If you’re an SME developer, there’s been plenty to keep up with.

Recent changes to planning and land policy are set to have a significant impact on SME developers across England.
With reforms to planning thresholds, Biodiversity Net Gain (BNG), planning committees and Grey Belt policy now taking effect, the development landscape continues to evolve. While these changes bring some uncertainty, they also present opportunities for SMEs to identify and bring forward sites that may previously have been challenging to develop.
Here are some of the key changes developers should be aware of:
Medium - sized development
The latest National Planning Policy Framework (NPPF) formally recognises medium-sized development as a distinct category.
The category covers 10 – 49 homes on sites of up to 2.5 hectares, following confirmation in August 2026 that the previous 1-hectare cap would be increased.
For SME developers, the introduction of a more proportionate planning category could help reduce unnecessary bureaucracy and support more efficient decision-making.
Our view: This is a positive development for SMEs, although the capacity of local planning authorities will remain an important consideration. Early engagement with LPAs will be key to understanding capacity, requirements and potential constraints.
Changes to Biodiversity Net Gain
Since becoming mandatory in 2024, BNG has presented particular challenges for smaller developments, with concerns around cost, administration and the complexity of meeting requirements.
From August 2026, developments of 0.2 hectares or less are exempt from mandatory BNG, subject to the priority-habitat exception. For minor developments that remain within scope, the biodiversity gain hierarchy has also been relaxed, providing greater flexibility between on-site and off-site delivery.
The Government is also consulting on a potential exemption for certain brownfield residential developments of up to 2.5 hectares.
Our view: The changes should help make BNG more proportionate for smaller developments, while maintaining the policy's wider environmental objectives. Clear guidance and continued support will be important as developers adapt to the revised requirements.
Planning committee reform
The new National Scheme of Delegation comes into force on 31 October 2026, with more minor and routine applications expected to be determined by planning officers rather than committees.
Minor residential developments of up to nine homes, alongside a number of other routine applications, will be subject to mandatory officer delegation. Other applications will generally be presumed to be delegated unless they are considered to have local strategic significance.
For SMEs, reducing unnecessary committee involvement could help improve the speed and predictability of planning decisions.
Our view: Greater efficiency is welcome, but it will be important to maintain meaningful local engagement and scrutiny throughout the process.
Grey Belt opportunities
Grey Belt remains an area of significant interest for developers seeking new land opportunities.
The latest NPPF continues to provide a route for certain Green Belt land to be considered for development where it does not make a strong contribution to specified Green Belt purposes and other policy requirements are met.
For SMEs, this could create opportunities to identify sites that have historically been difficult to bring forward, particularly where competition from larger housebuilders has made conventional land acquisition challenging.
However, Grey Belt designation does not guarantee planning permission. Sustainability, accessibility, environmental and heritage considerations remain important, and sites must continue to be assessed on their individual merits.
What does this mean for SME developers?
Taken together, these reforms could create a more proportionate and accessible planning environment for smaller developers.
Key areas to watch include:
- Medium-site thresholds: greater flexibility for 10–49 home schemes.
- BNG changes: reduced requirements and greater flexibility for some smaller developments.
- Planning committee reform: increased use of officer-led decision-making.
- Grey Belt: potential opportunities to explore previously constrained land.
- Finance and land initiatives: continued Government support through schemes such as the Home Building Fund, Homes England initiatives, Small Sites Aggregator pilots and the proposed National Housing Bank.
For SME developers, understanding these changes early will be important. The ability to identify emerging opportunities, assess sites against the evolving policy framework and act decisively could provide a competitive advantage in an increasingly complex land market.


