the (election pending) forthcoming new agency More Homes Scotland have been set out by the current government to meet these challenges. To achieve the manifesto pledges, Holyrood decision makers will also be looking to planning reform to do much of the heavy lifting.

 


 

The Conservatives pledge to repeal the National Planning Framework 4 (NPF4, in force since February 2023), which is the most significant change to planning policy of all the parties’ manifestos. Central guidance would be issued only on amenities and design, leaving the remainder of planning policy to councils agreed through Street Votes modelled on those introduced (but not implemented) in the Levelling-up and Regeneration Act in England. 
The Liberal Democrats share a focus on design, aiming to introduce a pattern book of pre-agreed standard housing designs which they hope would speed up approvals. They would keep the NPF4, however, pledging reforms to ensure ‘sufficient’ land is available to developers and reduce the level of pre-approval reports, particularly for SME builders.
Labour are promising further substantial reforms to NPF4, designed to make it a more positive, rules-based framework for development. Similar to Labour’s planning reforms in England after 2024, the presumption in favour of sustainable development would be reintroduced, and a ‘grey belt’ designation would be created, to allow development on sites which do not strongly serve green belt purposes.
Unsurprisingly, the SNP have vowed to enhance the existing planning system, which will need to address the current undersupply in affordable housing to meet the targets set out.
Reform and the Greens are silent on NPF4 and have chosen to focus on other planning matters, particularly the standards for new homes.
Reform and the Conservatives both argue that existing regulations, such as the New Build Heat Standard, which effectively bans oil and gas boilers in new-build homes and buildings, and upcoming net-zero targets for new housing, modelled on the Passivhaus standard and due to be implemented in 2028, form a major additional cost on housebuilding. They have therefore pledged to repeal these – Reform’s position as part of a wider position to repeal all net-zero related targets – and not to introduce any new building regulations in the next parliament. Labour has taken a more cautious position, promising a review of regulations that add costs to housing developments while also considering standardised building requirements.

 

 

By contrast, the Greens and SNP have pledged to strengthen building regulations. The SNP will take forward the Heat in Buildings Bill, which was originally proposed in the previous parliament before being put on hold in response to consultation feedback. The bill will have a less ambitious scope than its original form, but will still set a target for decarbonising heating systems by 2045 and give ministers powers to set minimum energy efficiency standards for certain building types[1]. The Greens have also pledged to take forward this bill, with an intention to decarbonise buildings by 2045.
A further issue in this election cycle has been approaches to rent control. The SNP introduced emergency rent caps in 2022 in response to the cost of living crisis, before making provision for permanent rent controls in the Housing (Scotland) Act 2025. Under this act, ministers have the power to designate rent control areas, in which rent increases for applicable properties will be capped[2]. Under a future SNP government, the first rent control areas would likely be introduced, while the Greens have pledged to take rent controls further, scrapping the exemption made in April 2026 for build to rent and mid-market rent properties and restoring the emergency rent controls which expired in 2025. 

 

 

In contrast, the Conservatives have made the strongest opposition to rent controls, arguing that they have reduced housebuilding and promising to repeal them. Reform have also pledged to remove rent controls, but only for new tenancies, which would lead to a more gradual phase-out. Labour and the Liberal Democrats have not declared a position on this issue but have promised respectively a ‘strategy’ for and to ‘restore confidence’ to the private rented sector, which could suggest weakened or removed rent controls.
All parties have set out a suite of policy choices and targets within their manifestos to meet the significant housing and planning challenges facing Scotland. On taking office, whoever the ruling party is will face the same conditions whereby housebuilding of all types is (in the light of policy 16) falling drastically short of what is required and the dwindling number of homes granted planning permissions pointing to delivery worsening at least in the short term.
If the parties hope to meet their varying housing targets, and with it provide the homes and affordable homes required, a rapid and significant uptick in the number of homes being granted permission will be required. Changes will be necessary to encourage more allocations – or to allow development on non-allocated land – given the dwindling stock of allocations, as covered in Lichfields’ report Misallocating growth?.
Scotland’s rate of house building can ill afford business as usual, it is therefore encouraging that across the parties, housing and planning again seems to be high on the agenda.

 

 

Footnotes

 

[1] https://www.gov.scot/publications/heat-in-buildings-plans/
[2] To the Consumer Price Index (CPI) plus 1 percent, up to a maximum 6 percent.

