Planning matters

Since its first publication in 2012, the National Planning Policy Framework (NPPF) has encouraged local authorities to establish the need, size, type and tenure of housing for different groups, including older people. As set out in Martin Taylor’s blog, the 2025 NPPF consultation (16 December 2025[1]) does not waver from this core principle, which seeks to secure a diverse mix of homes to meet the needs of different groups through the planning system.

Despite this longstanding approach, Lichfields’ Solutions to Age Old Problem Insight identified both in 2019 and the 2024 update that whilst many local plan policies refer in general terms to the needs of older people, few set out a specific requirement for the level of older person’s housing that could be provided or contain allocations for the development of such accommodation. Similarly, only a few local authorities have tended to monitor the delivery of specialist housing for older people. As of 2019, just 14% of development plans in England had policies that identified a requirement for housing for older people and just 8% of English development plans included allocations for housing for older people. The 2024 update showed an improvement in identified specialist housing requirements within development plans to 48% but the number of plans with allocations for specialist housing remained largely static at 9%. 

The ageing population has been a longstanding and significant contributor to household growth. The 2022-based Household Projections shows that the number of over-65 households in England is anticipated to grow by over 3 million between 2022 and 2047, equivalent to 57% of all household growth over this period.

Importantly, older people generally live in smaller households (single or couples) so the housing implications of the population increase will be disproportionately significant. The provision of specialist accommodation for older people can provide social and economic benefits by increasing social interaction, providing safety and security, and helping to meet care needs, whilst also helping to free up general needs housing. It therefore represents an important part of the puzzle to solving the housing crisis.   

This blog considers whether the suite of new Plan-making and Decision-Making Policies within Section 6 of the draft NPPF will require local authorities to properly plan for older person’s housing and, in turn, deliver the step-change in delivery that is required to meet needs. 

There are four key policies within the draft NPPF which consider housing for older people; three of these are plan-making policies which seek to provide greater clarity to local planning authorities over what is expected at the plan-making stage. The fourth is a National Decision-Making Policy (NDMP) which should be used by local planning authorities in the determination of planning applications. 

The draft policies are not substantially different to the current approach within the NPPF, but the restructuring helps provide greater clarity for plan-making and decision-taking. 

 

Draft Plan-making policy HO1 “Assessing the Need for Homes” largely reflects the approach set out in paragraph 63 of the current NPPF (2024), which requires development plans to assess the size, type and tenure of housing or other accommodation to meet the needs of different groups, including older people. 

Whilst the overall number of homes needed is to be addressed through Spatial Development Strategies (SDSs) (part 1 of HO1), part 2 of Policy HO1 states that size, type and tenure requirements should be determined “at the most appropriate level”. This will allow plan-making authorities to adjust their policies to encourage a particular housing mix to respond to local needs. Taking the West of England SDS authorities as an example, it would seem inappropriate for the same approach to be taken to older person’s housing delivery in Bristol, where less than 13% of people are aged over 65, and North Somerset, where almost a quarter of residents (23.9%) are aged 65 or over.

This element of flexibility within Policy HO1 is welcomed but care must be taken to ensure that planning for specialist forms of accommodation does not ‘fall through the cracks’ with the SDS deferring to the local plan and then for local authorities to fail to pick up the mantle.

As recommended in Lichfields’ Insight, clear guidance will need to be published on how housing for older people is calculated when assessing local housing need, with the current 2019 guidance pre-dating the standard method. 

It is important to note that the standard method identifies a minimum housing annual need figure for residential in Use Class C3 and therefore an assessment of need for any older person’s housing falling within Use Class C2, such as care homes, should be in addition to the standard method figure.

It will be important for site promoters and developers to evidence the need for development at both SDS and local plan preparation and examination and make the case for care, retirement and sheltered housing. Lichfields’ Carepacity product can provide up-to-date evidence to assess the need for housing for older people. This will ensure that local authorities prepare development plan policies and identify suitable allocations that are robust in accordance with draft policy HO1. 

 

The draft NPPF’s Plan-making policies HO4 “Land for large scale residential and mixed-use development” and HO5 “Meeting the needs of different groups” both set out specific requirements to identify sites or parts of sites capable of supporting delivery of housing for specific groups, such as older people. 

