A key feature of the 2026 NPPF is the clearer distinction between policies concerned with plan-making and those concerned with decision-making. This is intended to give Local Plans a more defined role, with less need for them to reproduce national policy and a greater focus on the spatial strategy and locally specific matters.
A more standardised and streamlined planning system
The reforms establish a clearer hierarchy within the plan-making system. Spatial Development Strategies (SDS) are intended to provide the strategic framework, with Local Plans sitting beneath them and focusing on local spatial matters and site allocations. This should, in principle, allow strategic matters to be considered at the appropriate geographical scale while reducing duplication between national, strategic and local policy.
The direction of travel is therefore towards a planning system which is more standardised and streamlined. This is reinforced by the new local plan-making process, which is designed around a 30-month end-to-end timetable, supported by three gateways and a more prescribed approach to plan preparation and examination, and importantly, earlier engagement with the Planning Inspectorate. The intention is clearly to change the way in which plans are prepared so that they can be produced more quickly and with greater consistency.
There is a practical sequencing issue as this new system is introduced. With local government reform and the new strategic tier of Spatial Development Strategies at the same time as authorities being expected to move towards the new 30-month Local Plan process, this raises an important question for authorities entering the new system: how should Local Plans progress where the SDS intended to provide the wider strategic context is itself still being prepared?
That transition matters because the ambition for a faster, more prescribed plan-making process depends, in part, on authorities having sufficient clarity about the strategic framework within which their plans are being prepared. The risk is that the process of establishing the new system creates a period of uncertainty at precisely the point when the Government is seeking to accelerate plan-making.
Nevertheless, this represents a significant attempt to address one of the fundamental weaknesses of the planning system: the number of authorities without an up-to-date Local Plan and the length of time it can take to prepare and adopt one.
However, this is not the first major reform of the planning system to seek to accelerate plan-making. The experience of the last fourteen years suggests that the relationship between reform and delivery is more complicated.
Certainty matters: lessons for local plan-making
Clear patterns can be identified in both plan submissions and examination times, demonstrating the influence of major policy interventions and periods of uncertainty. Below we explore the link between the rate at which Local Plans are submitted and the time they take to navigate the examination process and major events, focussing only on plans containing strategic policies which proceeded to be found sound or were withdrawn based on PINS data.
The period before the NPPF in 2012 was characterised by relatively high levels of plan-making activity. The era of Regional Strategies, and the publication of Planning for Growth in 2011 coincided with a sustained flow of submissions, reflecting a comparatively clear strategic planning framework. The publication of the NPPF in 2012 does not appear to have resulted in a sustained reduction in submission rates. While activity fluctuated in the years that followed, submission levels remained comparatively strong until the latter part of the decade.
Different iterations of national policy have included various ‘transitional arrangements’, but, in earlier versions, a consistent measure was whether the plan had been submitted by 24 January 2019. In fact, plan submission rates (in the post NPPF world) peaked in 2018 when the NPPF was first revised, but ahead of that key transitional arrangement.
A renewed period of uncertainty emerged from 2019 onwards, with the further revisions to the NPPF, introduction of the Standard Method, Housing Delivery Test, numerous ministerial statements and successive planning reform proposals creating an increasingly fluid policy environment. Authorities were often faced with a ‘stick or twist’ decision: progress plans under the existing system or wait for further reform. From 2019 to 2023 there was a dramatic and sustained decline in the number of plans submitted for examination. Sat alongside that fluid policy environment: political turmoil and a global pandemic.
Submission rates have recovered over recent years, but arguably this is a consequence of the draft and final versions of the NPPF published in 2024, the transitional arrangements allowing for submission before 31 December 2026, and the prospect of greater housing requirements / Grey Belt policies applying if plans were delayed.
Aside from Local Plans already at examination, anecdotal evidence suggests more than 100 are due to be submitted by the end of the year, in order to proceed under the ‘legacy system’. That is more than double the number of Plans submitted in any one year since 2006 and compares to an average of around 35 each year between 2012 to 2025. If realised, that volume of submissions would place unprecedented pressure on the examination system and provide a first major test of whether the reformed framework can maintain momentum whilst two plan-making systems operate in parallel.
Examination times for these plans reveal a related, but not identical, trend. Between 2006 and 2011, plans were generally adopted within 0.85 to 1.26 years of submission. Since 2012, the period from submission to adoption has steadily increased, peaking at an average of 2.45 years for plans submitted in 2021. While examination times have reduced slightly in more recent years, these figures should be treated with caution given that many plans submitted recently have yet to complete the examination process.
| Submission year | Average time from submission to adoption |
| 2012 | 1.47 |
| 2013 | 1.64 |
| 2014 | 1.81 |
| 2015 | 1.91 |
| 2016 | 2.02 |
| 2017 | 2.16 |
| 2018 | 2.23 |
| 2019 | 2.23 |
| 2020 | 2.29 |
| 2021 | 2.45 |
| 2022 | 1.90 |
| 2023 | 1.90 |
| 2024 | 1.48 |
It would be difficult to attribute this increase to any single policy intervention. However, the trend broadly coincides with a period characterised by repeated changes to national planning policy, evolving approaches to housing need, increasing evidence requirements and growing scrutiny of plan soundness.
While major reforms appear to have a clearer and more immediate effect on submission rates, their influence on examinations is likely to be more indirect, increasing the amount of evidence, policy interpretation and testing required before plans can proceed to adoption. The result is a system in which plans have generally taken longer to navigate the examination process than was the case in the years immediately preceding the NPPF.
The experience of the past fourteen years suggests that major changes to the plan-making framework can have short-term consequences. Periods of policy uncertainty have often been associated with lower submission rates, whereas clearly defined transitional arrangements appear to influence the timing of submissions.
Those changes are not limited to the NPPF, or plan-making processes, but come alongside the reintroduction of spatial planning, and local government reform.
A different kind of reform?
There are reasons to believe the 2026 reforms may avoid some of the difficulties experienced following previous policy changes. The clearer distinction between national and local policy, the more prescribed plan-making process and the move towards standardised evidence requirements should all reduce opportunities for duplication and narrow debate. Nevertheless, the scale of change means that all stakeholders will inevitably spend time testing and interpreting the new policy and process.
The lesson from the past 14 years is not that reform inevitably slows plan-making. Rather, it is that certainty matters. The periods associated with the highest rates of plan submission were generally those in which local planning authorities had confidence in the policy framework within which their plans would be examined. The challenge for the 2026 NPPF is therefore not simply to create a faster plan-making system, but to establish that certainty quickly. If it succeeds, the result could be a substantial increase in plan coverage, housing delivery and economic growth. If it does not, the planning system risks exchanging one period of transition for another.
To discuss plan-making in the NPPF 2026, please contact David Murray-Cox or Olivia Carr.
8 September 2026
