Planning matters blog

London’s Emergency Housing Package: Final Version and Key Updates

Clare Catherall, Georgia Crowley & Ben Kelway 26 Mar 2026

The GLA has now adopted its eagerly awaited Support for Housebuilding in London London Plan Guidance (LPG), following the draft consultation published in November 2025. This is to be read alongside the joint MHCLG-GLA Policy Note, which further explains the final package of measures and provides additional context.

The LPG introduces a temporary time‑limited planning route that will allow residential schemes on private land providing at least 20% affordable housing to proceed without an upfront viability assessment, provided they meet certain eligibility criteria.

Disappointingly student accommodation and shared living continue to be excluded from this time-limited affordable housing route, despite many consultation responses to the contrary from across the sector.

The measures also relax certain London Plan design requirements covering dual aspect units, dwellings per core, and minimum cycle parking standards.

Overall, the final LPG largely mirrors the consultation document, as covered in previous blogs by Amy Jones and Jennie Baker. The principal changes from the draft relate to the LPG’s 20% affordable housing threshold.

Early Stage Review Mechanism Replaces ‘Gain‑Share’ Review

In place of the consultation draft’s suggested “gain‑share review mechanism” (which would have been triggered if construction had not reached first floor slab by 31 March 2030), the adopted LPG now introduces an Early‑Stage Review mechanism.

A single Early Stage review will now be triggered if ‘substantial implementation’ is not achieved within 30 months of the permission being granted (or another period agreed by the borough or Mayor for referable applications). Substantial implementation is not defined in the LPG but it is expected to reflect a ‘reasonable level of progress’ and in many cases will comprise construction up to a first floor slab. Helpfully the LPG allows for discretion so applicants can agree a bespoke definition of substantial implementation and an appropriate timeframe for reaching that milestone with LPAs/the GLA. This is a positive move since viability reviews of the nature initially suggested in the draft introduce uncertainty and act as a fundamental deterrent for investors.

Perhaps less welcome is the shift towards a position whereby 100% of any surplus profit identified through this early review must now be paid in full to the LPA. The draft had proposed that any surplus identified through a review would be shared 60:40 in the borough’s favour (in line with existing late‑stage review arrangements). This change is clearly intended to further incentivise early implementation and delivery.

Eligibility Timeline

The time‑limited affordable housing route will also now be available to a wider set of schemes than had been suggested. Any applications validated by 31 March 2028 can now benefit from this approach (the draft suggested it could only apply to planning permissions approved by that date). This is a welcome change given that previous timelines were too short to meaningfully benefit many developments. Further guidance is expected to address the overlap between this LPG and the next London Plan for schemes that fall within this eligibility window.

Other Emergency Measures

Other MHCLG emergency measures (local CIL relief and changes to GLA referral) require legislative changes and are therefore expected to take longer to introduce.

The MHCLG Consultation Outcome, also released today, confirms that the local CIL relief will run until 31 March 2030 (previously 31 December 2028). The extension of this timeframe can again only be a positive move.

It also states, however, that CIL liability threshold of £500,000 will continue to be required to benefit from the local CIL relief. This will exclude many developments. The sustained application of such a high threshold feels like a missed opportunity for SME developers.

The exact details of the MHCLG measures are to be released ‘in the spring’.

Lichfields View

The introduction of these measures will be welcomed in principle by the industry, particularly in light of the ongoing decline in housebuilding across the capital. The broader eligibility timeframes, removal of the gain-share mechanism in relation to the 20% affordable housing threshold and the flexibility for applicants to negotiate appropriate milestones for the early stage review are all positive changes improving on the draft measures.

It remains to be seen whether these measures go far enough to meaningfully unlock London’s housing delivery. This will depend to an extent on how fully they are embraced by the industry. The concluding statement of the Joint Policy note is clear though that Government and the Mayor “now expect boroughs, developers and delivery partners to make full use of these measures to approve and build the homes that Londoners urgently need”.

As the London Plan turns five, will its review create a new beginning for housing delivery?

