By Sebastian Tibenham, Executive Director – Planning at Pegasus Group.
Summary: The new policy keeps important Green Belt protections while carving a much clearer path to development on suitable Grey Belt land and sustainable Green Belt locations, particularly around well-connected transport hubs.
The 2026 National Planning Policy Framework retains and continues the significant advancement in Green Belt policy that began with the December 2024 NPPF. While the 2026 NPPF retains much of the old, including the definition and concept of Grey Belt, it also introduces further policies that should prove useful to developers and local authorities.
Overall, the Government’s changes to Green Belt / Grey Belt policy are positive. While restrictions remain, the 2026 NPPF will most certainly increase opportunities to boost housing supply and mixed-use development in sustainable locations, and importantly, in areas with pressing demand.
Executive Summary: What are the biggest changes the NPPF makes to Green Belt / Gray Belt policies?
Below are the biggest changes developers and local authorities need to be aware of.
- The new definition of Grey Belt land no longer requires assessment of whether former footnote 7 constraints provide a strong basis for refusal (such as Designated Heritage Assets, AONBs, or veteran trees). This makes identifying Grey Belt land through the Local Plan process simpler. It has typically not been straightforward to determine if a particular constraint would constitute grounds for refusing a planning application for a development proposal at the plan-making stage.
- The PPG’s guidance on what represents strong, moderate, weak/no contribution to Green Belt purposes A, B and D is unchanged but is now set out in Annex E of the NPPF.
- Green Belt authorities must now prepare Green Belt Assessments and identify Grey Belt land as part of the evidence base for Local Plans.
- Exceptional circumstances to alter Green Belt boundaries are not required in instances where the development plan’s spatial strategy has identified suitable land for development around well-connected stations. The NPPF has extended this to stations within the top 80 Travel to Work areas by GVA (with the draft stating the top 60). However, good connections are required — i.e. at least 4 services per hour or 2 services per hour in one direction throughout the daytime. Moreover, only the respective parts of a site that are within around 800m/10-minute walk from a well-connected station fall within this definition.
- Other Green Belt release must still be supported by fully evidenced exceptional circumstances. However, the NPPF makes clearer that these circumstances can include the need to meet minimum housing requirements under the Standard Method, provided it has been demonstrated that brownfield and underutilised land has been maximised; development densities have been optimised; insufficient suitable sites exist outside the Green Belt to meet development needs.
- Neighbourhood Plans can now amend Green Belt boundaries where the need for change has been established in strategic policies but not addressed through the Local Plan.
- A subtle but helpful change is the addition of infrastructure development related to energy networks, water, telecommunication infrastructure and transport. Previously, this exception only applied to local transport infrastructure. Development proposals still need to minimise their impacts on the openness of the Green Belt and its purposes.
- The Golden Rules for major housing schemes remain largely unchanged, requiring affordable housing, infrastructure improvements and accessible green space. Significant positive weight must still be applied when considering planning applications.
- Site-specific viability assessments can now be used in a limited number of circumstances, including on previously developed land and strategic phased sites.
Full breakdown of specific Green Belt policies
The 2026 NPPF now sets eight specific policies relating to the Green Belt, including:
Plan Making Policies
- GB1 – Establishing new Green Belts
- GB2 – Assessing existing Green Belt land
- GB3 – Altering existing Green Belt boundaries
- GB4 – Defining Green Belt boundaries
- GB5 – Beneficial use of Green Belt Land
National decision-making policies
- GB6 – Control of development in the Green Belt
- GB7 – Development which is not inappropriate development in the Green Belt
- GB8 – The Golden Rules
Plan Making Policies
Policy GB1
The 2024 NPPF made it clear that new Green Belt land should only be established in exceptional circumstances and through the plan-making process. More explicit criteria are now set by Policy GB1 (previously set out in the PPG), which include the need to demonstrate all three of the following:
- Whether major changes in circumstances exist, which make establishing a new Green Belt necessary as an exceptional measure
- Why normal planning and development policies would be inadequate for addressing these circumstances
- That it would be compatible with long-term growth ambitions for the relevant area.
There are few examples where new Green Belt has been identified through the Local Plan process. One example can be found, however, in the Joint Places for Everyone Plan in Greater Manchester, where exceptional circumstances were met for several new Green Belt parcels across the city region. That said, not all parcels identified in the submitted plan met these thresholds after being tested via the examination process, suggesting that this is a high bar for Local Authorities to pass.
