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National Planning Policy Framework · 17 August 2026 Decision-taking · housing

Which route,
which test

Where a housing proposal sits decides which policy routes it, and the route decides who has to prove what. Three routes lead to a default yes. One leads to a reversed burden. The chain below is drawn from the Framework’s own words, clause by clause.

Source NPPF, published 17 August 2026 — policies S3–S6, HO1, HO7, GB6–GB8 Every clause checked against the Framework as published

What is true on every route

Before the branching, one policy applies whichever way the tree resolves. It is the reason affordable housing changed status in this edition.

The constant · HO7(1) with HO1(2)(a)

“substantial weight should be given to the benefits of providing homes which will contribute towards meeting the evidenced accommodation needs of the community, as identified through needs assessments prepared for the area of the local planning authority and other relevant evidence. This includes, but is not limited to, homes needed for different groups assessed under policy HO1.”

Two consequences, both in the wording. First, the test is the evidence of need, not the figure a Local Plan chose as its response to that need — a plan may answer an 800-a-year evidence base with a 300-a-year target, and it is the 800 that HO7 engages. Second, “other relevant evidence” is not confined to the headline figure in a needs assessment: Housing Registers, homelessness duties, temporary accommodation, affordability ratios and tenure-specific shortfalls all bear on it.

HO1(2)(a) supplies the link, identifying “those who require affordable housing (including Social Rent)” as one of the groups whose needs HO7 weights.

The chain

three tests, resolved in order

Each test must be answered before the next arises. The order is set by S3 and by S5(5), not by choice.

1
Location — the designation gate

IF the site is in the Green Belt or on land designated Local Green Space

S5(5) “This policy does not apply to development proposals in the Green Belt or on land designated as Local Green Space, which should instead be determined in accordance with policies HC8, GB6, GB7 and/or GB8 (as appropriate).” The settlement question at test 2 never arises.

TRUERoute C — Green Belt Determined under GB6, GB7 and GB8. S5 is disapplied in terms.
FALSEGo to test 2 The proposal is routed by S3 on the settlement boundary.
2
Settlement — the S3 routing

IF the site is within a settlement

S3(1) directs proposals within settlements to S4, and proposals outside settlements to S5. This is the routing clause: S3 does not itself decide anything, it says which principle applies. Annex B matters here — settlements do not include hamlets and scattered groups of houses outside predominantly built-up areas unless the development plan defines them as settlements, nor villages defined as part of the Green Belt.

TRUERoute A — S3(1)(a) to S4 The default is approval.
PARTLYBoth, then an overall view S3(2) — where a proposal falls partly within and partly outside, S4 and S5 are applied to the relevant parts before coming to an overall view.
FALSEGo to test 3 S3(1)(b) sends the proposal to S5, which is a closed list.
3
Outside settlements — the S5(1)(j) gate

IF the proposal addresses an evidenced unmet need AND (is physically well-related to an existing settlement and of a scale the infrastructure can take OR is major freight and logistics under E3)

S5(1)(j) gives two examples of unmet need — no five-year supply of deliverable sites, or a Housing Delivery Test result below 75% — but prefixes them “including, but not limited to”. They are illustrations, not a definition. An evidenced affordable housing shortfall can satisfy the trigger on its own terms. The limb is conjunctive: the trigger alone does not open the route, because (j)(i) or (j)(ii) must also be met.

TRUERoute B — outside settlements The shortfall is not a benefit weighed inside the presumption. It is the reason the presumption is engaged at all.
FALSES5(4) — the reversed burden Not a neutral balance. Approval only in exceptional circumstances, where the benefits substantially outweigh the adverse effects.

Where the three routes land

Same constant, three different chains. The policy chips are the route in the Framework’s own numbering.

A

Within settlements

S3(1)(a)→ S4(1)→ HO7+HO1(2)(a)
  • S4(1) — development within settlements should be approved unless the benefits would be substantially outweighed by adverse effects assessed against the national decision-making policies.
  • S4(2) lists where that is likely: substantial adverse impact on allocation or safeguarding, on HC7, HC8, N6, N4 or L2(1)(d); loss of burial ground or water storage land; or failing an NDMP that requires refusal. The list is expressly “not restricted to” those.
  • HO7 then directs substantial weight to meeting the evidenced need, inside a balance that already starts from approval.
The resulting test

Approve unless the benefits are substantially outweighed.

