IN Brief:
- HBF analysed Freedom of Information responses covering more than 14,000 planning-condition discharge applications, not a complete national census.
- Some 50.8% of sampled applications were determined within the usual 56-day period across the three-year data collection.
- The median determination time reported for the partial 2025/26 data was 70 days; the normal target is eight weeks.
Home Builders Federation research undertaken with Paragon Bank Development Finance has found that 50.8% of sampled applications to discharge planning conditions were determined within the usual statutory eight-week period. The study draws on Freedom of Information responses covering more than 14,000 applications over three financial years. It concerns decisions required after planning permission has been granted, when outstanding conditions can still prevent a housebuilder from starting or progressing specified work on site.
Conditions attached to planning permission can require the submission of drainage designs, contamination assessments, access details or other information before construction reaches a defined point. Pre-commencement requirements may prevent work from starting until an authority has formally accepted the relevant details; others can affect foundation operations, construction above ground level or occupation. The existence of planning permission therefore does not automatically mean every part of an approved development can proceed without further administrative decisions.
The normal statutory period for determining a discharge application is 56 days, although the applicable period can extend to 16 weeks for certain development subject to environmental impact assessment requirements. Authorities may also agree a longer period in writing with the applicant. A decision within the target does not necessarily mean approval: conditions can remain outstanding where an application is refused or further acceptable information has to be supplied.
HBF’s three-year analysis found that the proportion of applications determined on time fell from 55.6% in 2023/24 to 51.8% in 2024/25. In the partial 2025/26 dataset, the median determination time was 70 days, compared with 105 days in 2023/24 and 95 days in 2024/25. The latest figure represents a period 14 days longer than the normal eight-week target, but the incomplete 2025/26 data cannot be compared directly with full-year results as proof of sustained improvement.
Performance varied sharply among the responding local authorities. Some determined more than 75% of the applications in the sample within the deadline, while others achieved the target in only 18% of cases. Several councils could supply aggregate counts but not a breakdown by condition category, and others could not isolate applications relating to new homes. The 50.8% result is consequently an indicative snapshot of responding authorities, not a measured national rate for every council or every planning condition.
The available data show an additional measurement problem. Planning departments must report performance against targets for determining planning applications, but there is no equivalent standard national dataset for applications to discharge conditions. Manual retrieval of records was required for the federation’s research, and differences in local recording systems affected how much detail could be obtained. Without comparable records, delays affecting pre-commencement conditions are difficult to distinguish systematically from slower decisions on later design or occupation details.
A delayed pre-commencement decision can affect the deployment of labour and equipment even where a developer has secured land, finance and a principal contractor. Contractors may have reserved excavation plant, groundworkers and specialist subcontractors for a planned start date, while foundation or drainage designs remain subject to conditions. Rescheduling one activity can force changes to the order of subsequent trades and extend the period over which the site carries financing, security and other holding costs.
Smaller developers may have fewer sites between which to move plant, people or working capital when an application is delayed. HBF and Paragon identify those constraints as a particular concern for small and medium-sized housebuilders. The study does not, however, calculate a national cost of delayed decisions or establish a precise number of homes lost. Its strongest direct evidence is the time taken to process the sampled applications and the variation between responding planning authorities.
The federation’s separate workforce research indicates that 90% of council planning departments are operating below full staffing capacity, with an estimated 2,660 additional planners needed across England and Wales. Staffing shortages may contribute to slower decisions, alongside the complexity of technical evidence and the need for consultation with specialists. The Freedom of Information exercise was not designed to attribute each late determination to a specific cause, so the workforce estimate and the measured application times remain separate findings.
HBF is seeking a national reporting framework for discharge decisions, more effective resourcing of planning departments and standardised model conditions. It also wants the effects of changes to application fees to be monitored. More consistent recording could distinguish delays in particular types of conditions and give developers a firmer basis for sequencing the work that depends on them. Standardisation would not remove the need for site-specific assessments where drainage, contamination, access or other material conditions require scrutiny.
The existing decision timetable remains in force while the Government considers wider planning and housing delivery reforms. Pre-commencement conditions must still be discharged before the affected works begin, and councils must normally determine applications within 56 days unless a valid extension or the longer EIA period applies. More consistent national reporting would allow future comparisons of determination times, but the proposed monitoring arrangements and staffing measures have not yet been implemented.