Ross Raftery, Simon Slatford & Mia Busby 20 Mar 2026

This month, the London Plan turned five years old. As most of us look ahead to the next iteration of this Spatial Development Strategy (‘SDS’) - the first under this Government’s direction of being “genuinely strategic” - we consider what this anniversary, the new Local Plans system and the new London Plan could mean for London boroughs and those looking to build new homes across London.

It is now well documented that the Mayor recognises the scale of the housing crisis in London and he has indicated that the new, slimline, London Plan is expected to seek to meet the London’s housing need in full. We watch this space with interest, to see how that will be achieved. The aim is to have a new London Plan in place by 2027/28, but there is plenty of time to influence what that will contain.

In the intervening period, there are other potential opportunities that will arise for bringing forward new homes:

In certain boroughs, the Five Year Housing Land Supply (‘5YHLS’) requirement will increase dramatically;
There may be trouble ahead for those boroughs who seek to adopt lower housing targets; and
There are many new opportunities to influence emerging local plans or to ensure they keep on the straight and narrow.

We consider these in this blog.

The timeline

Over the next year, there will be changing circumstances at a local, London and national level which will significantly influence the housing position in London (in terms of planning). We have therefore analysed the local plan position for each London borough and in Figure 1 identify what their local plan trajectory is expected to be against key upcoming milestones. These milestones are:

March 2026 - London Plan becomes 5 years old and the basis of calculating the 5YHLS changes to be in line with standard method.
1 July 2026 - NPPF 2024 §78c requires a 20% buffer to be applied where a borough has a housing requirement adopted in the last five years whose annual average housing requirement is 80% of less than the LHN (unless a 20% buffer is already applied).
summer 2026 - anticipated publication of draft London Plan (including its proposed housing distribution, although this will have limited weight).
2027/ early 2028 - GLA’s published target adoption date.

Overall findings are that 11 no. of Local Plans are in place that will run through this period. 10 no. of local plans are currently underway and due to be adopted before the London Plan is adopted and the remainder of plans will be adopted after the new London Plan. We explore the implications of this in more detail below.

The anniversary for 5YHLS

Colleagues have previously analysed the importance of this anniversary[1] and the window of opportunity it creates when measuring the 5YHLS.

Now that the London Plan is five years old, the 5YHLS measurement for decision-making depends on the status of individual Local Plans[2]. If a London borough’s local plan is already five years old, then this reverts to the standard method which is, almost uniformly, higher than the current London Plan targets.

This means that the following boroughs all revert to using the standard method LHN, which is higher than their London Plan target (until they adopt a new Local Plan), creating potential opportunities for speculative planning applications[3]:

Bromley; Camden; City of London; Croydon; Ealing; Enfield; Hackney; Hammersmith and Fulham; Haringey; Harrow; Hillingdon; Hounslow; Kingston upon Thames; Redbridge; and Sutton

July 2026 – 20% buffer

A new 20% buffer was introduced by the Government in the 2024 NPPF (§78c) to help address shortfalls between recent local plans and the new standard method. This new buffer to the 5YHLS calculation will apply to seven London boroughs where their housing target is 80% or less than the LHN and a 20% buffer is not already applied by virtue of the 2023 Housing Delivery Test results:

Barnet; Bexley; Brent; Merton; Waltham Forest; Wandsworth; and Westminster

Combined with the 2023 HDT results, of the boroughs with a plan adopted in the past five years, we anticipate that all will have a 20% buffer applied.

For these boroughs, there could be greater scope to demonstrate an unmet housing need – creating the future opportunity for the broader presumption in favour of development in the draft NPPF to be applied.

Emerging Local Plans

The Government has announced that local planning authorities can submit plans under the existing system until 31 December 2026[4]. While we move to a faster and more streamlined plan-making system with great anticipation, this deadline is having a bearing on boroughs with local plans in preparation.

We expect the following boroughs to try and submit plans for examination before this deadline:

Bromley; Greenwich; Hammersmith & Fulham; Kingston upon Thames and Sutton

Failure to achieve this deadline will mean that boroughs then need to transition to the new Local Plans system promptly, including repeating relevant plan-making steps, so the stakes are high for them to achieve this. This will further delay having an adopted plan in place, when we are meant to be working with a ‘plan based’ system.

