Planning matters

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.

 

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.

 

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 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’.

  

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”.