Best-laid plans? The Starmer stocktake

Matthew Spry 17 Jul 2026

Published on 5^th July 2024, as Sir Keir Starmer took office, my Lichfields blog - A new dawn has broken, has it not? – provided a stock take of the new Government’s planning inheritance on housing and identified five policy elements that were “likely to be necessary if the Government is serious about aiming for its 1.5m target” over the five years of the parliament.

As it turned out, the Prime Minister’s term will last a little over two years, shorter than the typical period for securing an outline planning permission for a residential scheme.[1] If the average time it takes to get consent for building new homes is a day longer than the term of any Prime Minister except George Canning or Liz Truss (and perhaps Viscount Goderich), you know you have big problems with your planning system.[2]

The five policy necessities identified by the blog were:

Reform and strengthen the presumption
Update local housing need
Unlock poor quality Green Belt
Remove technical blockages
Lay the ground

With Starmer about to be replaced by Andy Burnham and a new NPPF prepared but not now to be released until after the summer recess, it is worth measuring progress against those asks and the baseline to see if the new dawn is likely to fulfil its promise.

1. Reform and strengthen the presumption

My blog asked for the circumstances in which the presumption in favour of sustainable development applies to be broadened and the tilted balance sharpened through ‘extra tilt’ and some prescription on weights to be applied in the balance of benefits and harms to improve consistency.

The Government did the first part of this quickly. The December 2024 NPPF reinstated the five year housing land supply requirement for every authority irrespective of local plan progress, reversing the December 2023 concessions. Our own estimate is that 65-80% of the country is now operating under the presumption.

However, the Government waited until the December 2025 Consultation NPPF to put forward its response to the second and third parts of the ask (which we unpacked further in this October 2024 blog), with suggested changes that included amending the tilt in the balance from the 2012 formulation of “significantly and demonstrably” to a new “substantially”, and the attribution of “substantial weight to certain benefits, and the limited circumstances in which it is expected that permission would be refused”.[3] Of course, none of this will be in place until the new NPPF is published.

On the debit side, the Government has fallen behind on publishing the Housing Delivery Test which is an important mechanism for triggering access to the presumption.[4] The Government was elected promising to reinstate so-called “mandatory” targets, but has not published one of its measures for enforcing them.

2. Update Local Housing Need

I suggested a simple, stock-based standard method with an affordability adjustment, distributing need more evenly, addressing obvious flaws in relying on circular demographic projections, and opening up more authorities to land release.

This ask was delivered almost to specification, first in draft within weeks of taking office and with tweaks for its final form in December 2024. The method is stock-based, affordability-multiplied, strips out the arbitrary caps and the 35% urban uplift, and is ‘mandatory’ as the basis for need (but not the planned requirement). It raised the assessed need from 305,000 to 370,000, a 21% increase, and redistributed towards the least affordable places. London’s figure landed at 88,000, posing a challenge for the Mayor’s next plan which has just been launched for consultation.[5]

3. Unlock poor quality Green Belt

My blog suggested the automatic ‘substantial’ weight to Green Belt harm to be qualified for previously-developed and low-performing land, and for plan making to require Green Belt reviews with a brown-grey-green sequential approach to meeting needs.

This was delivered, and then some. Grey belt, the Golden Rules, and a route by which development in the Green Belt is not inappropriate where four tests are met, went considerably further than many anticipated. Contrary to the findings of the House of Lords Built Environment Committee,[6] it also seems to be working, albeit the viability burdens it imposes may put a cap on its potential in a suppressed market.[7] The policy requirement for Local Plans to review Green Belt reversed the December 2023 NPPF and makes clear for the first time that Green Belt should be reviewed with the objective of meeting needs.[8]

4. Remove technical blockages

I noted the need for nutrients, the flood risk sequential test, statutory undertaker responsibilities and the section 106 affordable housing cliff edge to be addressed.

The Government has made strides, but it is a difficult area at the intersection of a fractured infrastructure ecosystem, longstanding investment backlogs, and statutory obligations, notably on habitats. The challenge has resembled ‘Wack-a-mole’. Just as the Government addressed one set of blockages (e.g. its deal on water neutrality in North Sussex)[9], new ones appeared (e.g. Anglian Water’s promise to block schemes).[10]

The Building Safety Regulator shifted its performance: a previous maximum of 1,206 starts in a quarter – associated with a growing backlog - shifted after the June 2025 reforms to a reported 7,089 in 2025 Q4 and 6,276 in 2026 Q1.[11]

The Government and Mayor’s London emergency package was produced with measures - a time-limited route at 20% affordable housing without viability assessment, CIL relief, and changes to some London Plan Guidance as it relates to density - that were largely seen as positive, tempered by concerns that they do not go far enough to address the viability crisis.

