NPPF 2026 and Energy Statements

NPPF 2026 and Energy Statements: What Developers Need to Know

The new National Planning Policy Framework (NPPF) introduces important changes for energy efficiency, carbon reduction and climate-responsive design in England.

Published on 17 August 2026, the revised NPPF affects how local authorities develop planning policies and how they assess planning applications. It also clarifies when councils can require energy-efficiency standards that go beyond Building Regulations.

For developers, architects and planning consultants, the changes make it even more important to establish the correct energy requirements at the beginning of a project. A well-prepared Energy Statement can demonstrate compliance, support the planning case and reduce the risk of costly design changes later.

🏗️ What Is the NPPF 2026?

The National Planning Policy Framework sets out the government’s planning policies for England. Local planning authorities must consider it when preparing development plans and determining planning applications.

The government published the new version on 17 August 2026, replacing the December 2024 NPPF.

The revised framework separates its policies into two main categories:

Plan-making policies, which guide councils when preparing development plans.
National decision-making policies, which help determine planning applications.

This distinction matters. Some of the new requirements affect how councils write future policies, while others can influence planning decisions immediately.

The NPPF 2026 applies to England. Different planning policies operate in Scotland, Wales and Northern Ireland.

You can read the complete National Planning Policy Framework on GOV.UK.

🌱 What Does the NPPF 2026 Say About Energy Efficiency?

The new framework supports the transition to net zero and encourages development that reduces energy demand.

Policy CC2 states that development proposals should use design approaches that conserve energy and other resources. It also encourages developments to take advantage of decentralised heat networks and other low-carbon energy opportunities where appropriate.

Therefore, energy performance should form part of the design process rather than becoming an issue only when the project reaches Building Regulations.

An Energy Statement can explain how the proposed development will reduce energy demand through measures such as:

Building orientation and layout
Improved insulation and airtightness
High-performance windows and doors
Efficient heating and hot-water systems
Heat pumps
Solar photovoltaic panels
Connection to a heat network
Passive design and solar control
Energy-efficient lighting and controls

The level of detail will depend on the scale of the development and the requirements of the relevant planning authority.

📊 Can Councils Still Set Energy Standards Above Building Regulations?

Yes. However, the NPPF 2026 places specific conditions on how councils should introduce these standards through development plans.

Policy PM13 generally says that local planning policies should not duplicate matters already covered by Building Regulations. Nevertheless, it provides an exception for energy efficiency.

A council may propose an energy-efficiency standard that exceeds current or proposed Building Regulations when it has:

A clear and robustly costed justification
Evidence that the standard will not harm development viability
Evidence that the requirement will not prevent development from being delivered

For dwellings, the council should express the requirement as a percentage improvement over the Target Emission Rate, commonly known as the TER. It must also identify the applicable version of SAP or another approved calculation method.

This creates a clearer and more measurable basis for local energy policies.

For example, a residential planning policy may require a development to achieve a specified percentage reduction in regulated carbon emissions beyond the Building Regulations baseline. The Energy Statement and supporting SAP calculations would then demonstrate whether the proposed design achieves that target.

⚠️ Does the New NPPF Cancel Existing Local Energy Policies?

No. The publication of the NPPF 2026 does not automatically remove every existing local energy or carbon-reduction requirement.

Planning applications must generally be determined in accordance with the adopted development plan unless material considerations indicate otherwise. The new national decision-making policies also form a material consideration.

Furthermore, the NPPF explains that plan-making policies should not be used directly to determine development proposals. Policy PM13 primarily concerns how authorities prepare development-plan standards.

Therefore, developers should not assume that an existing London Plan, local plan or borough energy policy no longer applies simply because the new NPPF has been published.

Every project should still be checked against:

The adopted development plan
Relevant local energy and sustainability policies
The London Plan, where applicable
Supplementary planning guidance
Site-specific planning conditions
Emerging policies that may carry planning weight
The correct version of Building Regulations
The applicable SAP or SBEM methodology

The exact requirements can differ considerably between planning authorities.

🏙️ What Does the NPPF 2026 Mean for London Developments?

The NPPF applies in London, but it operates alongside the London Plan, borough local plans and other relevant planning guidance.

Many London developments must already demonstrate carbon reductions through the established energy hierarchy:

Be Lean – reduce energy demand through efficient design.
Be Clean – use energy efficiently and investigate heat-network opportunities.
Be Green – use renewable and low-carbon technologies.
Be Seen – monitor and report energy performance where required.

