Hand in hand with Purpose-Built Student Accommodation (PBSA)
Policy regarding co-living (in policy terms called: Large Scale Purpose-Built Shared Living or LSPBSL) is covered in Draft Policy HN5, which now combines all specialist accommodation (Purpose-Built Student Accommodation, LSPBSL, and Specialist, Supported and Older Person’s Accommodation) into one policy. While there are still specific requirements for each type of accommodation within, it is notable that the Draft London Plan intends to group these residential types together under one policy. Co-living has often been compared to student accommodation, despite serving a distinct market and purpose, therefore, aligning PBSA and LSPBSL so closely under one policy may reinforce these comparisons rather than clarify the distinction between the two.
The demand for housing deliverability
The Spatial Strategy presented in Draft Policy MBUL1 acknowledges the challenges associated with delivering development at scale to meet London's housing needs. Within, specialist housing products such as co-living are identified as potential ways to improve scheme value, particularly in the early phases of larger developments.
For larger regeneration and mixed-use sites, co-living may increasingly be viewed as a delivery tool as much as a residential product. Early delivery of co-living schemes is recognised as a mechanism for promoting scheme viability, generating value that can aid in funding wider development proposals, and accelerating the delivery of other housing products where it previously was considered unviable.
The approach to affordable – Fast Track Route unlocked
The emerging affordable housing Policy HN3 retains payment in lieu as the default position for LSPBSL. However, unlike current London Plan Policy H16, on-site provision of conventional affordable housing is explicitly noted as an alternative option for development where such an opportunity exists. LSPBSL schemes with a payment in lieu remain subject to the Viability Tested Route, however, one of the most significant changes is that for the first time co-living developments can qualify for the Fast Track Route if they provide policy-compliant on-site affordable housing. The current fixed contribution requirements of 35% or 50% are proposed to be replaced by the threshold levels set out in Policy HN3 ranging from 20% to 50% (depending on Borough and land type).
This change could prove significant for larger schemes where conventional residential accommodation is already proposed. In such circumstances, it may be more practical and viable for affordable housing requirements to be delivered as part of a wider residential offer rather than through a payment in lieu contribution. Where a scheme can accommodate both products, the ability to utilise the Fast Track Route will provide additional certainty, deliverability and potential for sites to come forward with a blended offer.
Amenity standards
Draft Policy HN5 no longer makes explicit mention of detailed amenity requirements (for example communal kitchens, laundry facilities, concierge services) as they are now detailed in the LPG. The blanket term of ‘social interaction and communal living’ is also used to describe the expectation of amenity on site, reinforcing the objective of co-living development to provide a collaborative living environment between the collective of residents.
The requirement for 10% of units to be wheelchair-accessible remains, with an additional note that, where possible, these units should be prioritised on the ground floor, while provision on upper floors is also supported in buildings with two or more lifts. Part M Volume 2 of the Building Regulations remains in place, with further guidance on accessible kitchens also provided.
The provision of cycle parking has been clarified within Draft Policy GHR11. Utilising the new ‘cycle parking bands’, the policy now replaces the 0.75 spaces requirement within the LPG for a lower 0.7 spaces per bed figure in Band 1, 2 and Brownfield Opportunity Areas (BOA), 0.6 in Band 3, and 0.5 in Band 4. We expect these changes will be welcomed by developers in consideration of the other requirements expected of co-living development, with the lower quantum helping to free up floorspace for other amenities or potentially more bed spaces.
Ultimately (as has been the case since its adoption) co-living standards are to be assessed against the recently adopted Large-Scale Purpose-Built Shared Living LPG published in 2024. While this presents its own challenges, Paragraph 3.3.3 of the Guidance confirms that:
“Some flexibility in the assessment of LSPBSL applications against these recommended benchmarks may be applied to the design, scale and provision of these facilities in consideration of the site’s location and context, or other scheme-specific factors where it is demonstrated that qualitatively good design outcomes are being achieved.”
Therefore, in the limited instance of cycle parking, developers should expect more of the same as to how policy will be interpreted in terms of the design and quality of co-living spaces.
Location, location, location
Draft Policy HN5 identifies that where spatial concentrations or proliferation of PBSA or LSPBSL accommodation exist compared to conventional housing, and the extent to which it is impacting the ability to ensure mixed and inclusive neighbourhoods, local authorities can develop policy to address this. The supporting text for the policy adds in Paragraph 3.72 that:
“Whilst it is incumbent upon the applicant to ensure LSPBSL accommodation and PBSA is carefully located, designed and managed for the positive benefit of mixed and inclusive neighbourhoods, the LPA may wish to use the Local Plan to define any aspects that might be spatially relevant for an applicant to consider.”
To date, both PBSA and co-living schemes have largely been concentrated around highly accessible locations, transport hubs, opportunity areas and town centres where strong public transport connectivity and access to education and employment supports the operational model. The Draft Plan does not discourage such locations, but it does provide Boroughs with greater scope to assess whether an area is becoming overly dominated by such residential typologies. As mentioned previously, given co-living and PBSA serve very different demographics and purposes, it does not seem appropriate for a concentration of one typology to limit the bringing forward of another.
A number of local authorities have already been setting location and spatial concentration limits in adopted or emerging Local Plan policy (e.g. LB Lambeth, LB Wandsworth and LB Islington). So, this direction of travel is not new, but it certainly validates, and will encourage, the growing trend we are seeing for local authorities to more strictly control co-living development through local policy.
A Local Plan-driven approach
In the Draft London Plan there is a clear shift towards a more local level of judgement, despite the addition of co-living being specifically referenced as a residential typology for the first time in the most recent draft of the NPPF, with the next version expected in September 2026.
The recurring references to local evidence, concentrations and neighbourhood impacts suggest that the future direction of co-living in London will increasingly be shaped through Local Plans. Boroughs are now explicitly encouraged to assess the presence of co-living within their areas.
This could result in a more varied policy landscape across London. There remains a broad spectrum of understanding and acceptance of co-living between Boroughs, often reflected in the position of the councillors representing their planning committees. Whilst a stronger strategic position from the GLA could have provided additional certainty for authorities less familiar with the product, the more flexible approach enables supportive Boroughs to continue bringing forward schemes that contribute towards housing delivery objectives.
The potential consequence is greater divergence between Boroughs. Local authorities may adopt different thresholds, evidence requirements or spatial criteria when assessing co-living proposals, creating a less consistent development environment across London.
Final thoughts
Overall, the Draft London Plan provides a relatively cautious response for the growth of the co-living sector in the capital. No longer seen as a novelty residential typology, with a number of established schemes across London, the strategic involvement from the GLA is somewhat reduced, with the draft wording seeking to place greater responsibility on local authorities to lead the supply of this housing type, compared with the more rigid approach seen for student accommodation.
However, some of the changes that have been made are positive, particularly placing more emphasis on the possibility for affordable housing to be provided on site as an alternative to a payment in lieu, thereby opening up the potential for the Fast Track Route for co-living schemes for the first time. In co-ordination with the focus on conventional housing delivery and the need to unlock sites, making this explicit could provide the golden thread to support site delivery.
The key risk is the likely patchwork of Borough led Local Plan policies that will continue to grow under this Draft London Plan policy, particularly relating to the matter of over-concentration, which could unnecessarily delay this form of residential accommodation to come forward in the most appropriate locations – particularly when considered alongside PBSA within the same policy framework.
For more information on the emerging policy position for co-living in London, please contact Jordan Bishop and James Simondson.
13 August 2026
