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MD3490 Support for Housebuilding London Plan Guidance (SHBLPG)

Key information

Decision type: Mayor

Directorate: Good Growth

Reference code: MD3490

Date signed:

Date published:

Decision by: Philip Graham, Executive Director, Good Growth

Executive summary

This decision form seeks the Mayor’s approval to adopt and publish the Support for Housebuilding London Plan Guidance (SHBLPG). This guidance is key to implementing the government’s October 2025 policy statement; and outlines measures to help accelerate housebuilding.

The SHBLPG provides updated guidance for implementing the following London Plan 2021 policies: 
•    T5, related to cycling standards 
•    D6, on housing design standards.

This includes withdrawing and replacing relevant standards in the Large-Scale Purpose-Built Shared Living LPG, and the Housing Design Standards LPG. In respect of affordable housing policy, it creates an additional time-limited emergency route. This departs from policy H5 of the London Plan; and seeks to bolster housing delivery in the current challenging economic conditions.

The SHBLPG maintains the core principles set out in the draft SHBLPG (published in 2025, for consultation). Notably, it restates that the approach to housebuilding should serve as an incentive route to accelerate housing delivery in a time-limited way; and should be supported by a review mechanism where necessary. However, this decision form proposes several changes to the draft SHBLPG. These seek to simplify the approach; and support its utility and impact. 

The SHBLPG contributes to the Building More Homes strategic programme. It is considered a key mechanism to help increase the delivery of homes – including affordable homes – at a time of significantly falling delivery rates. 
 

Decision

That the Mayor – having taken into account the accompanying equality impact assessments and consultation summary reports – approves adopting the Support for Housebuilding London Plan Guidance document, to respond to the current challenging housing delivery context.

Part 1: Non-confidential facts and advice

1.1.    In October 2025, the government and the Mayor announced a series of measures to support housebuilding in London. These were intended to respond to: 
•    the current challenging macro-economic context
•    a changing national regulatory landscape.
Together, these factors have contributed to a significant reduction in housebuilding in the capital. 

1.2.    As part of the measures, London Plan Guidance sets out:
•    time-limited changes to cycle-parking requirements
•    changes to housing design guidance
•    proposals for a new time-limited planning route to deliver affordable housing; this departs from policy H5 of the London Plan, which provides the threshold approach to planning applications. 

1.3.    Separately, the government is implementing a time-limited approach to relief from the Borough Community Infrastructure Levy (CIL). It is also introducing additional planning powers for the Mayor, through: 
•    amendments to the English Devolution and Community Empowerment Bill 2026
•    accompanying changes to secondary legislation. 
The aim, with these changes is, to drive housebuilding.

1.4.    The draft SHBLPG was published in 2025 for an eight-week consultation (running from 28 November 2025 to 22 January 2026). The consultation process involved engagement with Londoners and key stakeholders such as Local Planning Authorities (LPAs) and industry. 

1.5.    The SHBLPG is being issued under the powers in sections 30 and 34 of the Greater London Authority Act 1999 (the GLA Act). It does not have statutory weight, as part of the development plan. It is a material consideration that sets out how the Mayor is responding to the current emergency situation that has arisen in respect of housing delivery in London which would not have been specifically contemplated by the affordable housing policies of the 2021 London Plan.
 

2.1.    The SHBLPG proposes: 
•    changes to cycle-parking requirements 
•    changes to housing design guidance
•    a new, time-limited planning route for the delivery of affordable housing. 

These changes seek to make housebuilding more viable. The objective is to provide momentum to stalled sites, and increase housing delivery numbers, while maximising affordable housing in the current, challenging context. This new route will be available for validated planning applications until 31 March 2028, by which time the next London Plan is expected to have been adopted.

2.2.    The new route should facilitate clarity and faster decision-making, by ensuring a consistent and shared understanding of policy requirements across: 
•    local planning authorities (LPAs)
•    developers and their agents
•    the local community. 

2.3.    Adopting and implementing the SHBLPG will, therefore, contribute to the aims set out in the GLA Act – particularly in relation to achieving economic and social development in London.

