Seasonal Calendar

Housing Delivery Test publication and what it triggers

7 min readBy PlanScope Editorial Team

The Housing Delivery Test measurement triggers an action plan below 95 per cent, a 20 per cent supply buffer below 85 per cent and the presumption in favour of sustainable development below 75 per cent.

Three numbers decide what the Housing Delivery Test publication does to an authority: 95 per cent, 85 per cent and 75 per cent. Above 95 per cent nothing happens. Below it the authority must publish an action plan. Below 85 per cent a 20 per cent buffer is added to its five year housing land supply. Below 75 per cent the presumption in favour of sustainable development applies to decisions on housing applications in that area. For anyone promoting housing land, the publication date is therefore a date in the development programme rather than a statistical curiosity.

What the measurement covers

The test compares net additional homes delivered in an authority's area over the previous three years against the number of homes required over the same period. The Ministry of Housing, Communities and Local Government publishes the result as a percentage for every local planning authority in England, together with the underlying figures, and the method is set out in a published measurement rule book.

Delivery is taken from net additional dwellings data and includes student accommodation and other communal accommodation converted to a dwelling equivalent. The requirement side uses the local housing need figure or the plan requirement, depending on the age of the plan, with adjustments where a plan was adopted part way through the period. Reading the rule book once is worth the hour, because most arguments about a published result turn out to be arguments about which limb of the requirement calculation applied.

Publication has been less predictable than the policy intended. The measurement was expected each autumn, and in several years it has arrived considerably later. Check the gov.uk collection for the current measurement and its publication date rather than assuming an annual rhythm.

Consequences at each threshold

Measured delivery Consequence
Below 95 per cent The authority must publish an action plan setting out how delivery will be improved
Below 85 per cent A 20 per cent buffer is applied to the five year housing land supply calculation
Below 75 per cent The presumption in favour of sustainable development applies to decisions on applications for housing
95 per cent or above No consequence under the test

The thresholds have been stable since the test was introduced, but the surrounding policy has moved. The Framework was re-issued on 17 August 2026 with policy-coded chapters replacing the old paragraph numbering, and the buffer and supply arrangements were altered in the December 2024 edition before that. Verify the current wording and policy code on gov.uk before quoting any of it in a statement of case.

An action plan is a six-month obligation from publication, and its practical value to an applicant is as evidence. An authority that has published an action plan has, in its own words, accepted that delivery is behind. That document can be quoted.

The presumption and how it is applied

Where the presumption applies to a housing decision, the balance shifts. Permission should be granted unless the adverse impacts of doing so would significantly and demonstrably outweigh the benefits, assessed against the Framework as a whole. Practitioners usually call it the tilted balance.

Two misconceptions are worth clearing. The presumption does not make development-plan policies irrelevant; the statutory duty under section 38(6) of the Planning and Compulsory Purchase Act 2004 to determine in accordance with the plan unless material considerations indicate otherwise still applies, and the presumption operates as the material consideration that can displace out-of-date housing policies. And the tilted balance is not a licence. Specific policies protecting designated heritage assets, the Green Belt, flood risk and habitats sites continue to operate as constraints in their own terms.

The practical effect is on the quality of evidence required. In a tilted balance case, the benefits side of the equation has to be evidenced rather than asserted. Housing numbers, affordable housing by tenure, construction and occupier expenditure, biodiversity gain above the statutory minimum, and off-site infrastructure all belong in the Planning Statement with figures attached.

Timing an application around publication

If a measurement is expected and you believe the authority's figure will fall below one of the thresholds, the timing question is whether to submit before or after.

Submitting before publication means the application is determined against the current position, and an authority that improves is a risk to you. Submitting after means you can rely on the published figure from day one, and the officer's report has to engage with it. On an eight-week minor application the gap matters more than on a 13-week major, where the determination period will usually straddle any plausible publication date anyway.

There is a third option that is often better than either. Submit when the technical evidence is ready, and deal with the supply position in a short standalone note that can be updated by addendum when the measurement lands. Appeals are where this usually plays out, and the deadlines on that route are set out in our piece on appeal timetables and the six month deadline.

Illustrative example: a 45-unit scheme in a district whose previous measurement came in at 82 per cent. The applicant submits with a supply note arguing for a 20 per cent buffer and a resulting shortfall. The next measurement, published during the determination period, falls to 71 per cent. The applicant files a two-page addendum applying the presumption, and the committee report is written against it. The figures are illustrative rather than drawn from a real case.

Evidence to prepare in advance

Work backwards from the appeal you hope not to need.

  1. The authority's published supply statement, its base date, and your own site-by-site critique of deliverability.
  2. The published Housing Delivery Test result for the area and the preceding two measurements, to show trend rather than a single year.
  3. Any action plan the authority has published, and whether the actions in it have happened.
  4. A quantified benefits case, with affordable housing tenure and numbers agreed with a registered provider in principle.
  5. Technical evidence complete enough that no constraint can be put against you as an unknown, which means commissioning seasonal surveys a year ahead where they are needed.

That last point is the one that costs money if it slips. Ecology and some transport surveys have fixed windows, and a scheme that is policy-ready but survey-short gains nothing from a favourable measurement. We set out how to spread that spend in the note on phasing a survey budget across two financial years.

Where the result is contested

The measurement itself is published by the Secretary of State and is not usually open to reargument at a planning appeal. Authorities have an opportunity to query their data before publication, and the figures and the rule book are the answer to most challenges after it.

What is open to argument is everything downstream. Whether a particular site in the supply is deliverable. Whether the buffer has been applied to the right base. Whether the plan's housing policies are out of date for reasons beyond the test. An inspector will engage with those questions on the evidence, and the authority's own monitoring documents are frequently the most useful material an applicant has.

One honest uncertainty: how much weight a decision maker gives to a single poor measurement against a longer trend varies, and there is no formula. Presenting three consecutive measurements rather than one is the cheapest way to make the point stick.

Enter your postcode on PlanScope to see which reports a housing scheme in your area is likely to need, and browse the full report index while you scope the evidence base.

This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.

Frequently asked questions

When is the Housing Delivery Test published?

It was intended to appear each autumn, and in several years it has arrived considerably later. The Ministry of Housing, Communities and Local Government publishes the measurement for every authority in England alongside the underlying data. Check the gov.uk collection for the current measurement and its publication date rather than assuming an annual rhythm.

What does an action plan mean for an applicant?

It is an obligation on the authority within six months of a measurement below 95 per cent, and its value to an applicant is evidential. An authority that has published an action plan has accepted in its own words that delivery is behind, and that document can be quoted in a planning statement or a statement of case.

Does the presumption in favour override the local plan?

No. The duty under section 38(6) of the Planning and Compulsory Purchase Act 2004 to determine in accordance with the plan unless material considerations indicate otherwise still applies. The presumption operates as the material consideration that can displace out-of-date housing policies, and specific protections for heritage, Green Belt, flood risk and habitats sites continue to apply.

Can a published measurement be challenged at appeal?

Rarely. Authorities have an opportunity to query their data before publication, and the published figures and the measurement rule book answer most later challenges. What remains arguable is everything downstream: whether individual sites in the supply are deliverable, whether the buffer has been applied to the right base, and whether plan policies are out of date for other reasons.

Should I submit before or after a measurement is published?

Submit when the technical evidence is ready and deal with the supply position in a short standalone note that can be updated by addendum. On a major application the 13-week determination period will usually straddle any plausible publication date, so the timing gamble matters less than having the surveys and the benefits case complete.

Sources and further reading

housing delivery testfive year supplytilted balancepresumption in favourhousingnppf

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.

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