A five-year supply shortfall used to be the most powerful thing an applicant could hold. It switched on the tilted balance and, in practice, decided the appeal. The revised framework of 17 August 2026 did not abolish the supply test. It demoted it.
What a shortfall now does
Failing to demonstrate the required supply no longer triggers the old paragraph 11(d) out-of-date mechanism, because that mechanism is gone. It now counts as evidenced unmet need under S5(1)(j), which is one of the routes by which development outside a settlement can be acceptable.
That is a narrower job than it used to do. It is a way in for a scheme outside a settlement boundary. It is not a thumb on the scale across every decision in the district.
The Housing Delivery Test is where the buffers live
The delivery test thresholds carry over, and they are worth holding in your head as three separate lines rather than one.
Housing Delivery Test thresholds
Below 95% an action plan is required.
Below 85% a 20% buffer is added to the five-year supply.
Below 75% both of those apply, and the authority is also recognised as having evidenced unmet need for the purposes of S5(1)(j).
The 75% line is the one that changed character. It used to be a measure of past failure. It is now a key that unlocks a decision-making route for sites outside settlements, which makes it worth knowing exactly where an authority sits before you design around it.
Annex D moved house
The standard method now sits in Annex D of the framework itself rather than in Planning Practice Guidance, where it lived under the 2024 framework. That is administrative rather than substantive, and it matters for one practical reason: guidance is easier to change than a framework. Putting the method in the NPPF makes the number harder to move quietly.
What to do with this
Work out the authority's delivery test result before you work out its supply position, because the first now partly determines what the second is worth. Then decide which side of a settlement boundary your site sits on, because that decides whether you are in S4 or S5 at all.
Running the supply arithmetic first is the habit most of us carry over from the old framework, and this year it answers a question that matters less than it used to.
Sources
- Ministry of Housing, Communities and Local Government, National Planning Policy Framework, published 17 August 2026, including Annex D.
- Planning Geek, NPPF 2024 vs 2026, on the Housing Delivery Test thresholds and S5(1)(j).
- Local Government Association, briefing on changes to the National Planning Policy Framework, August 2026.