2.4.    The SHBLPG proposes changes to cycle parking requirements and to housing design guidance, together with a new time-limited planning route for the delivery of affordable housing. These changes seek to make housebuilding more viable with the objective of providing momentum to stalled sites and increasing housing delivery numbers, while maximising affordable housing within the current challenging viability context. This new route will be available for validated planning applications until 31 March 2028, by which time the next London Plan is expected to have been adopted.

2.5.    It should facilitate clarity and faster decision-making by ensuring a consistent and shared understanding of policy requirements across local planning authorities, developers and their agents, and the local community. The adoption and implementation of the SHBLPG will therefore contribute to the aims set out in section 30 and 34 of the Greater London Authority Act 1999 (the GLA Act), particularly in relation to achieving economic and social development in London.
 

3.1.    The Mayor and the GLA are subject to the public sector equality duty (the Duty), as set out in section 149 of the Equality Act 2010. The London Plan, and its policies, plan for growth based on its potential to: 
•    improve the health and quality of life of all Londoners
•    reduce inequalities
•    make the city a better place to live, work and visit. 

3.2.    The London Plan uses the opportunities of a growing and changing city to plan for a better future. It also means planning decisions can focus on improving London, and transforming the city over time. It plans not just for growth, but for good growth: sustainable growth that works for everyone.

3.3.    Objective GG1 of the London Plan – building strong and inclusive communities – makes it clear that good growth is inclusive growth. This objective underpins the policies in the Plan, which will help to address inequality in a broad range of ways. The London Plan 2021 was subject to an iterative Integrated Impact Assessment (IIA) process (including an Equality Impact Assessment (EqIA)); this assessed the impact of the Plan’s policies. This work has been supplemented by an EqIA that is specific to the SHBLPG – recognising that applying the guidance in detail can add, worsen or mitigate impacts. Such effects must be considered in having due regard to the Duty. The London Plan IIA has already assessed policies attempting to increase the supply of homes (including affordable homes) in the context of acute need. It has found overall positive impacts. The aim of the SHBLPG is to provide an urgent intervention, and so reinvigorate the core objective to increase the supply of homes (including affordable housing) in response to a significant downward trend.

3.4.    The SHBLPG introduces a threshold of 20 per cent affordable housing for the time-limited planning route. This is lower than the current London Plan’s 35 per cent threshold. The London Plan threshold remains operable; but is set against the current context, where: 
•    significantly lower levels of affordable housing are being proposed by developers 
•    existing schemes are returning through the planning system, to revise affordable housing levels down to very low levels (many at 0-5 per cent). 
The intended impact of the SHBLPG is, therefore, to increase the delivery of affordable housing above the levels currently being achieved in practice. This includes helping unlock delivery of schemes that are not progressing at all, due to the impacts of a 35 per cent threshold on viability. 

3.5.    Boosting delivery is considered unlikely to result in any negative impacts on sustainability, health or community safety. Instead, it should help to maintain positive impacts demonstrated through the London Plan IIA.

3.6.    Conversely, failing to increase the current very low levels of housing delivery would result in negative impacts. These will be particularly felt by those in need of affordable housing; and those with protected characteristics under the Equality Act 2010. The SHBLPG proposals SH1 to SH4 (cycle parking; housing design standards; and affordable housing time-limited planning route) introduce a set of measures to respond to these challenges and urgently support housebuilding in the short term. In this way, the proposals are helping delivery to ‘get back on track’.

3.7.    Reduced cycle-parking provision may negatively impact some groups: 
•    those that rely on cycling
•    those that would be more affected by any potential increase in road traffic, road danger and air pollution. 

3.8.    The above groups include: 
•    children
•    people aged 16–30
•    people aged over 65
•    disabled people 
•    ethnic minority groups 
•    Londoners on low incomes. 

