Statement on planning reform and why Section 106 requirements are vital for delivering affordable housing

17 February 2026

Kate Henderson, Chief Executive of the National Housing Federation has made a statement on planning reform and why section 106 requirements are vital for delivering affordable housing. In her statement she said:

"The government is currently consulting on the revised National Planning Policy Framework (NPPF) and we are concerned about proposed changes to the site thresholds for section 106 agreements.

The NPPF proposal to remove the requirement for developers to directly deliver affordable housing on medium sites (defined as 10-49 homes on sites of up to 2.5 hectares) could have far-reaching consequences for our ambition to deliver truly affordable social homes across the country.

National Housing Federation member data shows that in the last three years, 12% of S106 acquisitions were on medium sites. For small and medium housing associations, the impact is even greater: 26% of their S106 acquisitions came from these sites. Almost 10,000 affordable homes delivered nationally over the past three years wouldn’t exist if developers hadn’t been required to build them.

These homes are a lifeline for local delivery and for keeping smaller providers active and viable in their communities, especially in rural areas.

Replacing on-site delivery with cash contributions rarely results in new affordable homes. This approach depends on local authorities having the capacity, land, funding, and expertise to bring forward alternative schemes – conditions that too often don’t exist. In some cases, councils have even had to return unspent funds to developers, despite housing associations being ready to deliver.

Cash-in-lieu must remain the exception, not the rule. When used, funds should be channelled directly to housing associations to ensure every pound delivers real, timely and locally targeted affordable homes.

We can’t afford to lose a pipeline that provides thousands of affordable homes every year – and the communities that depend on them."