The Planning and Infrastructure Act 2025 introduced the idea of Environmental Delivery Plans and a Nature Restoration Fund and the first use is likely directed at nutrient neutrality catchments.[12] But it will take time and secondary legislation was laid just last month.[13]

Many of the solutions involve on-site mitigation, paying a levy or buying a credit, all adding to the cost of building a home. Taking into account other economic pressures, this has increased by an estimated £76,000 since 2020.[14]

Making the dysfunctional planning consent process work more effectively and removing the general grit in the system remains work in progress.[15] Delaying release of the NPPF until after summer recess is unhelpful in this regard.

5. Laying the ground

Recognising the long-term nature of any sustainable solution for tackling the housing crisis, my 2024 blog pointed to the need for a platform: strategic plans, local plans, New Towns.

The government has begun to deliver on this, but with added complications. The new plan-making system came into force on 25th March 2026, twenty months into the parliament, with its 30-month preparation timetable, three Gateways and no Duty to Cooperate. In response to the strategic planning question, Spatial Development Strategies are coming, at least in some locations. The New Towns Taskforce began work almost immediately and reported in September 2025, twelve locations became seven in March 2026, and final decisions are expected in late summer 2026, with no dedicated grant programme announced.[16]

Weakening the strategic platform has been:

the fracturing of the Government’s political writ through poor local election results and the national opinion poll performance that ultimately cost Sir Keir his job. In some locations, those running local administrations are at best ambivalent about high levels of housing growth and may believe the Government can be toppled at the next election; this dilutes their motivation to make hard decisions through the formation of local and strategic plans.
The decision to run major policy change in planning – including the SDS and Local Plan making – at the same time as local government reorganisation and devolution changes has also had an impact on the focus of officers and elected members. Was it wise to twin track in this way? Views differ, but the genie is out the bottle and – as a generality - it may now be preferable to resolve the institutional uncertainty and crack on.

Meanwhile the second new NPPF is on its way, although seemingly unlikely to see light under Sir Keir. The December 2025 draft laid out 133 coded policies, national decision-making policies and a restructure that the Government itself describes as the biggest change since 2012.

But that change is not as big as it might have been. The Government decided not to implement s.93 of the Levelling Up and Regeneration Act 2023 and put these policies on a statutory footing. Whether the desired simplification can in fact be achieved without doing so remains to be seen. Many people at the coal face of decision making on applications have their doubts.[17]

What has this produced on the ground?

Just 18 local plans were submitted for examination in 2023/24 (see Figure 1). In 2024/25, the ‘threat’ of the new Standard Method and emerging policy requirement to release Green Belt provided motivation for some of the slowest cohort of plan making LPAs to suddenly realise how quickly they could formulate a local plan working to the December 2023 NPPF under transition arrangements. Submissions fell back to 25 in 2025/26 but now PINS projects 115 submissions in 2026/27.

Figure 1: Local plan submissions

Source: PINS / Lichfields analysis

The implication is that the housing targets in adopted Local Plans are still hovering around the 230,000 mark, as they were in 2024; local plans are still being adopted based on the old Standard Method’s targets; twelve alone in Q1 of 2026. The gap between what’s forward planned and what’s needed has almost doubled.

Of course, an authority commencing preparation of a plan adopts it in 2028/29 earliest, and its allocations (assuming they are deliverable) deliver first completions in the early 2030s. New Local Plans were never likely to contribute meaningfully in this decade.

Housing Delivery

So where are the homes? Figure 2 shows that the rate of housing delivery (as measured by EPC registrations) is lower in 2025/26 than it was in 2023/24, albeit with a small uptick year-on-year from the low of 2024/25. Measuring net additional dwellings 9^th July 2024 to 14^th June 2026 the figure is an estimated 392,400 homes, leaving 1.1m to achieve over the remaining three years of this parliament, broadly similar – as if by magic - to the Standard Method’s circa 370,000 a year.[18]

The OBR does not think this will happen. Its March 2026 forecast has UK net additions falling to a low of 220,000 in 2026-27 before rising to just over 305,000 in 2030-31, a year after the parliament ends.[19] Its verdict on the reforms is that the impact “has yet to meaningfully materialise in outturn”.[20] Full Fact rates the pledge as off track.[21] At the current run rate, England reaches 1.5 million in about 2032.