3.9.    Any negative impacts are expected to be limited, as the strategic aims of the London Plan (to enable cycling and cycle parking) remain. The SHBLPG cycle parking standards are also designed to generally accommodate existing demand, along with some capacity for future growth. The proposed change to the Housing Design Standards LPG for standards C4.1 (dual aspect) and B2.5 (units per core) are expected to have a neutral impact on older people; young children; and people with a disability. For all other groups with a protected characteristic, no impacts are anticipated. 

3.10.    The SHBLPG will be available in a format that is accessible to blind and visually impaired people who use screen readers. On request, it will also be made available in an appropriate format for Deaf and hearing-impaired people. People will also be able to request a paper version. Requests for the documents to be made available in other formats, and translated into other languages, will be considered on a case-by-case basis. 

3.11.    The EqIA and IIA were published for comment as part of the consultation. Both have been updated to reflect the consultation responses. The resulting changes in the proposed published version of the SHBLPG, and the Mayor, should consider the EqIA and the IIA, in deciding whether to agree the recommendations in this decision form.
 

Key risks and issues 

4.1.    The key risks and issues are outlined in the table below:

Risk

Mitigation

RAG

Measures may have a limited impact on housebuilding in London – noting other macro-economic and structural challenges impacting new supply (e.g. the conflict in the Middle East; demand-side challenges; high construction costs; ongoing building safety regulator delays); and reliance on registered providers, whose financial capacity may limit uptake.

 

The emergency measures use the levers available to the Mayor. They are supported by:

  • grant funding
  • continued engagement with registered providers
  • monitoring of market conditions
  • ongoing assessment of the impact of the emergency measures
  • the government support package, including CIL relief.

These wider macro‑economic pressures are, in any event, having an impact. Without action, housebuilding is clearly stalling.

Red

Any uplift may be only short term – incentives can only be accessed up to 31 March 2028.

 

 

Provide clear transitional guidance for effective and efficient implementation of schemes.

Look to the medium and longer term. For example, policies through the London Plan should encourage, support and secure uplift beyond the short-term.

Amber

The temporary flexibilities of the SHBLPG may diverge from the direction of travel for the next London Plan. This may, in turn, lead to schemes that do not align with future policy; and uncertainty from boroughs when determining applications.

 

The implementation and impact of these measures is being considered as the next London Plan is developed. This will set the context for future development, beyond the time-limited measures. Clear advice will be provided around decision-making, during the transition and the decision-making process.

Amber

High take-up of the emergency planning route could overstretch borough planning departments’ capacity. There may also be some concerns about the quality of applications, if applicants rush to get them validated before the cut-off point.

The Ministry of Housing, Communities and Local Government (MHCLG) is providing some funding to support borough capacity where it is most needed. GLA officers will work closely with boroughs through pre-application processes etc, to ensure that applications are well designed and meet key objectives.

Red

The measures may be applied unevenly across boroughs depending on political appetite, capacity and other factors.

 

The guidance will clarify the expectations for LPAs. The Mayor can also use his planning powers for call-in and review over housing schemes, if required (additional powers, to call in housing applications of 50 homes or more, also being implemented by government).

Amber

There is a reputational risk to the Mayor and the GLA, given opposition to these measures. Key stakeholders have voiced concerns around reduced design quality and missed opportunities to provide a higher proportion of affordable housing.

 

The ambition for, and commitment to, quality design and housing delivery is still part of the next London Plan’s development. There has always been an expectation that design factors should be applied with some flexibility – recognising the various opportunities and constraints of different sites, and the potential trade-offs between measures. The approach to the SHBLPG has sought to clarify the rationale and urgency of the context. The Mayor has set out that his next London Plan will prioritise the delivery of housing and economic growth, while maintaining a strong commitment to design quality.

Amber

There may be a legal challenge to the SHBLPG due to, for example, not undertaking further consultation on the new changes.

 

Given the urgent context, with very low levels of housing delivery, and the aim to increase momentum as soon as possible, it is important to implement support measures quickly. Nonetheless, the process followed to publish this guidance has been robust and has followed legal advice throughout. This includes ensuring that:

  • legal duties have been considered (as set out in this MD)
  • appropriate assessments, and an appropriate consultation, have been carried out.