To understand the cumulative effect of the transition to the new Local Plans system and layering the timeline for the preparation of the new London Plan, we have reviewed some case study boroughs in more detail:

Hillingdon

Hillingdon’s original ambition was to submit a local plan under the existing plan-making regime, by December 2026. However, in a Cabinet Report[5] officers recommended delaying this process and instead progressing under the new plan-making system.

This approach was, partially, based on Hillingdon’s LHN more than doubling from the London Plan target, and a recognition that the plan was being prepared in advance of the Mayor’s apportionment of London’s LHN to each individual borough. This apportionment could require substantial revisions and further consultation – they considered it is prudent to delay publication of the draft plan, so that the apportioned targets can be considered.

The indicative timetable now proposes submission in September 2027 and adoption in April 2028 which would tie in closely with the London Plan.

Camden

In the alternative, LB Camden submitted its plan for examination in October 2025. However, its proposed housing target is 11,550 additional homes from 2026/27 to 2040/41 – an average of just 770 homes per annum (74% of the annual London Plan target, 1,038 dpa between 2019-29).

This drop in housing requirement was challenged by the GLA[6]. The GLA note that the “current London Plan does not meet London’s identified need and therefore the overall amount of housing required annually should not be expected to reduce.”

The GLA also state that the text at paragraph 4.1.11 of the London Plan[7] is “now considered to be out of date”, in the context of working towards delivering 88,000 homes per annum. The GLA stated that boroughs “should seek, as a minimum, to roll over the current London Plan target beyond 2028/29, including any shortfall accrued to date, and to continue to take proactive measures to increase housing supply.”

The GLA’s position here demonstrates that it is seeking to try and boost housing supply through local plans now – in anticipation of increases in the next London Plan.

While Camden’s position was ultimately agreed in the statement of common ground between the GLA and Camden it could result in a Local Plan being adopted with a materially lower housing target than the current position. This will be superseded by the targets in the next London Plan when it is adopted, but it will effectively ‘bake in’ a housing strategy and site allocations at this lower level for the duration of the plan.

It is also notable that 25 boroughs[8] responded to Camden’s duty to co-operate request and all confirmed that they are not in a position to help Camden identify a 5YHLS.

What this all means for local plan preparation?

The cyclical lag between local plans, the London Plan and, now, the application of the new standard method, continues to create a complex picture of the housing requirement across the capital.

It is expected that the Mayor will redistribute the 86,000 homes per annum LHN for London across boroughs, so that this is met in full. However, achieving this will be reliant on having local plans that are prepared with sufficient allocations and ambition to match this requirement. The current picture is that most local plans will be based on out-of-date housing targets, including those that are continuing to be prepared.

Our analysis of borough’s local plan timetables (Figure 1) indicates that:

there is a group c.11 boroughs with adopted local plans that will remain less than five years old through to 2029-31.
there are c.15 boroughs in the preparation of a local plan now, five of which are seeking to submit ahead of the 31 December 2026 deadline for the current plan-making system. Concerningly, a number of these boroughs are seeking to adopt targets beyond 2029, which will be below the current London Plan target, let alone seeking to meet their LHN. It is unclear if Inspectors and the Mayor will expect these boroughs to meet a draft LHN redistribution figure, or if this will only be applied closer to adoption of the London Plan.
the remaining c.8 boroughs are expected to progress under the new local plan-making system, and their timescales are likely to coincide with the Mayor’s LHN redistribution figure being at an advanced stage. This should lead to the expectation that those boroughs prepare plans to meet this need.

Concluding thoughts

Housing distribution: In order for boroughs to begin to prepare local plans that contribute to achieving London’s LHN as a whole, the distribution of those 86,000 homes cannot come soon enough. This is necessary for effective planning and to avoid local plans being adopted which ‘bake in’ anomalous housing numbers for the next plan period.

