NPPF 2026: What Has Changed for Heritage Proposals?
The National Planning Policy Framework was updated on 17 August 2026, replacing the December 2024 version. For projects affecting listed buildings, conservation areas and other heritage assets, the changes are more than a reorganisation of policy paragraphs.
The central principles remain familiar: significance must be understood, harm should be avoided or minimised, and proposals should conserve and, where possible, enhance the historic environment. But the new Framework changes the way heritage effects are described, assessed and presented in planning applications — and it does not lower the level of protection given to heritage assets.
For anyone bringing forward development in a sensitive historic context, one point is especially important: heritage is not only an issue for works to a listed building, or development within a conservation area. It can also be an issue for development near a heritage asset, where that development affects its setting and, in turn, its significance. But proximity alone is not the test — a listed building nearby does not automatically mean a proposal will cause harm.
A new heritage-policy structure
Heritage policy now sits in Chapter 20 of the NPPF, under the heading "Conserving and enhancing the historic environment." The Framework uses policies HE1–HE10 rather than the familiar sequence of numbered paragraphs (202–221) in the former chapter.
HE1–HE3 relate mainly to plan-making and Historic Environment Records. The policies most relevant to planning applications are:
HE4 – Securing the conservation of heritage assets
HE5 – Assessing the effects of proposals on heritage assets
HE6 – Proposals affecting designated heritage assets (listed buildings, conservation areas, scheduled monuments, registered parks and gardens, and World Heritage Sites)
HE7 – Decisions on non-designated heritage assets
HE8 – World Heritage Sites
HE9 – Conservation areas
HE10 – Loss, removal and archaeological interest
That structure should make it easier to identify the relevant policy route. It does, however, mean that existing heritage-statement templates, planning statements and standard report wording should be reviewed rather than simply updated with new paragraph references.
"Less than substantial harm" has gone
One of the most recognisable changes is the removal of the familiar phrase "less than substantial harm."
Under the previous Framework, heritage effects were commonly categorised as either less than substantial harm or substantial harm. In practice, "less than substantial harm" became a catch-all label covering a very broad range of effects — from a minor change to something close to serious damage.
HE5 requires a clearer classification. A proposal's effect on a heritage asset should now be identified as one of:
a positive effect — significance is enhanced or better revealed;
no effect on significance;
harm — an adverse effect on significance, short of substantial harm;
substantial harm; or
total loss.
Substantial harm is now expressly described as an effect which seriously affects a key element of an asset's significance. That places real weight on getting the significance assessment right at the outset — it is difficult to judge whether a key element of significance has been seriously affected if that element was never clearly identified in the first place.
The practical discipline required is a clear chain of reasoning:
Identify significance → explain the contribution of setting or fabric → assess the proposal's effect → classify that effect → explain how harm has been avoided, reduced or justified.
A bare conclusion of "less than substantial harm" is no longer available, and would in any case no longer be an adequate substitute for that reasoning.
Harm still carries very significant weight
The removal of "less than substantial harm" should not be read as heritage protection becoming weaker or harm becoming easier to justify.
HE6 requires substantial weight to be given to the conservation of a designated heritage asset — the previous Framework's "great weight" — and states that the more important the asset, the greater that weight should be. This applies whatever the effect: positive, harmful, substantially harmful or total loss. Where harm is identified, the Framework treats it as a matter of considerable importance and weight in the planning balance.
Where a proposal would cause harm (short of substantial harm) to a designated heritage asset, HE6 requires that harm — and the significance of the asset — to be weighed against the proposal's public benefits. Substantial harm and total loss are subject to a markedly more demanding test, generally requiring clear and convincing justification or exceptional/wholly exceptional circumstances depending on the asset.
So the change is one of clarity and structure, not of lowered ambition. A well-drafted heritage statement now has to do more explaining, not less.
Positive effects have an explicit place in the policy
The new Framework gives clearer, more direct recognition to positive heritage outcomes. HE5 defines a positive effect as one where significance is enhanced or better revealed. HE6 goes further: proposals with a positive effect on a designated heritage asset should be supported.
That may include repairing historic fabric, removing an inappropriate later addition, reinstating a feature where there is good evidence, bringing a vacant or underused historic building back into use, or improving the relationship between a building and its historic setting.
This does not mean that unrelated conservation work offsets separate harm elsewhere in a scheme. It does mean that genuine conservation benefits should be identified and argued explicitly, rather than treated as a secondary or incidental point in the planning case.
Setting is about relationship, not proximity
The revised NPPF confirms that assessing significance should include the contribution made by an asset's setting, where relevant. This matters most for development near listed buildings, conservation areas, historic landscapes and other designated heritage assets — including development outside the asset's curtilage or a conservation area boundary.
Setting is not simply the land immediately around a heritage asset, and it is not defined by a fixed distance or by whether the site appears in the same photograph as the asset. It is the surroundings in which an asset is experienced, where those surroundings contribute to its significance or allow that significance to be understood and appreciated.
Equally, being close to a listed building does not automatically mean a proposal affects its significance. The relevant question is whether the site has a meaningful visual, physical, historical or experiential relationship with the asset, and whether the proposal would change that relationship in a way that affects significance.
Historic England's established methodology remains the most useful practical approach: identify the affected heritage assets and their settings; understand the contribution setting makes to significance; assess the proposal's effect; and explore ways to maximise enhancement and avoid or minimise harm.