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The New Plan-Making System: Zen and the Art of Timetable Maintenance

The New Plan-Making System: Zen and the Art of Timetable Maintenance

Dominic Bowers 01 May 2026
The legislation for the new plan-making system is now largely in force and initial guidance has been published.
While the headline change of the new plan-making system is the 30-month target for plan adoption[1], the reforms also aim to improve the transparency and consistency of the preparation process. This blog covers the latter aspect of these reforms: the three gateways an authority must pass through on its way to adoption and, in more detail, the timetable it must maintain to keep progress visible[2].
The new timetables, which replace Local Development Schemes, will be one of the first visible changes brought by the new process now that regulations for the new system are largely in effect. The ability of Local Planning Authorities (LPAs) to keep them updated in a timely manner will therefore be a leading indicator of the ability of the system to make plan-making faster, clearer, and easier to monitor.

The 30-month plan-making process and the gateways

 

The new system features three gateways[3], which act as both check valves for plan-making progress – in the case of Gateways 1 and 2, which cannot be repeated (unless the whole process is restarted)[4] – and opportunities for LPAs to receive two rounds of advice from an appointed assessor on the state of their plan, which should in theory expedite the examination process.
  • Gateway 1 is a ‘self-assessment summary’ of whether the tasks required during the 4-month notice period have been undertaken – passing through Gateway 1 is the start of the 30-month process.

  • Gateway 2 is the seeking of observations and advice from a Planning Inspectorate appointed assessor on aspects of the proposed plan, having consulted on content and the draft vision.

  • Gateway 3 is when a Planning Inspectorate gateway assessor provides observations and advice, and decides whether the plan has met the legal, prescribed requirements, and is ready to be submitted for examination.

 

“Getting ready”

 

The Government’s ‘30-month overview’ guidance includes the below diagram:


30-month local plan process: an overview, MHCLG, 2026

Before an LPA can progress to the 30-month plan-making process, it must first “get ready”. This stage, which leads to Gateway 1, must be at least four months long.
Recommended progress by Gateway 1 is detailed in the guidance[5] with the following headings, which reflect Regulation 21 of the Local Planning Regulations. The self-assessment summary template[6] which LPAs should fill out in Gateway 1 also uses these headings:
  • Preparing and publishing a local plan timetable
  • Establishing project management and governance
  • Consulting and engaging on the plan
  • Scoping the anticipated content of the plan
  • Progressing the Strategic Environmental Assessment (SEA)
This initial stage has been allowed for in terms of the deadlines provided to the first LPAs to commence the new system, the 39 which are required to start preparing their plan by 30 June 2026. Guidance states that “these LPAs must publish a notice of intention to commence plan-making by 30 June 2026 and to publish a Gateway 1 self-assessment by 31 October 2026” [7].
Accordingly, there can be no slippage from the 30 June notice of intention to commence, because this must take place at least four months before the Gateway 1 assessment. Working backwards from 31 October and considering the necessary tasks ahead of 31 October is also a factor in meeting both deadlines.
As the system beds in, we will learn whether LPAs will be able demonstrate progress on these five key matters within the minimum of 4 months, or if we will see LPAs mobilising for plan making earlier, which could see the first notices of intention and timetables published very soon.

In with the timetable and out with the LDS

 

While the speed of plan making is yet to be seen under the new system, an authority’s timeline to completion will have to be reported on in greater detail in the replacement for Local Development Schemes (LDSs). LDSs typically report the intended dates for Regulation 18 and 19 consultations, submission to the Secretary of State and adoption.
In contrast, the new timetables will cover no less than ten milestones in the preparation process, with up to six more where stages have to be repeated or plans revoked[8]. The ten steps in the local plan-making process which must be timetabled (along with the publishing of the timetable itself) are set out in the diagram below:


Lichfields’ interpretation of the Local Planning Regulations, 2026.

A timetable must be first published, at the latest, on the day the notice of intention to commence a local plan is published (or the day a notice to commence a supplementary plan is published, if this is sooner).