HDT methodology: Positively, the Government is proposing to amend the Housing Delivery Test rule book, so that the relevant housing requirement is derived from whichever is the most recently adopted plan (whether it is a spatial development strategy or borough/district-level local plan). If implemented, this will address the risk of boroughs being measured against materially lower targets for the HDT.

5YHLS methodology: The next London Plan will return to primacy as the basis of the 5YHLS from its adoption (likely late 2027/early 2028). However, until then, those boroughs with local plans that are more than five years old will revert to the full LHN for this measure. Based on the potential implication of failing the 5YHLS[9], we anticipate that this will be most relevant to Camden; Hillingdon; Hounslow; Redbridge and Tower Hamlets.

Local elections: with all London borough councillor seats up for election in May 2026, there is the possibility for new local plan committees to introduce yet more uncertainty to this position. This could mean potential delays in local plan preparation, as new councillors/parties seek to understand and influence their local plan.

Clearly, given the complexities of considerations over the next year, the housing position needs to be considered on a borough-by-borough basis, but there are expected to be significant opportunities, both through speculative applications and through engaging in local plan consultations in the context of significant increases in housing requirements.

Footnotes

[1] The Presumption: a London Focus - A Complex Outlook for Calculating Land Supply, Paddy Hynes & Harry Bennett

[2] Until the next London Plan is adopted (stated by the GLA to be 2027, https://www.london.gov.uk/programmes-strategies/planning/london-plan/next-london-plan and in the more recent Hounslow/GLA statement of common ground as ‘early 2028’).

[3] It is recognised that for some boroughs, this is tempered by existing failings in the Housing Delivery Test, but it will add further weight to the importance of housing delivery.

[4] https://www.gov.uk/government/news/new-local-plan-system-launching-early-2026-latest-update

[5] Cabinet Report 15 January 2026. https://modgov.hillingdon.gov.uk/documents/s65395/05%20-%20REPORT%20HC%2020251124%20Local%20Development%20Scheme%202025%20December%20Cabinet%20Report%201.pdf

[6] https://www.camden.gov.uk/documents/d/guest/sd19-statement-of-common-ground-with-the-gla

[7] Paragraph 4.1.11 of the London Plan requires that housing targets beyond the 10-year period of the London Plan targets should draw on the 2017 SHLAA findings, any local evidence of identified capacity.

[8] Barnet, Bexley, Brent, Bromley, City of London, Ealing, Enfield, Greenwich, Hackney, Haringey, Havering, Hillingdon, Hounslow Islington, Lambeth, Lewisham, Merton, Newham, Redbridge, Richmond, Southwark, Tower Hamlets, Waltham Forest, Wandsworth and Westminster

[9]Based on Planning Resource 5YHLS data, these boroughs could see their position fall below five years.

Beyond the Ratios: A Purpose‑Led Green Book

Sakhi Sumaria & James Robertson 12 Mar 2026

HM Treasury’s latest Green Book update brings a much needed reset to how appraisals are developed. The refreshed guidance is clearer, more flexible, and better aligned with the realities faced by practitioners. Perhaps most importantly, the revised guidance introduces a fairer, more balanced framework for assessing investment proposals and business cases across the public, private and charity sectors. It places greater weight on the underlying need for investment, moving beyond the narrow value‑for‑money thresholds that historically have underpinned decision-making processes.

In this blog, we look at the challenges posed by previous versions of the Green Book, show how the latest update creates more space to make a compelling case for investment, and outline the practical considerations to keep in mind when applying the new guidance.

Challenges to date

In an increasingly competitive funding landscape, business cases must clearly articulate strategic fit, demonstrate good public value and provide evidence of deliverability to stand out against a growing volume of high quality submissions. Our decade of experience in business case development and appraisal has highlighted a consistent set of challenges in securing funding. The most significant are set out below.

1. BCRs used as litmus test

For years, Benefit Cost Ratios (BCRs) have been treated as a pass or fail test in gateway decision-making processes. This narrow use of BCRs has, in practice, disadvantaged schemes in certain areas of the country and has sidelined places, even when projects deliver clear strategic and social benefits.