Figure 2: Housing Delivery (EPC Registrations) (000s)

Source: MHCLG (Housing Supply Indicators of new 2026 Q1 19^th June 2026)

Completions are the rear-view mirror, reflecting the housing market but also the planning system operating in preceding years. In the year to Q1 2024, before Labour took office, only 236,000 homes were granted permission, implying a delivery rate of 190,000 per annum. The forward flow of consents was expected to decline further because the number of applications for major development was down 12%, almost half the level they had been in 2016/17.

Unsurprisingly, therefore, the position on homes granted permission is not (yet) positive – See Figure 3. MHCLG decided to stop publishing its Glenigan-based data on homes granted planning permissions pending data validation, so no official data is available after Q3 2025.[22] However, it has been suggested the number for the 12 months to Q1 2026 is just 186,000.[23] Not auspicious.

Figure 3: Residential Units Granted Permission to Q3 each year (000s)

Source: MHCLG (Glenigan) / Lichfields analysis

However, given these numbers relate to detailed permissions, and it takes two years on average even to get to an outline, this fall is not surprising; it is the echo of the policy trough created in 2022 by the draft NPPF and its December 2023 denouement, and matches the trend anticipated by our assessment of that policy

More promisingly, MHCLG data shows the pipeline is looking up, with the number of homes within planning applications submitted having increased by a third between 2024 and 2025 – see Figure 4, even as the absolute number of applications is down 3%.[24]

Figure 4: Planning applications received – residential units in outline and detailed applications to Q4 2025 (000s)

Source: MHCLG / Lichfields analysis

This is the December 2024 NPPF starting to do its work. Bigger sites, brought forward by promoters responding to higher housing targets and with more opportunity in local authorities previously off-limits due to Green Belt.

How many of these applications expect to be approved is a different question, and given the majority were submitted in 2025 won’t be determined until late 2026 or 2027, this will be significantly influenced by how (and when) the new NPPF lands.

But this surge of applications should convert into more consented homes and boost the supply of homes in 2029/30. That’s the nature of the pipeline, and one the Government now recognises in its focus on tackling the grit.

Conclusions and turning to the demand side

The Government undertook or at least began most of the five suggested ‘supply-side’ planning measures we identified in July 2024 as a pre-requisite for its 1.5m homes ambition, and it executed its reforms much faster than previous Governments did for their equivalents.[25] Housing targets are up and ‘mandatory’, the presumption is engaged across most of the country, the Green Belt is reopened, there is an Act on the statute book, and the plan-making system has been replaced. Yet, housing output fell every year and the 1.5m homes is conclusively beyond reach. A reasonable estimate in the current climate is that the Government might achieve the same “one million homes in a parliament” commitment made by the Sunak Government.[26]

Does that mean supply-side reforms needed to go further? Perhaps – there is always more that could be done, notably the transition arrangements in the December 2024 NPPF that baked in low local plan housing targets, suppressing potential supply by 70,000 homes.

But those polices have an inescapable payback period measured over two electoral cycles.[27]

In July 2024 we concluded our analysis of the five policy measures by saying: “none of this is a silver bullet that diminishes the need for complementary measures to overcome other barriers to housing delivery”.

Early delivery was about releasing the potential of schemes already with permission. Much of this relates to the demand side and the viability crisis arising from wider economic challenges.

Here, to use the parlance of the school report, the Government has been “working towards expectations”.

It created a £39bn funding settlement for affordable housing, but the FT and IFS showed much of this was backloaded, with the increase beyond current rates of investment not rising until after 2029.[28]

The Government recognised the challenges of affordability and has launched various measures to boost home ownership.[29] But it didn’t grasp the nettle of how to find a replacement for Help to Buy. At UKREiiF 2026, the Housing Secretary said he needed “to have conversations” with the Treasury about a stimulus to demand.[30] A report in the Times on 11^th July suggests the Chancellor has been resisting it.[31]

The ongoing approach to viability reform from the Government is seemingly based on the idea (popular in many circles) that there is more land value uplift to be extracted from the planning and development process, by standardising developer profit and suppressing benchmark land values.[32] And yet it is increasingly apparent (from here and overseas) that there are fundamental difficulties in pushing this too far, and Jules Pipe - London Deputy Mayor – has suggested the current cross subsidy model for affordable housing is “surely dead”.[33]

In our July 2024 blog, we identified the risk that the Government’s new dawn for housing delivery would find itself “perceived as a false one”.