Policy GB2
This policy makes it clear that the preparation of spatial development strategies must now be informed by a Green Belt Assessment. This must be carried out by the Council in accordance with the approach set out in Annex E of the new NPPF.
While most Local Plans areas that contain Green Belt have typically included a Green Belt Assessment, there are examples where such evidence was deemed unnecessary by the respective Local Authority. These decisions were made on the basis that exceptional circumstances had to be demonstrated in the first instance to determine if changes to Green Belt were necessary – or likely to be required – to accommodate development needs.
Policy GB3
The published wording of Policy GB3 is arguably not quite as strong as that presented in the Draft NPPF. It confirms Green Belt boundaries should only be altered through the preparation of local plans, and where exceptional circumstances are fully evidenced and justified. However, it still includes a critical change that confirms the exception to this still applies to instances where ‘a development plan’s spatial strategy has identified suitable land around well-connected train stations.’ This is a clear step change in national policy.
The new NPPF also explicitly confirms exceptional circumstances must be demonstrated if a Local Authority cannot meet its identified development need in full (including the minimum housing need set by the Standard Methodology and any additional needs). The Local Authority must still:
- Ensure it has made as much use as possible of suitable brownfield sites and underutilised land
- Optimise the density of development
- Assess whether sufficient suitable sites can be identified outside of the Green Belt.
Policy GB4
This policy contains many of the same provisions of the former NPPF in relation to establishing and altering Green Belt boundaries and identifying safeguarded land through a Local Plan.
Priority should be given to releasing Green Belt land in the following order, subject to an area’s spatial strategy and the need to promote sustainable development patterns:
- Previously developed land within the Green Belt;
- Grey Belt that is not previously developed;
- Other Green Belt locations, so long as this promotes a sustainable pattern of development overall
For those sites released for housing development, the LPA needs to ensure that they are able to meet the ‘Golden Rules’.
A key policy change is the fact that Neighbourhood Plans can now alter Green Belt boundaries where the need for change has been established but not made within the Local Plan.
Policy GB5
This policy requires development plans (at the most appropriate level) to establish how Green Belt land can deliver benefits for communities and nature. For example, benefits can include improved public access to green spaces, outdoor sport, allotments and community food production, and nature recovery. The published policy no longer includes the requirement for Local Plans to detail how they will offset the impacts of any Green Belt land removal through compensatory improvements to quality and accessibility of remaining Green Belt land, which was set out in the 2025 Draft NPPF.
Decision Making Policies
Policy GB6
This policy reaffirms that inappropriate development in the Green Belt is harmful by definition and should not be approved, except in very special circumstances. The harm to the openness of the Green Belt and any other harms must be clearly outweighed by other considerations. Passing this bar still requires one to overcome the substantial weight afforded to the harm to the Green Belt.
The policy confirms that all forms of development that are not encompassed by Policy GB7 are inappropriate in the Green Belt. However, it is within Policy GB7 where more exceptions exist.
Policy GB6 still confirms that very special circumstances will need to be demonstrated for renewable and low-carbon energy schemes.
Policy GB7
This policy retains previously established exceptions for development in the Green Belt, including agriculture, infill, re-use of buildings and redevelopment of previously developed land. It also allows development on Grey Belt land where:
- There is an identified need – e.g. failure of the housing delivery test or 5-year land supply test
- The site is in a sustainable location
- The wider Green Belt is not undermined
- Housing proposals can meet the Golden Rules
A subtle but helpful change for infrastructure providers is the allowance of certain forms of transport, electricity network, telecommunications and water infrastructure required in a Green Belt location. The 2024 NPPF only referred to local transport infrastructure previously. While such exceptions are still limited to proposals that minimise impact on Green Belt ‘openness’ and which do not conflict with Green Belt purposes, this change is still helpful and should simplify the application process for delivering such infrastructure.
Another key exception to development in the Green Belt, added by the 2026 NPPF, includes housing and mixed-use developments located near ‘well-connected’ railway stations that provide high levels of connectivity to services and employment. A well-connected station is defined on the NPPF Glossary as a rail/underground/tram/light rail stop that is:
- Within a reasonable walking distance to the development area, which is now defined in the NPPF Glossary as 800m/10 minutes (subject to considerations of the route i.e. topography/barriers, etc). Notably, only the parts a respective site that fall within this definition can be included when applying Policy GB7.
- Running at least 4 services (or 2 in one direction) per hour during weekday daytimes. Alternatively, they must have a reasonable prospect of being subject to such a level of service via planned upgrades or through agreement with the rail/tram provider.