2. Inconsistent treatment of place‑based and distributional impacts

Earlier Green Book guidance name‑checked these issues but offered little on how to assess them, resulting in inconsistent application and appraisals that fail to capture regional and social disparities.

3. No clear steer on proportionality

The Green Book has lacked a clear expectation that appraisal effort should be proportionate to project scale, complexity, and risk. This gap has led to a uniform approach to assessment, where smaller schemes were over‑analysed and large, high‑risk interventions were sometimes insufficiently appraised.

4. Guidance that was hard to use

Past iterations of the Green Book offered depth but not usability, resulting in guidance that was overly complex and failed to tackle many of the practical issues raised by practitioners.

5. Strategic rationale and expected impact

Previous editions of the Green Book acknowledged the importance of linking an investment’s rationale to the outcomes it aims to deliver, but they stopped short of explaining how to build that connection. Without practical guidance on developing a Theory of Change, the five cases of the business case model often became disconnected, weakening the “golden thread” that should tie together a project’s inputs and objectives in the Strategic Case with the outcomes and impacts set out in the Economic Case.

6. Optioneering

Whilst an important element of the appraisal process, the optioneering process and guidance within the previous Green Book was overly cumbersome and disproportionate to many types of intervention.

The new Green Book

The revised Green Book takes significant steps towards addressing challenges practitioners have faced to date. Most notably, it introduces a more holistic approach to developing business cases, placing greater emphasis on building a robust Strategic Case, clearly articulating the case for change, and setting out a well-defined Theory of Change.

The new Green Book is also far more concise, logically structured, and easier to navigate. It focuses on the core principles of appraisal, supported by supplementary technical modelling guidance provided by departments such as MHCLG, DfT and Homes England.

Importantly, the updated guidance places stronger emphasis on assessing social costs and benefits, culminating in a more rounded view of a scheme’s total social value. It removes prescriptive value for money thresholds, giving schemes more flexibility to demonstrate their wider value, through the presentation of net present social value, benefit–cost ratios, return on public sector cost, and net present unit cost in parallel. This shift reduces the historic overreliance on a single metric and enables a more balanced, meaningful assessment of public value.

They key changes are summarised below:

Strategic rationale

Clearer guidance on setting the investment rationale upfront. This includes clearly identifying the market failures and strategic needs that should shape the development of a compelling case for change.
Practitioners are now expected to develop a Theory of Change that sets out a clear line of sight between inputs, outputs, and intended outcomes.
Guidance now requires a clearly defined Business‑as‑Usual scenario, enabling appraisers to better assess the true net additionality of a proposal.
The revised framework gives projects more scope to evidence and explain potential transformational change, encouraging more nuanced consideration of wider place‑based and long‑term benefit

Optioneering

Option generation based on project objectives and critical success factors.
A more flexible and proportionate approach to long-list options appraisal, with several approaches outlined, which can be utilised depending on the scale of investment.

Enhanced Place-based and distributional considerations

Whilst previous iterations to the Green Book over recent years gave more prominence to place-based and distributional impacts these, with hindsight were ultimately secondary considerations with guidance relegated to an Annex form at the back of the Green Book.The inclusion of these now within the main body of the Green Book (Chapter 7) sets a clearer path for the inclusion and consideration of place-based impacts within the appraisal process rather than being pulled back into a purely national view of the impact of intervention. Indeed, the document opens the door for place-based effects to be given more prominence by encouraging practitioners to use place-based analysis to distinguish between the effects of a proposal on their area alongside effects the United Kingdom as a whole. In keeping with a more succinct, framework approach, further guidance on assessing place-based impacts are provided in Section 6 of the updated 2026 MHCLG appraisal guidance (The MHCLG Appraisal Guide).
Clearer guidance on how to quantify and apply distributional weighting to identify how the effects of intervention benefit different groups. This helps to strike a fair balance on the impact of intervention throughout different parts of the country. The previous approach effectively disadvantaged areas in the UK with lower property prices, productivity and labour costs.
Incorporating place‑based economic impacts at the local level helps to strengthen the ‘golden thread’ across all business case dimensions. It also ensures that the Economic Case clearly demonstrates how the proposal contributes to the local economic objectives outlined in the Strategic Case.