Depending on the development, an Energy Statement may need to include SAP or SBEM results, carbon-reduction calculations, overheating analysis, renewable-energy proposals and information about any remaining carbon shortfall.

The NPPF 2026 does not automatically cancel these requirements. However, it is likely to influence how future London and borough policies justify, calculate and present standards that exceed Building Regulations.

Our guide to London Plan energy requirements explains the energy hierarchy and the information developers may need to provide.

For wider guidance, visit our Energy Statements London service page.

🧮 Why the Correct SAP or SBEM Baseline Matters

The NPPF 2026 highlights the importance of using a specified calculation methodology when a planning authority sets an enhanced residential energy standard.

However, establishing the correct baseline can become complicated when:

A planning policy refers to older Building Regulations.
A planning condition requires a reduction beyond Part L 2013.
The development benefits from transitional arrangements.
The local authority has adopted a newer carbon target.
Planning and Building Regulations use different baselines.
The project specification changes after planning approval.
A scheme contains both residential and non-residential areas.

For residential developments, the assessment will usually rely on SAP calculations. Non-residential developments normally require SBEM calculations or another approved method.

The Energy Statement should clearly identify:

The planning policy being assessed
The required carbon reduction
The applicable Building Regulations baseline
The version of SAP or SBEM used
The baseline emissions
The proposed emissions
The percentage improvement achieved
Any remaining carbon shortfall

Without this information, it may be difficult for the planning authority to confirm whether the development complies.

Learn more about our nationwide Energy Statements for planning applications service.

☀️ Energy-Efficient Design Now Has Greater Planning Importance

The revised NPPF connects energy performance more closely with good design.

Policy DP3 says that building layout, orientation, massing, landscaping and materials should help conserve energy and other resources. The design should also minimise climate-related risks, including overheating.

Consequently, an Energy Statement should not focus only on the final carbon figures. It should also explain how the project team has incorporated energy performance into the design.

This may include:

Orientating buildings to manage solar gain
Optimising window sizes
Providing suitable shading
Improving the thermal envelope
Reducing thermal bridging
Using natural ventilation where appropriate
Selecting efficient heating and hot-water systems
Protecting space for heat pumps or plant
Positioning solar panels effectively
Avoiding unnecessary cooling demand

Early energy modelling allows the architect and developer to test these measures before the design becomes difficult or expensive to change.

🌡️ What Does the NPPF 2026 Say About Overheating?

The new framework gives overheating a clear role within climate adaptation and good design.

Policy CC3 states that developments should consider current and future climate impacts throughout the anticipated lifetime of the scheme. Where relevant, proposals should use design approaches that minimise overheating risk.

Overheating also appears within Policy DP3, which links it to building layout, orientation, massing, landscaping and materials.

As a result, planning authorities may expect applicants to explain how the development manages overheating through measures such as:

Suitable building orientation
Proportionate glazing areas
External shading
Solar-control glazing
Secure ventilation openings
Cross-ventilation
Appropriate thermal mass
Reduced internal heat gains
Night-time ventilation
Mechanical ventilation where necessary
Green infrastructure and tree planting

Planning requirements remain separate from Part O of the Building Regulations. A development may need to satisfy both planning policy and Part O, but the two assessments do not necessarily use the same criteria or methodology.

Developers should consider overheating before fixing the window design, façade treatment or ventilation strategy.

🏠 Greater Support for Improving Existing Buildings

The NPPF 2026 states that substantial weight should be given to the benefits of improving the energy efficiency of existing buildings through development proposals.

It also supports proposals that draw energy from:

District heat networks
Heat pumps
Solar panels
Renewable-energy systems
Other low-carbon sources

This could strengthen the planning case for carefully designed energy improvements, particularly where equipment requires planning permission.

However, applicants must still consider matters such as visual impact, noise, heritage significance, conservation-area requirements and local planning policies.

For listed buildings and other sensitive properties, the Energy Statement should balance carbon reduction with the need to protect the building’s character and fabric.

📋 What Should an NPPF 2026 Energy Statement Include?

The content should reflect the development and the policies of the relevant planning authority. Nevertheless, a robust Energy Statement may include the following sections.

Project and Policy Background

This section should describe the site, the proposed development and the relevant national and local planning policies.

Applicable Energy Targets

The report should identify the required energy or carbon target, including any percentage improvement over Building Regulations.

Calculation Methodology

The statement should confirm the version of SAP, SBEM or another approved method used for the assessment.

Baseline Energy Performance

This section should set out the performance of the Building Regulations-compliant baseline design.

Proposed Energy Strategy

The report should describe the fabric, heating, ventilation, hot-water, lighting and renewable-energy measures included in the development.