While changes have been made to the version consulted on, there is clear rationale for these changes (as set out in this MD).

Amber

Without clear cross-referencing, and management of existing and new guidance, ambiguity and policy confusion may arise. Historically, supplementary planning guidance has not always been implemented as successfully as envisaged. This is due to the length of the documents; and a lack of focus on how their requirements should be implemented in the planning system.

The approach adopted for the SHBLPG has sought to ensure a concise, focused and cross-referenced document that aids implementation. The GLA Planning team will continue to run borough briefings, to embed understanding of the SHBLPG requirements.

 

Amber

4.2.    Care has been taken to ensure that the SHBLPG clearly explains how it is responding to the government’s policy statement outlining measures to accelerate housebuilding. The SHBLPG contains updated guidance for implementing London Plan 2021 policies T5 (related to cycling standards) and D6 (on housing design standards). It falls within the legal powers, and follows a considered process, used to produce such guidance. 

4.3.    Due consideration was given to preparing the SHBLPG as part of the emergency measures; and ensuring the timely adoption of a response to the challenging conditions impacting on housing delivery.

Links to Mayoral delivery plans and other strategies and priorities

4.4.    This SHBLPG will support the delivery of the Mayor’s Housing Strategy, and achieving the outcomes sought by the Building More Homes programme. The SHBLPG has had regard to the Mayor’s statutory strategies, to ensure consistency. Its relationship with the London Plan is explained in this MD. It creates a new route that is not envisaged in policy H5 Threshold approach to applications, in order to respond to the challenging macro-economic conditions; and to clarify how other policies should be applied flexibly to enable delivery.

Consultation and impact assessments 

4.5.    Consultation on the SHBLPG was undertaken in accordance with section 32 of the GLA Act; it ran for eight weeks (from 28 November 2025 to 22 January 2026) and included Londoners and stakeholders. Three online events, and one in-person event, were held during this time, for stakeholders to learn more about the draft LPG and ask questions. These events were as follows: 
•    developers’ session, Thursday 4 December 10-11am (in person)
•    London planning officers’ session, Tuesday 6 January 12-1pm (online)
•    session on wider engagement with Londoners, Thursday 8 January, 12-1 pm (online)
•    London borough housing and planning directors’ session, Wednesday 14 January (online).

4.6.    Consultation responses from 281 respondents were received in writing. This is detailed in the consultation summary report attached at Appendix 3. These responses contained a range of (often conflicting) views. 

4.7.    Some respondents representing LPAs supported the measures in the LPG. However, a larger proportion objected to them, because of concerns about the LPG’s impact on: 
•    the delivery of affordable housing
•    their capacity to deal with its implementation
•    other potential areas such as design quality and overheating. 

Overall, the LPAs’ main concerns relate to the proposals around BCIL which were the subject of separate MHCLG consultation. 

4.8.    Conversely, representations from the development sector were generally supportive of the SHBLPG principles and intent. However, they did not believe it went far enough to achieve the intended objectives; for these, it was said, certain changes would be needed (e.g., to timescales and the review mechanism).

4.9.    Many residents and civil society groups expressed concerns over reduced affordable housing, and the implications of changes in housing design standards and cycling.

4.10.    The table below outlines the key changes made to the SHBLPG in response to the consultation; subsequent trends in development proposals; and ongoing conversations with the government, LPAs, developers and stakeholders, including post the consultation closing.

Key area of change

Description

Rationale

Cycle Parking – minimum cycle parking standards

Added a table and a map to show the borough cycle-parking bands.

 

To improve clarity on the cycle bands, and the areas they apply to.

 

Cycle Parking – minimum cycle parking standards

Added text to explain that where LPA boundaries (such as with Mayoral Development Corporations) cross borough boundaries, the LPA should determine which band should apply.

To improve clarity, and enable local evidence to determine provision

Housing Design Standards

Added text to state that the London Plan policy covering housing design will continue to apply to decision making.

To improve clarity; and make clear that the proposed changes do not remove the existing London Plan policy D6 (housing quality and standards).