Value for money

Continued reliance on supplementary departmental guidance, which will need to be refreshed to ensure alignment with the updated central Green Book principles.
Expanded and more detailed topic specific guidance on areas such as housing, commercial development, employment, and labour supply.
A stronger expectation to use monitoring data and robust research evidence to inform the assumptions underpinning economic appraisal.
Greater clarity on the application of optimism bias which is often inconsistently applied.
Revised discounting guidance is expected to be published in 2026 which is anticipated to include updated discount rates more appropriate for interventions which have longer term transformational impacts.
A reframed approach to value for money, with explicit recognition that proposals with a BCR below 1 can still deliver value, and that BCR thresholds should not be used as rigid decision-making tools.
A shift towards a broader set of value metrics, by considering the BCR alongside other indicators such as return on public sector costs and net present unit costs to better capture social value.
A simplified and more intuitive Appraisal Summary Table, improving transparency.

What does this mean for business cases and funding opportunities going forward?

The newly published HMT Green Book marks an important step forward in how we make the case for investment. As we highlighted in our recent Funding and Business Case Insight, earlier versions of the Green Book, and many funding programmes, placed too much emphasis on meeting strict value for money thresholds. This often overlooked the wider strategic and place-based benefits that many projects deliver. We called for a fairer, more balanced framework that reduces geographic bias and gives areas most in need a genuine opportunity to secure investment.

The revised Green Book moves firmly in that direction. By shifting the focus away from narrow value for money metrics and towards a more holistic evidence base, it enables business cases to present a fuller picture of a project’s impact. By shifting the emphasis beyond narrow BCR thresholds, the revised Green Book creates space for projects that deliver wider economic and social value to make a stronger case for investment across all regions and sectors. But for this to be realised, several practical issues must still be address. These are explored below.

The revised Green Book offers a simpler and more streamlined framework for developing investment proposals. However, it still relies on a suite of technical guidance that shapes how specific benefits are quantified. For its ambitions to be fully realised, technical guidance needs to align with the principles set out in the refreshed Green Book. Only then can appraisal consistently support fair, place‑focused investment decisions.

The latest updates to the Green Book place greater emphasis on establishing an investment rationale upfront, shifting appraisal away from a narrow focus on value for money and toward a more balanced assessment. As a result, business cases can present a more holistic impact of proposed interventions rather than relying solely on traditional economic metrics.

The updated guidance emphasises proportionality, reminding appraisers to match the depth of analysis to a proposal’s scale, cost, complexity and risk. For smaller schemes, this means avoiding unnecessary optioneering and recognising that some economic and social benefits cannot be monetised yet still provide a strong strategic case for investment.

We’ve seen first‑hand how rigid funding criteria and prescriptive application forms can constrain the development of business cases. To unlock the full value of the updated Green Book, funding administrators now need to bring their processes into line with the new guidance by amending application processes so that they are proportionate to requested funding giving all places and projects the chance to secure the funding they need.

Town Centres: “...reports of my death have been greatly exaggerated"

James Singer 27 Feb 2026

In his blog at the beginning of the year on the potential changes for retail and town centre planning on the horizon from the draft 2025 NPPF consultation[1], my colleague James Cox referenced “… the way we use, experience and value our town centres has changed fundamentally”.

This got us thinking about the data behind town centres, and the wider narrative of ‘the death of the high street’ that has grown around the data to forecast the health of a centre (or otherwise).

‘the death of the high street…’

From the early 1980s through to the mid‑2000s, the phrase ‘death of the high street’ barely registered, appearing only in small, irregular spikes[2]. Usage began to rise steadily after 2010 (likely coinciding with a wave of closures following the 2008 financial crisis[3]), before accelerating sharply from around 2017. By the early 2020s, it had reached its highest level on record.

The idea has well and truly taken on a life of its own, well beyond planning circles.