VIEW TABLE FOR MORE DETAIL

The timetable must additionally show:
  • The dates of any additional consultation proposed; and/or

  • For each supplementary plan intended to be prepared, the dates of the notice of intention to commence preparation, the notice of consultation and when representations must be received by, intended submission for examination and intended consideration of adoption.
The upshot is that the length of time between milestones – and dates – on the timetable should be shorter than in LDSs, meaning fewer long gaps between events where the state of plan-preparation to observers is unclear. Whether the gaps between actions turn out to be long or short, the progress made is arguably clearer than at present, due to the number of milestones.
This timescale uncertainty should be further reduced by an obligation for LPAs to update their timetables much more frequently than before. LPAs were required to revise their LDS only “at such time as they consider[ed] appropriate” or following a directive from the Secretary of State or Mayor of London[9], meaning that authorities’ LDSs were often years old. This left some timetables practically meaningless, as the pace of plan-making had drifted from the pencilled-in dates over the years.
In contrast, the new legislation requires LPAs undertaking a local plan or review to check that their timetables are up to date every month and to revise it if the timeline has changed[10].
There are then further maintenance requirements. LPAs must revise their timetable:
  • On the day that a relevant plan preparation stage happens[11], to note the date this occurred;
  • As soon as practicably possible after deciding to carry out an additional consultation, to note its start and end dates; and
  • As soon as practicably possible after repeating Gateway 3, pausing a local plan examination (to set out the pause period) or withdrawing or revoking a local plan
Therefore, a timetable should never be more than a month out of date, and often less than this following a significant event.
In practice, however, the timeliness of these dates will depend not only on legislation but on LPA resourcing. As noted above, historically, maintenance of LDSs has varied. It remains to be seen whether the explicit duty to revise a timetable every month will prove effective; it is perhaps notable that the Secretary of State’s directive for all LPAs to update their LDS by March 2025 was later bolstered with a resourcing incentive: an up-to-date LDS was a condition of authorities receiving additional Local Plans Delivery Funding[12]. To meet the new, stricter requirements for timetable maintenance, LPAs may need to streamline their review and publication processes, reorganising available resources accordingly.
When authorities provide a timetable, however, it will be in a much more accessible format than in an LDS. Since an LDS also had to detail which plans an LPA was making, in addition to when, the timetable itself was often found in the middle of a long PDF or Word document. The dates themselves also came in inconsistent format, sometimes by month or quarter, making comparisons across authorities difficult.
In contrast, the government has set out an approved data standard for timetables[13]. LPAs will have to provide two datasets, one on their plan and the other on their plan timetable. The plan data will have to include details including a unique reference, its start and end date, and the plan’s required housing figure. The plan timetable will state the event date, entry date, and actual date (when it occurs) of the minimum ten stages described above[14].
Both datasets will have to be published on the LPA’s webpage as tabular data[15] and provided to the government’s Planning Data Platform for collation. These requirements will allow the state of plan-making in an LPA – and in England as a whole – to be much more easily seen and monitored.
With the regulations for the new plan-making system now largely in effect, the new timetables will be one of the first visible changes brought by the new process. The ability of LPAs to keep to these timetables, provided that the timetables themselves are up-to-date, will be an early indicator of the achievability of the 30-month target.
Taking a positive view, the extensive guidance, new templates and timetable structure should support the plan-making process and encourage frequent reporting, such that the greater detail, frequency and accessibility of plan-making timetables will be a welcome improvement for all participants in the local plan-making process.

 

Footnotes

 

[1] Albeit there are legally required procedures to carry out before the start of this 30-month period, as covered later in the blog.
[2] The requirement for a local plan timetable is provided by s15B of the Planning and Compulsory Purchase Act 2004, as inserted by the Levelling Up and Regeneration Act 2023, and by Part 2 of the Town and Country Planning (Local Planning) (England) Regulations 2026 ‘the Local Planning Regulations’[2].
[3] The legal requirements for each Gateway are in the Local Planning Regulations (Gateway 1 - Reg 21, Gateway 2 - Reg 26 and Gateway 3 - Reg 31, Reg 32 and potentially Reg 33).
[4] Gateway 3 can be repeated, though only if an assessor advises that one or more of the prescribed Gateway 3 requirements have not been met by the plan – see Reg 33.
[8] MHCLG, 2026, Plan and plan timetable template. These ten milestones correspond to fifteen dates in a timetable, since the start and end dates of consultations and gateways 2 and 3 must be reported.
[11] Publishing a self-assessment summary, observations or advice received in Gateway 2 and Gateway 3, and publishing recommendations and reasons in examination.
[15] MHCLG, 2023, Tabular Data Standard guidance, i.e. typically in .csv format

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