The Housing Delivery Test and its consequences

The Housing Delivery Test measures how many homes an authority actually delivered over the previous three years against how many were required, and publishes the result as a percentage. Fall below the thresholds and consequences follow automatically: an action plan, then a buffer on the five year land supply, then the presumption in favour of sustainable development applying to decisions. For anyone arguing a housing appeal, the published percentage is the single most useful number about the authority you are dealing with.

It is a delivery measure, not a permissions measure. An authority can grant everything put in front of it and still fail, because what counts is completions on the ground.

What the measurement counts

The measurement divides total net homes delivered over a three year period by the total number of homes required over the same period. Net additional dwellings come from the authority's own returns, and student accommodation and other communal accommodation are converted to a dwelling equivalent under the published rule book.

The requirement side is where most of the argument sits. Broadly, the requirement is drawn from the adopted plan where the plan is recent enough, and from local housing need calculated by the standard method where it is not. That distinction matters because a plan adopted years ago with a low requirement produces a flattering percentage, while an authority measured against standard method need in a high value area can fail on the same delivery record.

Read the rule book rather than relying on a summary of it. It has carried adjustments in particular years, including for the pandemic period, and those adjustments change the arithmetic materially.

The consequences at each threshold

These thresholds have run through successive editions of the National Planning Policy Framework, and the Framework was re-issued on 17 August 2026 with policy-coded chapters in place of the old paragraph numbers. Cite the policy code from the current edition rather than a paragraph number copied from an older document, and check the wording on gov.uk before you rely on it in a statement of case. The buffer arrangements in particular were revisited in the December 2024 edition.

The consequences stack. An authority below 75 per cent is also below 85 and below 95, so it carries the action plan duty, the buffer and the presumption together.

Action plans and what they are worth

An authority measuring below 95 per cent must publish an action plan within a set period of the measurement, analysing the causes of under-delivery and identifying what it will do.

In practice their quality varies enormously, and they are worth reading for a different reason than the one intended. An action plan usually contains the authority's own account of why sites are not coming forward: infrastructure constraints, a stalled strategic allocation, a viability problem in a particular part of the district, a shortage of development management staff. That account is the authority's published evidence, and it can be quoted back in a statement of case where you are arguing that the trajectory relied on in the plan is optimistic.

How the presumption applies

Where the presumption is engaged for decision-taking, the Framework directs that permission should be granted unless the application of policies in the Framework that protect areas or assets of particular importance provides a clear reason for refusing, or unless the adverse impacts of granting would demonstrably and materially outweigh the benefits when assessed against the Framework as a whole.

That is the tilted balance, and it changes the shape of the argument rather than deciding it. Green Belt, habitats sites, designated heritage assets and areas at risk of flooding remain capable of providing a clear reason for refusal. An appeal argued as though a failed Housing Delivery Test result guarantees permission tends to lose.

What it does do is shift the weight given to the benefit of delivering housing, and it removes the comfort an authority might otherwise take from an out of date development plan policy.

Using the result in an application

Three practical uses, in order of how often they work.

1. In the planning statement, state the authority's most recent measurement, the consequence that follows, and what that means for the policy balance. One paragraph, with the source named.
2. In pre-application discussions, use it to ask why the authority is resisting a site that would deliver completions within the measurement window. Consented but unstarted sites do not help an authority's percentage.
3. At appeal, pair the measurement with the five year land supply position. They are separate tests measuring different things, and an authority can pass one while failing the other.

The distinction between them catches people out. The land supply test looks forward at deliverable sites. The delivery test looks backward at completions. Winning on one does not decide the other, though both feed the same policy conclusion about whether the authority is meeting its housing requirement.

Where the result is disputed

The measurement is published by government, and appeal inspectors treat the published figure as the starting point. Disputes therefore tend to be about interpretation rather than about the number itself.

The arguments that arise are about whether particular completions were correctly counted, how communal accommodation was converted, and what happens in the window between the end of the measurement period and the date of the decision. An authority whose delivery has improved sharply since the measurement will say so, and that submission carries some weight even though the published percentage stands.

Anticipate it. Where you are relying on a poor result, check the authority's latest monitoring report for completions since the measurement period and deal with the point rather than leaving it to be made against you.

An illustrative example: a district publishes a measurement of 71 per cent. The presumption applies, and a scheme for 60 homes on an unallocated edge of settlement site goes to appeal. The authority argues landscape harm and prematurity. The appeal turns on whether landscape harm is a clear reason for refusal under the Framework's protective policies, and the delivery failure sets the weight given to the housing benefit in the balance that follows. The percentage did not win the appeal. It framed it.

Keeping track of the changes

Measurements are published annually, usually with a gap between the end of the measurement period and publication, so there is always a period where the previous year's figure is the operative one. Diary the publication and re-check any authority you are actively working in.

Reform continues around plan-making and national development management policies under the Levelling-up and Regeneration Act 2023, and the delivery test sits inside a system that keeps moving. The planning law updates timeline is a place to follow those changes, and the practical effect of earlier reform on obligations is covered in the pooling restriction removal and what it changed.

This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it.

PlanScope drafts a Planning Statement that cites national policy and adopted local plan policies, with missing facts flagged rather than invented. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.