Housing Delivery Test
Three thresholds carry the practical content of the Housing Delivery Test: an action plan below 95 per cent, a 20 per cent buffer below 85, and the presumption below 75.
The Housing Delivery Test is a percentage. Take the net additional homes delivered in an authority's area over the previous three years, divide by the number of homes that were required over the same three years, and express the result as a percentage. Below 95 per cent the council has to publish an action plan. Below 85 per cent it adds a 20 per cent buffer to its five year housing land supply. Below 75 per cent the presumption in favour of sustainable development applies to its decisions.
Those three thresholds are the whole practical content of the test for anyone promoting a site. What people get wrong is treating a failed test as a general licence, and treating a passed test as the end of the argument about supply.
What the test measures
Delivery, not permissions. The numerator is net additional dwellings completed, taken from the government's own statistics, with conversions and changes of use included and student accommodation and other communal housing converted to a dwelling equivalent by a published formula. Demolitions are netted off.
The denominator is the requirement for each of the three years, and which figure is used depends on the age of the plan. Where the authority has an adopted plan that is less than five years old, the housing requirement in that plan is used. Where the plan is older than five years, or there is no plan, the local housing need figure calculated by the standard method applies instead.
That second rule produces the result that surprises members: an authority meeting its own adopted plan target comfortably can still fail the test, because the plan aged past five years and the standard method figure that replaced it is higher.
The measurement is set out in a published rule book, which also deals with the treatment of the pandemic years and with authorities whose boundaries or plan coverage changed. Read the rule book rather than reconstructing the arithmetic, because the exclusions and adjustments matter.
How the consequences escalate
| Result | Consequence |
|---|---|
| 95 per cent or above | No consequence |
| Below 95 per cent | Action plan required, published within six months of the result |
| Below 85 per cent | Action plan, plus a 20 per cent buffer on the five year housing land supply |
| Below 75 per cent | Action plan, buffer, and the presumption in favour of sustainable development applies to decisions |
The consequences sit in the National Planning Policy Framework, and the current edition published 17 August 2026 organises its policies by code rather than by paragraph number, so check the codes on gov.uk before citing them in a statement of case.
The presumption at below 75 per cent is the consequence that changes decisions. It means that permission should be granted unless the adverse impacts of doing so would significantly and demonstrably outweigh the benefits, assessed against the policies in the Framework taken as a whole. It does not switch off the development plan, and it does not apply to development affecting habitats sites or certain designated areas, so the exclusions in the Framework have to be checked against the specific site.
The 20 per cent buffer is less dramatic and often more useful. It applies to the supply calculation, which means a council that was marginally able to demonstrate five years of supply may not be able to once the buffer is added.
Timing of the annual publication
The measurement covers three financial years and is published annually by the housing ministry, usually in the winter following the end of the third year. Publication has slipped in some years.
Two consequences for anyone running an appeal.
The result that applies is the most recently published one, not the one you expect to be published next month. Arguing from an unpublished estimate does not work.
And when a new result is published mid-appeal, it becomes a material consideration that both parties will want to address. Watch the publication date if your case turns on the presumption, because a council that moves from 74 to 76 per cent has removed the plank you were standing on.
Effect on decision taking in practice
Where the presumption is engaged by the test, the practical effect depends on what else is in the way.
On an unallocated greenfield site outside a settlement boundary, with no designations, the presumption is close to decisive and inspectors have allowed appeals on that basis.
Where the site is in the Green Belt, in a National Landscape, or affected by flood risk or heritage constraints, the presumption does much less, because the Framework's own policies on those matters carry substantial weight in the balance.
Where the council's refusal rests on highways safety, amenity or design, the presumption does not help at all unless those objections are weak on their own terms. A poor scheme in a failing authority is still a poor scheme.
The plan-led system also continues to operate. Section 38(6) of the Planning and Compulsory Purchase Act 2004 still requires determination in accordance with the development plan unless material considerations indicate otherwise, and the presumption operates through that framework rather than around it. If the plan is under examination, the soundness questions matter more than the test does, as our note on soundness and the tests at a plan examination sets out.
Establishing an authority's current position
Five documents give you the position, and they should be read together:
- The most recent published Housing Delivery Test measurement, which gives the percentage and the underlying figures.
- The council's action plan, where one is required. These are often thin, and a thin action plan is itself evidence about the authority's approach.
- The Authority Monitoring Report, which gives completions by site and often reveals which allocations are stalled.
- The five year housing land supply statement, including whether the 20 per cent buffer has been applied and how.
- Any Annual Position Statement the council has submitted for confirmation of its supply position.
Cross-check the supply statement against the monitoring report. A trajectory that assumes delivery on an allocation with no permission, no developer and no access solution is the part of the supply case that is worth attacking.
Where completions on a permitted site have stalled, a council may consider a completion notice, and the mechanics of that are set out in our note on completion notices and unfinished development.
The limits of the test as an argument
Four honest limitations.
The test is backward looking. It measures what was built in three years that have already finished, and says nothing about what is in the pipeline now.
It measures delivery rather than land supply. The two are different, and an authority can fail the test while demonstrating five years of supply, or pass the test while its supply collapses. They are separate arguments and should be pleaded separately.
Delivery is only partly within a council's control. Build-out rates, developer viability decisions, infrastructure providers and utility connections all affect completions, and inspectors know it. A council with a strong record of granting permissions and a weak record of completions will get some credit for that.
And a percentage is not a policy. The test creates consequences; it does not itself decide whether a particular site should be developed. The case still has to be made on the site's merits, and that argument belongs in a properly structured Planning Statement rather than in a recital of the authority's failings.
This is general guidance, not legal advice. The measurement rules and the policy consequences change between editions of national policy, so verify the current position on gov.uk or take advice from a qualified planning professional.
Browse all 66 PlanScope report types to see what an application on a site coming forward through the presumption will need to evidence. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.
Frequently asked questions
How is the Housing Delivery Test calculated?
Net additional homes delivered in the authority's area over the previous three years, divided by the homes required over the same three years, expressed as a percentage. Conversions and changes of use count, communal housing is converted by a published formula, and demolitions are netted off. A published rule book sets out the adjustments and exclusions.
What happens if a council fails the test?
Below 95 per cent it must publish an action plan within six months of the result. Below 85 per cent it adds a 20 per cent buffer to its five year housing land supply. Below 75 per cent the presumption in favour of sustainable development applies to its decisions, subject to the exclusions in national policy.
Which housing requirement figure is used?
The requirement in the adopted local plan where that plan is less than five years old. Where the plan is older than five years, or there is no plan, the local housing need figure from the standard method is used instead. That is why an authority meeting its own adopted target can still fail once the plan ages past five years.
Does a failed test mean permission will be granted?
No. Under the presumption, permission should be granted unless the adverse impacts of doing so would demonstrably outweigh the benefits when assessed against national policy as a whole, and it does not apply to development affecting habitats sites or certain designated areas. Green Belt, landscape, flood risk and heritage policies still carry substantial weight, and a weak scheme remains a weak scheme.
Is the test the same as five year housing land supply?
No. The test measures completions over three years that have already finished. Five year supply is a forward-looking assessment of deliverable sites. An authority can fail the test while demonstrating five years of supply, or pass it while its supply is failing, so the two points should be argued separately.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.