- Located within a top 80 Travel to Work Area (TTWAs) partially or fully in England. These are large geographical areas defined by utilising Census commuting data. The 2025 Draft NPPF indicated this would be the top 60 TTWA’s, and therefore, it is clear that the Government have expanded this to include a number of additional locations that were previously omitted including:
| Blackpool | Telford | Burton Upon Trent | Chesterfield |
| Cheltenham | Poole | Kettering and Wellingborough | Barnsley |
| Doncaster | Chichester and Bognor Regis | Grimsby | Eastbourne |
| Birkenhead | Worthing | Harrogate | Huntingdon |
| Colchester | Newbury | Halifax | Yeovil |
Policy GB8
The Golden Rules for major housing schemes in the Green Belt continue to apply, and where they are met, ‘substantial weight’ is to be provided to them when considering whether to grant planning permission, including:
- 50% affordable housing for those sites released from the Green Belt within a Local Plan, or 15% above the local adopted affordable housing policy in the meantime (up to a cap of 50%)
- The need for necessary improvements to local or national infrastructure
- The provision of new green spaces, or improvements to existing green spaces, which exist within a short walk of homes, and which meet local green space standards within a development plan. Such green spaces should contribute to the landscape setting of the development; include nature recovery and contribute to Local Nature Recovery Strategies where these are set; and meet local green space standards (or national ones set by Natural England where these are not explicit).
The key change/clarification provided by the 2026 NPPF relates to the consideration of viability in the context of the Golden Rules. There are now three scenarios where a site-specific viability assessment can be considered:
- On previously developed land and demonstrably burdened by costs associated with that previous development, which were not accounted for in the development plan’s viability assessment
- For strategic sites. This is now defined in the NPPF Glossary as sites for residential, commercial, or a mix of uses delivered over multiple phases that include significant infrastructure delivery and a masterplan, with residential-led sites typically accommodating 1,500+ dwellings (scale can vary, depending on mix of uses on site).
- For a development model, which is wholly different from that considered in the viability assessment supporting a development plan. However, the maximum possible contribution to affordable housing and infrastructure should still be sought. Proposals that deliver contributions significantly below the affordable housing requirements noted above will only be approved in exceptional cases, where fully evidenced and justified.
Definition of Grey Belt Land
The definition of Grey Belt land has been altered.
It remains the case that it must either be previously developed land and/or a parcel of land that does not make a strong contribution to 3 of the 5 defined purposes of Green Belt relating to:
- Purpose A – restricting urban sprawl
- Purpose B – merger of towns
- Purpose D – protecting the setting of historic towns
The key change in the 2026 NPPF is that the consideration of footnote 7 policies is no longer a matter to determine if a site can be deemed to be Grey Belt. This does not mean to suggest that such policy restrictions would not impact on the ability for a site to be allocated or successfully promoted through a planning application. However, the definition of Grey Belt land is now fixed to whether it is either previously developed land, or land that does not strongly contribute to Green Belt purposes A, B, and D.
Assessing a Site’s Contribution to the Purposes A, B, and D
The criteria applied to determine whether a Green Belt site makes a strong, moderate, or weak/no contribution to Purposes A, B and D is now contained in Annex E of the 2026 NPPF. The criteria remain unchanged from that previously set out in the PPG, and as before, the purposes do not relate to villages.
Annex E also now provides the guidance previously contained within the PPG relating to how Green Belt Assessments should:
- Identify the location and appropriate scale of areas to be assessed
- Identify areas of Grey Belt land, and;
- Whether the release of those parcels would fundamentally undermine the five Green Belt purposes (taken together) of the remaining Green Belt when considered across the area of the plan.
In short, Green Belt Assessments prepared to inform Local Plans should specifically identify and map those areas of the Green Belt that represent Grey Belt land.
Conclusion
The 2026 NPPF is not a wholesale overhaul of Green Belt policy, but it continues and strengthens the shift introduced in 2024. It retains important Green Belt safeguards while creating a clearer route to development on suitable Grey Belt land and in sustainable Green Belt locations, particularly around well-connected stations.
For developers, promoters and local authorities, the key opportunity lies in identifying sites that align with these new policy priorities. As local plans are reviewed and updated, the practical impact of these reforms is likely to be a significant increase in the amount of Green Belt and Grey Belt land considered for development.
If you would like to discuss how these changes affect your schemes, please get in touch with Sebastian Tibenham, Executive Planning Director at Pegasus Group.