B

Outside settlements

S3(1)(b)→ S5(1)(j)→ HO7+HO1(2)(a)
  • The unmet-need trigger is open. An authority can demonstrate five years and pass the Housing Delivery Test comfortably while carrying a persistent shortfall against its assessed affordable housing need — and the words “including, but not limited to” admit that shortfall.
  • Affordable housing therefore does two things at once: an evidenced shortfall can engage S5(1)(j), and HO7 then requires substantial weight for the homes proposed to meet it.
  • Fail the limb and you do not merely lose the presumption — see S5(4) in the table below.
The resulting test

Approve unless the benefits are substantially outweighed.

C

Green Belt

GB6→ GB7(1)(g)→ GB8(2)+HO7
  • GB7(1)(g) requires all four limbs: grey belt land not fundamentally undermining Green Belt purposes; an evidenced unmet need; a sustainable location under TR3; and, for major housing, compliance with GB8.
  • Footnote 41 closes the list. For housing, the evidenced unmet need at (g)(ii) means the lack of a five-year supply including any buffer, or an HDT result below 75%. The open S5(1)(j) formulation does not carry across.
  • Clear GB7 and S5(5) returns the balance: approve unless substantially outweighed. Fail it and GB6(2) applies — very special circumstances, with substantial weight given to the Green Belt harm.
  • GB8(2) gives substantial weight separately to complying with the Golden Rules, including affordable housing at 15 percentage points above the highest existing requirement, capped at 50%, or 50% by default where no requirement exists.
The resulting test

Not inappropriate: approve unless substantially outweighed. Inappropriate: very special circumstances.

The burden of proof, side by side

This is the payload of the whole diagram. Four destinations, and the only material difference between them is which way the presumption points and who carries it.

Policy Where it applies The direction, as drafted Starting point
S4(1) Within settlements Approve unless the benefits would be substantially outweighed by any adverse effects. Approval
S5(1) Outside settlements, within a listed category Approve unless the benefits would be substantially outweighed by any adverse effects. Approval
S5(5) Green Belt, where GB7 is satisfied Approve unless the benefits would be substantially outweighed, applying S5(2). Approval
S5(4) Outside settlements, no listed category Approve only in exceptional circumstances, where the benefits would substantially outweigh the adverse effects. Refusal
GB6(2) Green Belt, inappropriate development Very special circumstances, which will not exist unless the harm is clearly outweighed; substantial weight to the Green Belt harm. Refusal

Three things to be careful about

S5(1)(j) is conjunctive

A diagram that draws S3(1)(b) → S5(1)(j) → HO7 as a straight arrow understates the test. The evidenced unmet need is the first half; (j)(i) or (j)(ii) must also be satisfied — physically well-related to an existing settlement and of a scale the infrastructure can accommodate, or major freight and logistics under E3.

Miss it and the fallback is not a neutral balance but S5(4).

GB8(2), not GB7(1)(g)(iv)

The direction to give substantial weight to complying with the Golden Rules sits at GB8(2). GB7(1)(g)(iv) does something narrower: it makes compliance with GB8 a condition of the development not being inappropriate, for major housing.

The distinction matters on an appeal: one is a gateway, the other is a weighting.

The trigger depends on a suppressible number

Overall housing need has been recalibrated through successive versions of the standard method. The methodology for assessing the needs of specific groups, affordable housing among them, has moved far less.

Assumptions on affordability, Housing Register eligibility, the private rented sector and households’ ability to meet their own needs can materially suppress the assessed figure — and a suppressed figure keeps the trigger from engaging at all.

Where your land sits on this tree is a question of fact

Which route applies turns on the settlement boundary, the designations over the land and the authority’s own published evidence — and those differ by district and change over time. We appraise that for landowners across Leicestershire, Northamptonshire, Rutland and Lincolnshire, from published sources, before anyone spends money on design.

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