BLOGS

A policy reset with real teeth

England's planning system has been described, variously, as broken, sclerotic, and captured by the status quo. For much of the 2010s and early 2020s, housebuilding fell persistently short of government targets — annual completions consistently lagged the 300,000 homes per year widely cited as necessary to address the housing shortage. Against that backdrop, the Labour government's December 2024 revision to the National Planning Policy Framework (NPPF) represented the most significant overhaul of planning policy in over a decade.

The twin pillars of the reform were blunt: reinstate mandatory housing targets for local authorities — scrapped under the previous Conservative administration — and unlock a new category of land for development. That new category, the so-called "grey belt", was defined as land within the Green Belt that either comprises previously developed land or that makes a limited contribution to the five Green Belt purposes. The message to councils was equally direct: meet your numbers, or speculative development will meet them for you.

Eighteen months on, the data tells a nuanced story.

The pipeline is responding — but not how you might expect

REalyse planning data tracking residential applications from Q1 2023 through Q1 2026 reveals a striking divergence. The total number of applications submitted each quarter has stayed relatively flat — typically between 5,500 and 7,000. But the units proposed within those applications has moved sharply upward since the reforms came into force.

In Q1 2025 — the first full quarter after the updated NPPF — units proposed jumped to around 185,000, up from a trough of approximately 108,000 in Q2 2024, when pre-election uncertainty had dampened developer appetite. By Q4 2025, proposed residential units reached approximately 259,000 in a single quarter, a level not previously seen in the dataset. Q1 2026 has moderated to around 155,000, still comfortably above the 2024 average.

The message embedded in that divergence is important. Fewer applications, but bigger schemes. Developers are not simply filing more planning applications at the margin — they are bringing forward larger, more strategically significant sites, confident that the policy backdrop now supports them. Grey belt land, urban extensions, and stalled strategic allocations are all re-entering the system.

What is also evident in the data is a growing backlog of undecided applications. In 2025, the volume of units sitting in "pending" decisions reached approximately 268,000 — nearly four times the level recorded in 2024 (around 67,000). These are typically the large, complex, often contested applications that require the most resource from planning departments already stretched thin. Policy ambition has outpaced system capacity, and the gap is widening.

Where the pressure is greatest: a South East story

Geography matters enormously in this analysis. REalyse data on the top local authorities by residential units proposed since January 2024 reveals a pipeline that is concentrated heavily in the South East growth corridor and the Oxford–Cambridge Arc — precisely the areas where Green Belt and grey belt policy intersect with the highest housing demand and the most acute local plan pressures.

Ashford in Kent leads the table with over 24,000 units proposed, followed by Central Bedfordshire (nearly 18,000) and Buckinghamshire (nearly 12,000). Huntingdonshire, Bedford and South Cambridgeshire collectively account for a further 28,000-plus units — the Ox-Cam Arc corridor is clearly emerging as a primary development frontier under the new framework.

These are not coincidentally also areas where local plans are under the greatest strain. Several South East authorities entered 2025 without an up-to-date local plan, having shelved or delayed plan reviews during the years of political uncertainty around housing targets. Under the updated NPPF, councils without a plan less than five years old — or whose plan fails to demonstrate a five-year housing land supply — are exposed to the "presumption in favour of sustainable development", effectively weakening their ability to refuse applications on speculative Green Belt or grey belt land.

London boroughs also feature: Tower Hamlets (nearly 11,000 units) and Wandsworth (nearly 8,000) signal that urban intensification is running parallel to peripheral expansion, with higher-density schemes in inner areas complementing the strategic urban extensions being assembled on the fringe.

Notably absent from the top of the table are the major northern conurbations. While Manchester, Leeds and Birmingham are facing housing targets of their own, the data suggests that the immediate pipeline surge has been most acute in the south — where land constraints are sharpest and the grey belt policy has the most to unlock.

Local plans: the missing piece

The grey belt policy is, in one sense, a blunt instrument designed to compensate for a local plan system that has failed to keep pace with housing need. But the instrument only works where developers can identify grey belt land, where councils accept its designation, and — crucially — where local plan allocations exist to guide development to appropriate locations with the right infrastructure.

REalyse data shows that approval rates across residential planning applications in 2024 and 2025 have remained broadly consistent with historical norms — around 68–69% of decided applications receiving consent. But the volume of units in undecided applications in 2025 is a warning sign. Large grey belt and strategic sites are sitting in a planning limbo that could extend their delivery timelines by 12–24 months or more, absorbing developer capital and suppressing actual completions even as the pipeline on paper looks healthy.

For investors and developers using REalyse to track opportunities, the planning data layer — which captures application status, unit counts, decision dates and affordable housing obligations — is becoming an increasingly essential input into site viability modelling. A scheme with 200 units pending for nine months in a district without an up-to-date local plan carries a very different risk profile to one already allocated in an adopted plan with a committee date set.

Comparable sales data from REalyse also illustrates why the stakes are high for land values in these locations. In the South Cambridgeshire and Bedfordshire corridors, residential achieved prices in the £300–£450 per sq ft range for new-build homes are supporting strong residual land values for well-located sites — provided planning risk is manageable. Grey belt designations, where they survive scrutiny, are capable of transforming the economics of a site overnight.

Affordable housing: the friction point

One complication the data does not fully capture — but any developer working through the system feels acutely — is the affordable housing negotiation. The updated NPPF retained the requirement for 50% affordable housing on grey belt land released for development, a "golden rules" condition that has been welcomed by housing associations but resisted by some in the development industry as viability-threatening.

For sites in lower-value markets — parts of the Midlands or South West where achieved prices sit closer to build cost — the 50% affordable threshold can render a grey belt scheme unviable without grant support. The pipeline data from areas like Wychavon and Shropshire, both featuring prominently in the top-15 table, deserves scrutiny on this front: high unit volumes proposed, but with viability pressures that may translate into slower starts and drawn-out Section 106 negotiations.

Outlook: ambition, attrition, and the long game

The headline conclusion from the data is broadly positive: planning reform has succeeded in animating a development pipeline that was visibly shrinking in 2024. The surge in units proposed in 2025, the geographic expansion of the active pipeline, and the growing appetite from developers to bring forward larger, more strategic schemes all point to policy working in the intended direction.

But the gap between units proposed and units built remains cavernous, and the planning system's capacity to process complex, contested grey belt applications at scale has not kept pace with demand. Unless local planning authorities receive meaningful resourcing to clear their backlogs — a point on which the government's Planning and Infrastructure Bill has made some progress — the risk is that a healthy-looking pipeline on paper translates into another cycle of disappointment at the completion stage.

For institutional investors, housebuilders and lenders tracking the market, the next 12–18 months will be the critical test. The sites entering the system now, through Q4 2025 and Q1 2026, will determine whether England's residential output makes a meaningful step toward its 1.5 million home target — or whether reform proves to be, once again, more ambitious in statute than in brick and mortar.

REalyse's planning and pipeline data provides granular visibility on application status, unit counts, affordable housing obligations and decision timelines across every local authority in England, enabling investors and developers to track this story as it unfolds — site by site, district by district.