For example, a new dwelling on land beside a listed farmhouse may affect significance if the openness of the surrounding land helps explain the building's historic agricultural function, status or relationship with associated farm buildings. A carefully positioned proposal, using appropriate scale and landscape treatment, may reduce that effect. A heritage statement should explain this reasoning rather than rely on general assurances that a scheme is "sympathetic."
Conservation areas and World Heritage Sites: dedicated policies
Conservation areas now have their own policy, HE9, which requires decision-makers to take account of an area's special architectural or historic interest, and to retain and conserve buildings and features that make a positive contribution to its character or appearance, where possible.
HE9 is not confined to development physically within a conservation area boundary — it also applies where a proposal affects the significance of a conservation area. That could include development that interrupts an important view, changes the approach to a historic settlement, affects a valued landscape edge, alters the relationship between a historic core and its surroundings, or changes the setting of a group of buildings that contributes to the area's character.
At the same time, not every element within a conservation area is necessarily significant, and not every proposal outside its boundary will affect it. The assessment should remain proportionate and evidence-led.
World Heritage Sites have their own dedicated policy, HE8, requiring consideration of significance, Outstanding Universal Value, setting and any buffer zone.
The statutory duty under section 72(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 also remains unaffected: decision-makers must pay special attention to the desirability of preserving or enhancing the character or appearance of conservation areas. The NPPF does not, and cannot, displace this.
Non-designated heritage assets
Non-designated heritage assets — locally listed buildings, and other assets of demonstrable heritage interest that are not statutorily designated — are addressed by HE7. Where a proposal would have a positive effect, it should be supported. Where harm would arise, a balanced judgement is required, having regard to the scale of harm or loss and the significance of the asset. Substantial harm or total loss to a non-designated asset attracts a correspondingly stronger test.
This is a distinct and less demanding route than the HE6 test for designated assets, and the two should not be conflated in a heritage statement.
Sustainability and public benefits
The new Framework gives climate-change mitigation, energy efficiency and low-carbon measures a more visible and integrated policy presence generally. In the specific heritage context, HE6 expressly recognises that public benefits capable of being weighed against harm to a designated heritage asset may include securing the long-term reuse of a vacant or underused listed building and enabling energy-efficiency and low-carbon heating measures.
This is a genuine and useful change — but it strengthens the evidence-led benefits case, not a general presumption that sustainability measures should be approved. Works such as replacement double glazing, solar panels or EV charging infrastructure on or near a listed building still need to show:
what is significant about the affected fabric, elevation, roof or setting;
what alternatives were considered (repair, secondary glazing, less visible siting, reversible fixings);
why the chosen approach is necessary; and
what specific, quantified benefit is being relied upon.
A generic claim that a proposal is "more sustainable" does not, by itself, discharge that burden. The strongest cases connect a real energy, resilience or viable-use benefit to a clearly reasoned, options-tested design response.
Archaeology
Archaeology remains firmly embedded in the heritage chapter. HE5 requires an appropriate desk-based assessment — with field evaluation where necessary — for proposals involving, or with the potential to involve, a heritage asset with archaeological interest. HE10 requires preservation in situ where feasible; where that is not achievable, appropriate provision must be made for investigation, recording, understanding, dissemination and archiving.
What this means for applications
The 2026 NPPF reinforces the value of early heritage advice. The most useful point to assess heritage is before a design is fixed, when there is still scope to test options and respond to the significance of the site — reducing the risk of late redesign, validation queries or an avoidable heritage objection.
A proportionate heritage statement (or, where required under Annex C, a Heritage Impact Assessment) should answer practical questions:
Which heritage assets could be affected, including assets beyond the application boundary?
What is significant about those assets?
Does the site contribute to the significance of a listed building, conservation area or other designated asset through setting?
Which elements of the proposal could affect that significance?
Is the resulting effect positive, neutral, harmful, substantially harmful, or total loss?
How has the design avoided or reduced harm?
Where harm remains, what specific public and/or heritage benefits are relied upon, and why are they sufficient?
The answer will vary considerably between projects. A modest alteration to a listed building may need focused assessment of fabric and historic plan form. A new-build scheme near a conservation area may require a broader assessment of views, landscape, settlement pattern and the site's contribution to the area's significance. The important point is to define the real heritage issue early, and provide evidence proportionate to it — not a fixed-length report regardless of risk.
How Recept can help
Recept Heritage provides clear, proportionate advice for projects involving listed buildings, conservation areas, historic settings and other heritage assets.
We can help early in the process to identify relevant heritage constraints, understand significance, assess the contribution of setting, and shape the heritage evidence a developing proposal will need — so that heritage considerations inform the design rather than becoming a late-stage obstacle at submission.
Our work includes:
Video advice — an early, focused discussion of the heritage issues and likely next steps.
Level 1, Level 2 and Level 3 Heritage Statements, matched to the scale and sensitivity of the proposal.
Bespoke heritage advice, including setting assessment, historic building research and heritage impact analysis.
Heritage input to planning and listed building consent applications, including proportionate evidence and validation requirements.
If you are considering works to a listed building, development in or near a conservation area, or a proposal that may affect historic setting, getting the heritage position clear early can make the design process more straightforward and the planning submission more robust.
Note on sources: policy descriptions above reflect the structure and content of the August 2026 National Planning Policy Framework, Chapter 20 (HE1–HE10), cross-checked against its contents listing and introduction. Exact operative wording of HE4, HE6, HE7, HE8 and HE9 should be verified against the primary Chapter 20 text before final publication, quoting directly rather than paraphrasing where the wording is legally or commercially significant.