In fact, the phrase has become so culturally embedded that it has even been adopted as the name of an indie punk band from the Midlands…

Figure 1: Google Books Ngram for 'death of the high street'

But whilst the narrative of the “death” of the high street is both recent and populist, it has grown precisely as town centres have been challenged to diversify, in most cases as a response to the structural and economic changes in retail. So, what does the data actually show when we look at the evolving mix of uses on the high street?

What the data shows

There are different ways of approaching this subject, one of which is to look at the total quantum of floorspace and how this has changed over time. Experian data suggests that all retail floorspace totalled 626 million sq ft in 2015 (58 million sq m), which rose to 641 million sq ft (60 million sq m) in 2024, the last full year in which total floorspace figures are available.

Of this, convenience goods[4] floorspace has grown from 153 million sq ft in 2015 (14 million sq m) to 176 million sq ft (16 million sq m) in 2024, whilst comparison goods[5] floorspace has fallen from 472 million sq ft in 2015 (44 million sq m) to 466 million sq ft (43 million sq m) in 2024.

However, the broad quantum of floorspace can only tell so much and is potentially tied to larger macro-economic factors that will influence the amount a population is willing to spend, particularly for comparison goods retailing.

We are, of course, not the first to broach this topic. It is interesting to note academic[6] analysis of five UK cities that suggested a greater level of diversity of uses as the proportion of comparison goods retailing fell between 2000 and 2017, with notable variations across the centres.

National average data from Experian[7] allows us to track changes across the mix and composition of town centre uses since 2015, shown in the graph below. This is, of course, a 'zoomed out' view of town centres over the time, and a notable caveat to the following analysis of national averages is that there have undoubtedly been centres that have experience more drastic changes over the last few years (both for the better, and for the worse). Ultimately, not all locations, regions or types of centres will have fared the same. There is, however, merit in taking a closer look at the headline changes and what this means for how we talk about town centres as an industry.

Rather than wholesale disruption, the data shows a far more balanced series of small adjustments that point to a gradual rebalancing of town centre economies.

Yes, comparison retail is declining in town centres

The clearest trend is the decline of comparison goods retail, dropping from around 36% in 2015 to just under 30% today. There is no single reason for this, which is likely to have resulted from a combination of structural pressures including:

changes in disposable income
disruptions to the visitor economy, which will have recovered at different rates across the regions following COVID-19
growing economic pressures from both rents and business rates on retailers with larger portfolios, contributing to a number of high-profile closures (Debenhams, Arcadia, BHS etc.)
increases in online spending
complications and rising costs across storage, transportation, and logistics networks
competing pressures from larger regional centres and retail parks

However disruptive the loss of large comparison goods retailers may be for individual town centres, the data suggests that this decline is not sudden or chaotic. It is a gentle reduction of less than one percentage point per year and, importantly, these vacancies have generally been filled with alternative uses.

Everyday service‑based uses are quietly growing

In contrast to comparison retailers, other uses have however shown consistent increases:

Restaurants and cafés have grown modestly since 2015, supporting their role as a key draw of social activity across town centres.
Pubs and bars have remained remarkably stable and the proportion has even grown slightly, countering another common narrative about the loss of pubs. However, we would note that the Experian data covers around 3,000 centres and does not include isolated or out-of-centre facilities where the majority of closures[8] may have occurred.
Fast and hot food takeaways in centres have effectively plateaued at just over 6%.
Convenience retail has grown steadily from 8% to 10%, highlighting its ongoing resilience.
Other non‑retail services have grown from 12% to 16%, making them one of the strongest upward trends, driven by a consistent surge of health and beauty openings.
Financial and professional services are the only other category of uses to have shown a consistent decline across centres from 12% to less than 8% over the last decade. This is an example of a broader narrative that does hold true, with last years’ House of Lords Library briefing clearly setting out the key considerations. Hope, however, is on the horizon with the growth of banking hubs[9] providing an innovative model for communities that are no longer able to support multiple dedicated banking branches.

Together, these patterns illustrate a shift towards town centres as social and service hubs, not purely shopping destinations. Places to spend time, meet and socialise, rather than a sole raison d’être to shop.