This is a positive step as it arguably provides the greatest certainty of delivery, ensuring that there are clear expectations for the land use on a given site. The delivery of older person’s housing should be embedded into the allocation policies for large-scale residential sites and this will ensure that development is located in the most sustainable and suitable locations for older person’s housing. Given the low proportion of local plans that currently contain such allocations, this policy could present a step-change in the identification of sites appropriate for older person’s housing.

Policies HO4 and HO5 both set out that policies for a mix of tenures, and therefore consideration of specialist forms of housing, need to be provided on sites for 150 homes or more. Reflecting the housing needs for older people within strategic allocations is important for a number of reasons, including that strategic allocations offer the economies of scale which can often support a mix of different housing types (which might not be viable elsewhere) and thereby contribute to more diverse and sustainable local communities.

However, given the prevalence of viability issues within the residential sector and potential complexities of delivering specialist forms of accommodation alongside general market and affordable housing, the 150-home threshold is unlikely to be appropriate as a national benchmark. Instead, it should be set at a local level to reflect local circumstances and the outcomes of plan-making authorities’ viability assessments to inform local plan preparation. 

 

Policy HO9 is a new NDMP which would provide greater clarity on requirements for different specialist forms of accommodation, including older person’s housing. The draft Policy HO9 part 1a) sets out two key aspects for housing for older people:

• Part i requires a sustainable location with access to frequently used services via sustainable transport; and,
• Part ii requires delivery of housing to M4(2) or M4(3) accessibility standards. 

It should be noted that within the supporting text to the consultation, the government proposes a national minimum target of 40% of new housing over the course of the Plan period to be delivered to M4(2) standards (Policy HO5). It should be confirmed whether this minimum applies to the local authority need or at site level. Once confirmed, this should be explicit within wording of Policy HO9 or deferred to plan-making authorities to determine an appropriate level based on local requirements. 

Policy HO9 part 1b) also provides helpful guidance which will be of relevance to developers of older person’s housing. It suggests that “specialist community-based accommodation”, which could include Integrated Retirement Communities, should be supported by a management plan which will provide a “safe and secure environment for residents”. Whilst there is merit in securing the safety of residents, there is a lack of clarity on how this is would be assessed at application stage and what criteria might need to be met. Specialist community-based accommodation is not defined within the draft NPPF and some clarity on this would be helpful.

As a non-statutory NDMP, Policy HO9 would act as guidance and must be read alongside any policies of the adopted development plan, which would be the basis for decision-making[2] . The consultation asks whether NDMPs could be introduced as statutory in “the most effective manner”, so it will be important to monitor this and other NDMPs going forward.

 

The NPPF consultation takes positive steps to address the lack of clear policy direction at a national and local level for older person’s housing, however this does not feel like the significant change needed to considerably boost the supply of specialist accommodation for old people. 

It is vital that a positive policy landscape is shaped to address the significant needs of the older population and to help free up family housing. In the light of the new policy context, Carepacity will play an even greater role in supporting developers by providing evidence for a robust needs case when assessing housing need in accordance with draft policies HO1 and HO5.

Policies HO4 and HO5 encourage plan-making authorities to allocate sites for specialist forms of accommodation. Lichfields’ evidence shows this is severely lacking in adopted local plans and so that change in approach is welcomed. These policies will help to provide greater certainty of delivery and clearer expectations for the land use, type, mix and tenure on a given site.

The Government should implement Lichfields’ three recommendations to help boost the supply of older person's housing:

1. Planning Practice Guidance (PPG) “Housing for older and disabled people” was last updated in 2019. It is vital that this is revised alongside the publication the NPPF to provide clear guidance on how housing for older people should be considered when assessing housing need, making clear where it forms part of, and where needs are in addition to, the standard method.
    
2. Greater certainty of delivery should be provided by requiring plan-making authorities to allocate sites for specialist accommodation where there is an identified need. This should include updating PPG which currently states “It is up to the plan-making body to decide whether to allocate sites for specialist housing for older people”. 
    
3. The PPG should be updated to clarify how older people’s housing should be considered within CIL Charging Schedules and whether other obligations such as affordable housing should be sought.

Please get in touch if you would like to understand more about the draft NPPF and how the proposed changes could affect your residential developments, or if you would like assistance in preparing representations to the consultation.

The consultation closes to representations on 10 March 2026.