Using Housing Delivery Test data in a submission
The Housing Delivery Test measurement is a published annual figure with defined consequences. Used well it takes two paragraphs. Used badly it invites a paragraph of rebuttal.
The Housing Delivery Test data you need is one spreadsheet, published annually by the Ministry of Housing, Communities and Local Government, with one row per local planning authority in England. Find your authority's row, read the percentage, and you have the point. Everything else is working out which of the three consequences follows and saying so without overclaiming.
Consultants lose this argument by writing a page about it. The measurement is a published government figure with a defined effect. State it, cite it, and move to the policy consequence.
What the measurement publishes and when
The test compares net additional dwellings delivered in an authority's area over the previous three years against the number of homes required over those same three years. The output is a single percentage.
The requirement side uses the housing requirement in the adopted plan where the plan is recent enough, and the standard method figure where it is not. The delivery side comes from the authority's own housing flows reconciliation return, with defined treatment for communal accommodation and student housing set out in the measurement rule book.
Publication timing has moved. The collection page on gov.uk carries the current release and the previous ones, and until a new measurement is published the existing one continues to apply. Cite the file by its release name and the three year period it covers, not just by a year.
Reading the calculation for your authority
Open the spreadsheet rather than a summary of it. You want five numbers: homes required in each of the three years, homes delivered in each of the three years, the totals for each side, and the resulting percentage.
Copy them into your statement as a small table. A reviewer who can see the arithmetic will not ask for the source.
| Year | Homes required | Homes delivered |
|---|---|---|
| Year 1 | ||
| Year 2 | ||
| Year 3 | ||
| Total |
Two details catch people out. Authorities that have merged or reorganised appear differently across releases, so a comparison with an earlier measurement may not be comparing the same area. And where an authority adopted a plan partway through the three year window, the requirement figures within a single row can come from different bases.
Consequences triggered by the result
The Framework sets three thresholds, each one biting harder than the last. Below the first, the authority must publish an action plan. Below the second, a 20 per cent buffer is added to the five year housing land supply requirement. Below the third, the presumption in favour of sustainable development applies to decisions on applications for housing.
Those thresholds have sat at 95, 85 and 75 per cent since the test was introduced. Confirm them against the current edition of the Framework before you rely on them, because the policy has been reissued more than once and the transitional arrangements around each revision have differed.
The third consequence is the one worth having, and it is also the one most often overstated. The presumption does not mean permission follows. It means the balance tilts, and it is switched off where policies protecting particular areas or assets provide a clear reason for refusing the development. A Green Belt site, a Flood Zone 3b site or a site affecting a designated heritage asset does not become straightforward because the authority delivered 71 per cent of its requirement.
Interaction with five year supply
Keep them apart in the writing. The delivery test measures what was built. Five year supply measures what can be built. An authority can fail one and pass the other, and inspectors dislike statements that blur the two.
The link is the buffer. A measurement below the buffer threshold adds 20 per cent to the five year requirement, which can turn a marginal supply position into a shortfall. Where you are running both arguments, set out the delivery test result first, then apply the buffer, then present the supply calculation. That sequence is how a decision maker will check it, and it is set out more fully in reading a council's housing land supply monitoring.
Action plans and what they contain
Where an authority falls below the first threshold it has to produce an action plan within six months of the measurement, identifying the reasons for under-delivery and the steps it will take.
These are published documents and they are useful evidence. An action plan that concedes a shortage of deliverable small sites is worth quoting in a statement supporting a small site. One that attributes under-delivery to a single stalled strategic allocation tells you where the authority's own trajectory is fragile.
Read the plan before you cite the percentage. It occasionally contradicts the position the authority takes at appeal, and that is a point you can only make if you have read it.
Where the figures are disputed
Authorities sometimes say the published measurement understates delivery, usually because of the treatment of communal accommodation or because completions were recorded in a different year. The route for correcting that is the housing flows return and correspondence with the department, not an appeal.
Inspectors take the published figure as published. If an authority argues for a different number, ask what it has done to correct the return, and say in your own statement that you rely on the published measurement.
Where the argument is about which completions count, check the rule book's definitions before drafting. The treatment of student accommodation and care homes uses a ratio rather than a headcount, and that ratio is where most genuine disagreements actually sit. Cross-checking published decisions in the same authority through searching decision data across authorities will usually show how the point has been handled locally.
Presenting the point in two paragraphs
Write it like this. First paragraph: the authority's measurement, the period it covers, the source, and the consequence that follows. Second paragraph: what that consequence means for this application, and what it does not mean.
As an illustrative example of the shape rather than any real authority's figures, the wording runs close to: the most recent Housing Delivery Test measurement records delivery in this authority at 68 per cent of requirement over the three years covered. The presumption in favour of sustainable development therefore applies to this proposal for housing. The site is not subject to any policy that protects an area or asset of particular importance, and the adverse impacts identified in the officer's report do not significantly and demonstrably outweigh the benefits set out above.
That is the whole argument. Put the spreadsheet extract in an appendix, put the two paragraphs in the policy section of your Planning Statement, and spend the saved pages on the site specific case.
And resist the temptation to lead with it. A submission that opens on the delivery test reads as a scheme with nothing else to say.
Enter your postcode on PlanScope to see which supporting documents a housing application on your site is likely to need.
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 measurement published?
Annually, by the Ministry of Housing, Communities and Local Government, as a single spreadsheet covering every authority in England. Publication has slipped past its intended month more than once, so check the collection page for the latest release date rather than assuming a fixed calendar slot. Until a new measurement appears, the previous one continues to apply.
What does the measurement actually compare?
Net additional dwellings delivered over the previous three years against the number of homes required over the same three years, expressed as a percentage. The requirement figure comes from the adopted plan where it is recent enough, and otherwise from the standard method. The rule book sets out the treatment of communal accommodation and student housing.
Does a failed Housing Delivery Test mean my application will be approved?
No. Where the presumption in favour of sustainable development is engaged, permission should be granted unless policies protecting specific areas or assets provide a clear reason for refusal, or the adverse impacts significantly and demonstrably outweigh the benefits. Heritage, flood risk, Green Belt and habitats constraints all still bite, and the planning balance is still a judgement.
How does the Housing Delivery Test interact with five year land supply?
They are separate tests with one link. A measurement below the buffer threshold adds a 20 per cent buffer to the five year requirement, which makes a shortfall more likely. Beyond that, an authority can pass the delivery test and still be unable to demonstrate a five year supply, or the reverse, because one looks backwards and one looks forwards.
Can the measurement be challenged?
The figures come from the authority's own housing flows returns, so errors are raised with the department rather than argued at appeal. Inspectors generally take the published measurement as it stands. If you believe a figure is wrong, ask the authority to confirm its return and write to the department, and say in your statement what you have done.
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.