Carbon-Reduction Results

The results should show the improvement achieved at each relevant stage of the energy hierarchy.

Renewable and Low-Carbon Energy

The statement should assess suitable technologies, including heat pumps, solar PV and heat-network connections where appropriate.

Overheating and Climate Adaptation

Where relevant, the report should explain how the development will manage overheating and remain resilient to future climate conditions.

Conclusions and Compliance Summary

Finally, the statement should confirm whether the proposal meets the applicable planning target and identify any further information or design changes required.

🕐 When Should You Prepare the Energy Statement?

Developers should begin the Energy Statement during the design and planning stage.

Waiting until the planning application is ready for submission can create avoidable problems. For example, the initial calculations may show that the development needs better insulation, less glazing, additional shading, a different heating system or more solar panels.

Making these changes early is usually easier and less expensive.

Early assessment also allows the project team to coordinate:

Planning requirements
Building Regulations
SAP or SBEM calculations
Overheating assessments
Mechanical and electrical design
Architectural drawings
Renewable-energy systems
Planning conditions

The Energy Statement can then support the design instead of merely reporting on it.

✅ What Should Developers Do Now?

Following the introduction of the NPPF 2026, developers and design teams should:

Check the adopted development plan for the site.
Identify the applicable local energy and carbon policies.
Confirm whether London Plan requirements apply.
Establish the correct Building Regulations baseline.
Confirm the required version of SAP or SBEM.
Review any existing or proposed planning conditions.
Assess energy performance before finalising the design.
Consider overheating alongside carbon reduction.
Keep the Energy Statement consistent with the drawings and specification.
Update the assessment whenever the design changes.

These checks can reduce planning delays and prevent conflicts between the approved Energy Statement and the final technical design.

🐝 How Assessment Hive Can Help

Assessment Hive prepares Energy Statements for residential and non-residential developments across England.

We can review the relevant planning policies, establish the calculation baseline and assess the proposed design using SAP or SBEM as appropriate. We can also help the design team identify practical improvements when the initial specification falls short of the required target.

Our services include:

Energy Statements for planning applications
London Energy Statements
SAP calculations
SBEM calculations
Part O overheating assessments
Renewable-energy assessments
Carbon-reduction calculations
Planning-condition discharge reports

By starting the assessment early, we can help you develop a coordinated energy strategy that supports planning approval and Building Regulations compliance.

Contact Assessment Hive to discuss the energy requirements for your development.

❓ NPPF 2026 and Energy Statements FAQs

Does the NPPF 2026 apply throughout the UK?

No. The National Planning Policy Framework applies to England. Scotland, Wales and Northern Ireland have separate planning systems.

When did the new NPPF take effect?

The government published the new NPPF on 17 August 2026. Its national decision-making policies became material considerations from the date of publication. Specific transitional arrangements apply to plan-making.

Does every planning application need an Energy Statement?

No. The requirement depends on the type, size and location of the development and the policies of the relevant planning authority. Some councils require Energy Statements for major developments, while others also request them for smaller schemes.

Can a council require energy performance above Building Regulations?

Yes. Policy PM13 allows development plans to include energy-efficiency standards above current or proposed Building Regulations. However, the council must provide a clear, robustly costed justification and show that the requirement will not harm viability or deliverability.

Has the NPPF 2026 removed London’s energy requirements?

No. The new NPPF does not automatically cancel the London Plan or adopted borough policies. Each application must still be assessed against the relevant development plan and other material considerations.

What is the Target Emission Rate?

The Target Emission Rate, or TER, represents the maximum permitted rate of regulated carbon emissions for a notional dwelling under the relevant version of Part L. SAP calculations compare the proposed dwelling’s emission rate with this target.

Do commercial developments need SAP calculations?

Normally, no. SAP applies to dwellings. Commercial and other non-domestic buildings generally use SBEM or another approved calculation method.

Is an Energy Statement the same as a Building Regulations calculation?

No. SAP and SBEM calculations assess compliance with Part L. An Energy Statement addresses planning-policy requirements and may use SAP or SBEM results as supporting evidence. The planning target may exceed the minimum Building Regulations standard.

Does the NPPF replace Part O?

No. The NPPF operates through the planning system, while Part O forms part of the Building Regulations in England. A development may need to demonstrate compliance with both planning overheating policies and Part O.

Can Assessment Hive prepare an Energy Statement before the design is final?

Yes. In fact, early assessment is often preferable. It allows us to test the proposed design and identify practical improvements before the drawings and specification become fixed.