Affordable Housing Time-Limited Planning Route – eligibility

Amended the eligibility window to validation of a planning application (rather than granting of planning permission). The validation deadline is 31 March 2028, by which time the new London Plan is expected to have been adopted.

 

This amendment better reflects the fact that there may be delays outside applicants’ control, in terms of securing planning permission. The 2026 local elections, and the timescales associated with the Building Safety Regulator, pose particular challenges for a tighter timescale. Otherwise, the route would tend to be limited to existing schemes with permission. This change responds to several development-sector responses to the consultation, which highlighted the challenges of the SH4 Affordable Housing Time-Limited Planning Route timeframe for obtaining a planning permission. Boroughs also raised issues around the practicality of timescales.

Affordable Housing Time-Limited Planning Route – review

The replacement of the later-stage ‘gain share’ review mechanism, as originally proposed in the draft SHBLPG, with a single early-stage review (ESR). This follows the existing requirements in policy H5 of the London Plan (even where the scheme is a multi-phased scheme). Under the ESR, 100 per cent of any uplift would go to the local authority.

 

 

There was some support for the proposed gain-shared review; but other respondents raised concerns. Responses from the development sector overwhelmingly cited the later-stage mechanism as a major barrier to accessing the time-limited route. In discussions on live applications, the late-stage review has acted as a significant disincentive to considerations on the use of the route. Instead, applicants are opting to use the viability-tested route at much lower levels of affordable housing. The issues cited are that the SHBLPG proposals:

  • are complex
  • do not provide the certainty needed to incentivise investment
  • would undermine the bringing-forward of development in the current market.

LPAs also raised concerns about the complexities of the proposal; and the burdens it would place on their constrained capacity.

The proposed change to an ESR thereby changes the mechanism to something clearer and simpler, while remaining consistent with the principles set out in the consultation.

An ESR would bring the new planning route into much closer alignment with the existing fast-track route, as set out in Policy H5 of the London Plan (2021). The ESR should incentivise more take-up, by removing the uncertainties associated with late-stage reviews in the context of current market conditions (as highlighted by development-sector responses to the consultation).

Implementation of an ESR would be simpler, as it would use existing GLA S106 templates. These are already widely used by developers and London boroughs.

Where an ESR is triggered, and a surplus achieved, 100 per cent of the surplus would go to the LPA. Where a sufficient surplus is generated, an ESR has the benefit of providing additional on-site affordable housing. This is because ESRs occur at an early stage of development, where housing tenures can be flipped more easily. Late-stage reviews, on the other hand, typically result in a financial contribution for off-site affordable housing provision.

Affordable Housing Time-Limited Planning Route – review

Explained that an ESR would be triggered, where an agreed level of progress on implementation (the default being the first-floor slab) is not made within a certain timeframe (the default being 30 months of the permission being granted). An alternative substantial implementation definition and/or timeframe can be agreed by the LPA.

 

Developers expressed concerns that the hurdle of the first-floor slab was too difficult to achieve in the timeframes – particularly for more complex schemes. Conversely, LPAs were keen to ensure a meaningful commitment and likelihood of the developments actually happening – rather than an easier hurdle at the start, which might be used simply to secure the permission. Given that the clear aim is to incentivise actual delivery, the defaults are still proposed to be delivery of the first-floor slab; and the 30-month time period. However, some flexibility is being provided to enable an alternative trigger and timescale to reflect the particular circumstances of schemes (e.g., where there are major upfront infrastructure costs). This is subject to LPA approval, so that they can be satisfied that it meets the objectives of ensuring genuine commitment to delivery.

Affordable Housing Time-Limited Planning Route – review

Explained that a ‘long stop date’ to achieve the substantial implementation milestone, serving as a cut-off date, would still be proposed to apply. This would be set at five years from the date of planning permission.

A long stop date seeks to ensure that timescales are not made so long as to undermine momentum to delivery.

