Planning & Policy
We’ve Read Parliament’s New NPPF Briefing So You Don’t Have To
What the draft framework’s single line on heritage actually means, and what to do about it now.
NPPF heritage policy would be rewritten from the ground up under the government’s draft framework: “less than substantial harm” becomes a mandatory categorised impact test, “great weight” becomes “substantial weight”, and reuse or retrofit of vacant listed buildings gains explicit policy support. Yet the new House of Commons Library briefing on the reforms (CBP 10964), published on 15 July 2026 ahead of a Westminster Hall debate, gives heritage a single line. We have reviewed the briefing in full, alongside the draft framework it examines, and this article sets out what it says, what it does not say, and what it means for anyone who owns, manages or is planning works to a historic building.
What the briefing is
The Commons Library is Parliament’s impartial research service, and its briefings are a reliable indicator of where a policy debate has reached. This one traces the NPPF from its introduction in 2012 through the December 2024 revision, the version currently in force, to the government’s consultation draft published on 16 December 2025, which was open for consultation until 10 March 2026.
The scale of what is proposed is not in doubt. The briefing quotes Matthew Pennycook, Minister for Housing and Planning, describing the draft as the most significant reform to national planning policy since the original NPPF was introduced. The framework has been wholly restructured, separating plan-making policies from a new set of national decision-making policies, and shifting the system from discretionary judgement towards a more rules-based approach. The current presumption in favour of sustainable development would become a permanent presumption in favour of suitably located development, making development of suitable land within settlements acceptable by default.
The briefing also captures a divided sector. Developers and housing bodies have broadly welcomed the clarity of the new format, while the Local Government Association describes the proposals as the largest shake-up of planning policy since the NPPF was introduced in 2012, and the Town and Country Planning Association warns the centralised approach limits local discretion and is likely to generate a new wave of case law.
What it says about NPPF heritage policy
Readers looking for heritage in the briefing will find a single line: the draft NPPF would take a more positive approach to the use of heritage assets, adopting a positive approach to support suitable heritage-related development.
One line. In our view, that line sits on top of the most consequential rewrite of national heritage policy since 2012, and it deserves unpacking.
Behind the one line: a full rewrite of heritage policy
The draft framework rebuilds the historic environment chapter from the ground up. The current Chapter 16 becomes Chapter 20, organised into numbered policies HE1 to HE11 and split between plan-making and decision-making. Four changes stand out.
Less than substantial harm would go
For over a decade, heritage cases have turned on whether harm is substantial or less than substantial. The draft replaces this with a mandatory impact assessment in which applicants must categorise the effect of a proposal as a positive effect, no effect, harm, or total loss, and must define the degree of any harm identified. Substantial harm survives as a distinct high threshold, now defined as a proposal that would seriously affect a key element of an asset’s significance. In practice this elevates what good Heritage Impact Assessments already do, assessing impact on significance rather than merely describing it, from best practice to policy requirement.
“Great weight” would become “substantial weight”. The government presents this as consistency of language across the framework. Historic England, in its formal consultation response, disagreed, warning the change risks a reduction in heritage protection and sits uneasily with the statutory duty to have special regard to the desirability of preserving listed buildings and their settings. Importantly, those statutory duties under the Planning (Listed Buildings and Conservation Areas) Act 1990 are unchanged, so the established case law on the considerable importance of heritage harm continues to apply. But the drafting is one to watch closely.
“Optimum viable use” would be removed. In its place, harm would be weighed against important public benefits, and for the first time the framework gives examples, including securing the long-term reuse of a vacant or underused listed building and enabling energy efficiency and low-carbon heating measures. For owners of empty or underperforming listed buildings, this is a genuinely positive signal: well-evidenced reuse and retrofit schemes would attract explicit policy support.
Non-designated heritage assets would be strengthened. The requirement for clear and convincing justification would extend to all heritage assets, councils would be expected to maintain local lists, and harm to a non-designated asset would need to be outweighed by benefits in its own balancing exercise.
What it means right now
Nothing, yet, and that matters. The December 2024 NPPF, with its existing Chapter 16, remains the framework against which live applications, appeals and listed building consents are judged. The government is still analysing consultation responses, and the final framework is expected in summer 2026, although reports suggest publication may slip past the parliamentary recess.
Our advice to clients is straightforward. Continue to prepare applications against the current framework, but future-proof new Heritage Impact Assessments now by adopting the draft’s categorisation approach and by assessing impact on significance explicitly. If your project involves the reuse or retrofit of a vacant listed building, start building the public benefits evidence base today, because the direction of travel is firmly in your favour.
The full briefing is available from the House of Commons Library at commonslibrary.parliament.uk/research-briefings/cbp-10964. If you would like to discuss what the emerging framework means for your historic building, listed building consent application or Heritage Impact Assessment, we would be delighted to help.
Download the full Commons Library briefingIn this article
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