In planning terms, it wasn’t, although there is still more to do (e.g. on grit). The reforms are real and set to have a positive effect ahead of 2029, at least for the flow of permissions and – probably – plan coverage and - perhaps - tangible progress with some new towns.

The difficulty for Starmer’s record is that the system his Government reformed runs to a clock that extends beyond what turned out to be his period of office. Burnham may reap some of the benefit if he quickly embraces the demand side ask that is reported to be before him.[34] It will also help if he acts promptly to issue the final NPPF. But the real dividend of a significant increase in the supply of new homes will only sit on his ledger if he wins the next election.

Footnotes

[1] As demonstrated by the 2025 Lichfields research How Long is a Piece of String for LPDF and Richborough.
[2] Per this Wikipedia list
[3] Consultation Draft NPPF Paragraph 7
[4] Nothing has been published since December 2024, and it is now promising to combine data collections for 2024 and 2025 HDTs and publish both results together – see here
[5] The Next London Plan is here. Analysis of this document can be found elsewhere in the Lichfields firmament, but I find the GLA’s decision to continue with ten year housing targets (rather than 20 years more befitting a strategic plan) utterly perplexing.
[6] A rather curious set of findings from its report published on 5th February 2025
[7] Box 3.B of the Budget 2025 reported on research by Marrons which found that 80% of major residential appeals located on grey belt land had been approved, homes that wouldn’t have been built under previous policy.
[8] See December 2024 NPPF para 146
[9] See its 8th October announcement: Thousands of new homes get the go ahead in North Sussex
[10] See this BBC news item. Subsequently addressed – at least in part - via the announcement on 2nd July 2026
[11] As reported in Housing Supply : indicators of new supply, England: January to March 2026
[12] See Notification from Natural England to Secretary of State
[13] A summary is provided in this DEFRA blog
[14] See this HBF report The viability Crunch: Analysing the impact of policy, tax, and regulatory pressures on home building May 2026
[15] As captured in the Minister of State’s speech to UKREiiF. Work by Lichfields on this for the LPDF will be launched on 23rd July 2026
[16] Lichfields contributed to the New Towns Taskforce report to Government (September 2025)
[17] A review of different perspectives is provided by Planning Resource here (£)
[18] MHCLG, Housing supply: indicators of new supply, England: January to March 2026
[19] Not all of these 305,000 are in England, obviously.
[20] OBR, Economic and Fiscal Outlook, March 2026.
[21] Full Fact Government Tracker on 1.5 million homes
[22] In its 19th June 2026 publication MHCLG states: “The latest figures on the number of residential units permitted provided by Glenigan have been removed from this publication while MHCLG and Glenigan undertake further quality assurance.”
[23] See Savills - English Housing supply Q1 2026
[24] MHCLG Planning applications in England: January to March 2026 - statistical release Published 19 June 2026
[25] Compare for example the timelines of the Blair Government with PPG3
[26] DLUHC, Measuring Progress towards one million homes, 24th May 2024
[27] Supply-side policies that aim to remove an existing pathway to permission and delivery act far more quickly: A yet to be determined application prepared pursuant to a positive planning policy can be refused the day after a new policy is introduced.
[28] Reported in the Financial Times England’s social housing funds ‘less generous’ than £39bn settlement suggests 12 June 2025 (£)
[29] For example, a mortgage guarantee scheme, changes to financial regulations to allow more loans at over 4.5 times a buyer’s income and the recent consultation on First Time Buyer ISA
[30] Reported by BD, 21 May 2026.
[31] The report in the Times (£) states: “Andy Burnham will be presented with plans to revive the Help to Buy scheme when he enters office on July 20. A review commissioned in the final throes of Starmer’s government by Matthew Pennycook, the housing minister, will explore a new iteration of the scheme following a long tussle with Rachel Reeves. Pennycook’s review, conducted in recent weeks, is understood to have followed an internal report, commissioned by members of the housing department and Treasury, which concluded that rolling out a new version of Help to Buy would not force up house prices. Critics argued that the Help to Buy scheme artificially inflated new-build prices. Whitehall sources said the chancellor blocked attempts to consider a new version since Labour came to power in 2024, citing concerns about inflation.”
[32] Per the December 2025 consultation
[33] In June, Deputy Mayor Jules Pipe told the London Planning Conference that the cross-subsidy model for affordable housing - in which private developers provide or fund low-cost homes using profits from private sales - “is now surely dead". See this Planning Resource report (£)
[34] Per the Times report

Planning matters