4.11.    Not all the changes were fully foreshadowed in the consultation document. However, it is not proposed that further consultation should be carried out on these changes. Instead, the recommendation is to implement the SHBLPG with the changes. This reflects several considerations:
•    The SHBLPG seeks to respond to the emergency context, as set out by government and the Mayor. A protracted process to implement the measures would reduce the impact and utility of the time-limited route. Delay erodes the utility of the proposed measures.
•    The proposed changes remain within the basic structure of a time-limited threshold route to inject momentum into delivery. The changes to the qualifying criteria, and timescales for eligibility, simply reflect the aim to make the route more practicable given the current challenges affecting delivery.  
•    The changes seek to respond to concerns raised by stakeholders on all sides, via the consultation and engagement, around complexity. The changes retain the core principle of a review mechanism: if the development fails to meet a significant milestone it is subject to a review. However, the approach to the time-limited planning route has been simplified by drawing on the established ESR methodology. This is well understood by the sector and stakeholders. It is already operating effectively to provide clarity, certainty and practical benefit. 
•    There will be continued engagement with stakeholders to develop further detail on the practical operation of the proposals in SHBLPG. This will ensure their effective implementation; and means transitional arrangements can be addressed further, as necessary, when the time-limited process approaches its end.

Conflicts of interest

4.12.    No one involved in the drafting or clearance of this form, or the preparation of the SHBLPG, has any conflict of interest that might arise because of the adoption and implementation of the SHBLPG.
 

 

 

5.1.    There are no direct financial implications for the GLA arising from this decision. 

6.1.    The LPG has been developed in accordance with the general powers in sections 30 and 34 of the GLA Act. This gives the GLA a general power to do anything that it considers will further one of its principal purposes, promoting economic development and wealth creation, social development and the improvement of the environment in Greater London.

6.2.    In exercising the section 30 power, this must be done in a way, best calculated to
•    promote improvements in the health of persons in Greater London
•    promote the reduction of health inequalities between people living in Greater London 
•    contribute towards the achievement of sustainable development in the UK
•    contribute towards the mitigation of or adaptation to climate change in the UK.

6.3.    Regard must also be had to: 
•    the related statutory duties, in relation to equality of opportunity for all people (as required by section 33 of the GLA Act) 
•    the duty to consult with such bodies or persons as the Mayor shall consider appropriate in the particular case (as required by section 32 of the GLA Act). 

6.4.    The information set out in this decision details how this LPG will further all three principal purposes, to some extent. Sections 3 and 4 of this decision set out how the Mayor’s public sector equalities duty, and the duty to consult, have been complied with. In reaching his decision, the Mayor should have regard to the EqIA and consultation summary report attached to this decision.

6.5.    Section 34 of the GLA Act contains a general power to do that which “is calculated to facilitate, or is conducive or incidental to, the exercise of any functions of the Authority”. The LPG is developed under these general powers.

6.6.    The High Court has confirmed the role of LPG in R (McCarthy and Stone) v Mayor of London [2018] EWHC 1202 (Admin). This guidance is a material consideration but is not part of the statutory development plan. 

6.7.    The development of this SHBLPG has been subject to legal advice. 
 

7.1.    This is the final stage of the development process for this piece of guidance and subject to this decision this SHBLPG will be published online with appropriate notification to stakeholders. 

7.2.    The SHBLPG will be applied as a material consideration to planning decision making.

7.3.    Timelines for the key next step activities are as follows: 

Activity

Timeline

Notification of the adoption

Week beginning 23 March 2026

Publication (including supporting documents)

Week beginning 23 March 2026

 

 

•    Appendix 1 – Support for Housebuilding London Plan Guidance
•    Appendix 2 – Consultation Summary Report
•    Appendix 3 – Equalities Impact Assessment
•    Appendix 4 – Integrated Impact Assessment 
 

Signed decision document

MD3490 Support for Housebuilding London Plan Guidance (SHBLPG)

Supporting documents

Appendix 1 – Support for Housebuilding London Plan Guidance

Appendix 2 – Consultation Summary Report

Appendix 3 – Equalities Impact Assessment

Appendix 4 – Integrated Impact Assessment

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