Chyna Fairclough
Solicitor
Better late than never? Government publishes long awaited Housing Delivery Test: 2025 Measurement
After a lengthy delay, the Government has published the Housing Delivery Test (“HDT”) results for 2024 and 2025. The impact of this will be immediate in respect of plan-making and decision-making within each English local authority.
19.08.2026
Interaction with the new NPPF
The publication of the 2025 measurement is linked with Annex D of the new NPPF which outlines clear consequences of under-delivery:
- Below 95%: LPA to prepare a Housing Action Plan
- Below 85%: LPA to apply a 20% buffer to their 5-year housing land supply requirement
- Below 75%: Presumption in favour of sustainable development applies to decision-making.
How do results compare to 2023?
In 2023, 110 authorities fell below the 95% threshold. By 2025, this had increased to 147 i.e. a 33.6% increase. Whilst there has been some methodology changes which could account for some of the increase e.g. the removal of the allowance for disruption to the construction industry during the Covid-19 pandemic, it’s clear that for many authorities there is a lot more work to be done.
The geographical spread of the 93 authorities for whom the presumption in favour of sustainable development will apply is pertinent. Under-delivery is particularly prevalent in the South of England especially London which accounts for 21.5% of these authorities, despite only constituting approximately 10% of local authorities in England. This is not surprising given the difficulty of meeting ambitious housing requirements in urban areas and we may see greater emphasis on these figures to support contested developments.
How these results with shape future decisions:
These results remove much of the guesswork around housing need versus delivery, which was necessitated by the lengthy gap between publication of results. The impact of the new HDT measurement is likely to be felt where the presumption in favour of sustainable development now applies.
With immediate effect, we expect to see applicants placing greater emphasis on housing supply including during the course of live appeals. Conversely, local authorities may struggle to justify refusing schemes which would contribute meaningfully to their target, particularly in grey belt areas where a change in figures from 2023 could demonstrate an unmet need.
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