Vacancy rates are far more stable than the narratives suggest

Perhaps the most interesting aspect of the data is the relative stability of vacancies. Despite COVID‑19 and the associated social lockdowns, disruptions to global supply chains, macro-economic uncertainty, the introduction of Class E, and a decade of media stories about widespread closures, vacancies have only moved within a narrow band of about 12-15%, broadly plateauing since 2020.

Of course, the experience of individual centres may vary across regions and different types of centres reflecting their mix and composition, reliance on specific anchor tenants, and the resilience of their local catchment to wider economic shocks. To a certain extent, the national average somewhat disguises the winners and losers with higher performing centres potentially propping up those that are struggling (maybe the topic for another blog).

Nonetheless, the data suggests that many centres have adjusted effectively to the reduction in comparison goods retailers. This challenges one of the most persistent myths of the high street, that vacancies are spiralling out of control. In reality, there is no sign of the dramatic vacancy spike that dominates media narratives.

Class E provided flexibility, not mayhem

Now, for a moment of personal reflection. I was one of the chorus of planners aghast at the chutzpah (look it up) of the Government driving a horse and cart through decades of carefully crafted retail and town centre policy with the introduction of Use Class E.

Surely, we thought as one, this would mean the end of Local Planning Authorities’ ability to control the mix of uses in their centres, inevitably leading to the widespread loss of town centre retail stores to bubble tea cafes, and the mass conversion of out-of-centre office blocks with dedicated car parking to multi-storey supermarkets.

To my credit, the introduction of Class E in 2020 does mark the only point in the last decade where the proportion of main town centre uses shift at once. Frustratingly, from a data analysis perspective, this coincides with the introduction of nationwide social lockdowns, which somewhat muddies the water.

And what did we see? The proportion of services ticked up (0.8 percentage points), as did vacancies (2.5). The number of retailers fell at a slightly greater rate (-3.6 points from 2020-2026, compared to -2.7 points over 2015-2020), and hospitality uses began a pattern of gentle growth (2.5). But even here the change is an evolution, not a revolution. The world did not end, and all these trends were largely already in play.

In summary, it has been a decade of slow but potentially steady diversification

Town centres may not therefore be dying, but potentially evolving to market, structural and social changes. Retail is still central to town centres with convenience and comparison retails collectively making up around 38% of units, albeit this has fallen from 44% a decade ago. As the proportion of comparison retail stores and financial and professional services across centres has fallen, non-retail services and hospitality uses are quietly and sustainably filling the gaps.

Whilst you can always find examples at the extremes of the average, and this is certainly an area for further research given the broad nature of the analysis[10], the national average data over the last decade tells a story of subtle shifts and places adapting at their own pace.

For planners, the task ahead is not to panic and not to rush to reinvent town centres in response to perceived trends, but to work with the market to refine centres. Given the incremental nature of change, our priorities should focus on managing transitions, shaping the balance of uses across centres, improving the overarching town centre environment, and supporting the underlying social and economic role of town centres.

Footnotes

[1] More of the same for town centres? Reflections on the draft NPPF consultation, James Cox[2] Google Ngram Viewer[3] https://www.theguardian.com/news/datablog/2011/sep/08/high-street-vacancy-rates-retail[4] Consumer goods purchased on a regular basis e.g. food/groceries and cleaning materials[5] Durable goods such as clothing, household goods, furniture, DIY and electrical goods[6] https://doi.org/10.1016/j.cities.2022.104124[7] Weighted to reflect Lichfields’ categories of main town centre uses[8] https://camra.org.uk/articles/2355[9] Banking hubs are shared banking facilities on the high street owned and funded by nine high street banks. The hubs offer a counter service operated by the Post Office, where customers of all major banks and building societies can carry out regular cash transactions. Hubs also offer a community banker service on rotation, where customers can talk to their own bank about more complicated banking issues, with a different bank available on each day of the week. https://www.cashaccess.co.uk/about-us/what-we-do/[10] For example, we do not consider changes to floorspace, disparities across different types of centres, and the rate of change across sub-categories of main town centre uses

Planning matters

London’s Emergency Housing Package: Final Version and Key Updates