The updated National Planning Policy Framework (NPPF) has now been published, following consultation on the December 2025 draft: National Planning Policy Framework 2026.

The government’s target of building 1.5 million homes during the current parliamentary term continues to put planning reform firmly in the spotlight. The latest NPPF reforms sit at the heart of Labour’s wider reshaping of the planning system: it is a clearer, more directive framework designed to support housing delivery, infrastructure investment and economic growth.

Published on 17 August 2026, the revised NPPF represents the most significant overhaul of national planning policy since the framework was introduced in 2012.

That is largely because the framework is now split between plan-making and decision-making policies, with coded sections covering topics such as housing, Green Belt, settlement growth and infrastructure.

Key changes and headlines at a glance

Strategic planning and economic growth

Strategic planning returns through Spatial Development Strategies (SDSs), introduced by the Planning and Infrastructure Act 2025. The new NPPF builds on that statutory framework by adding detail on the content of SDSs and confirming that they must establish a positive, sub-regional framework for investment and growth over a minimum 25-year period.

Local plans are expected to support a broader mix of housing delivery, including allocating at least 10% of housing requirements on sites of one hectare or less and a further 10% on sites between one and 2.5 hectares, strengthening opportunities for SME builders.

Significant weight is given to strategic employment development and sectors aligned with the Government’s Industrial Strategy, including advanced manufacturing, logistics, energy infrastructure, laboratories, data centres and AI Growth Zones.

Housing delivery

The headline here is that homes in existing urban areas close to transport hubs, delivered at high density, are supported. That is largely thanks to new support for residential and mixed-use development within reasonable walking distance of well-connected railway stations, creating a clearer route to development in sustainable, transport-connected locations.

The revised Standard Method remains the basis for assessing housing need and local authorities are expected to plan positively to meet identified need.

The paragraph 11 presumption and tilted balance have been replaced by new national decision-making policies s4 (development within settlements) and s5 (development outside settlements). Now, development within settlements should be approved unless adverse effects substantially outweigh the benefits. Development outside settlements may also benefit from policy support in specified circumstances, including where authorities cannot demonstrate a five-year housing land supply or have Housing Delivery Test results below 75%.

Accessibility and inclusivity expectations have been strengthened, with plans expected to seek at least 40% of homes on major developments to meet M4(2) accessible and adaptable standards, subject to local evidence and viability considerations. Alongside that, the new policy TR4 states that the arrangement of streets and other routes should help create places that are safe, inclusive and attractive for all users.

Following a campaign by members of parliament to introduce consideration of safety for women and girls in the NPPF, the new policy DP3 on public space states that well-designed places should include spaces that are “safe, secure, inclusive, and accessible for all ages and abilities including for groups such as women and girls”.

Green Belt and Grey Belt

The Government has retained its Grey Belt reforms. The definition has been simplified to land that “does not strongly contribute to any of purposes (a), (b), or (d)” — removing the previous reference to footnote 7 and the restrictions it imposed.

The Golden Rules and affordable housing additionality requirements remain, and those are aided by guidance at a new Annex E in relation to Green Belt assessments and grey belt identification. Whilst grey belt land is still actively promoted for development, these changes do not overcome the need for detailed analysis of whether land classifies as such, and the five core purposes of the green belt remain.

Biodiversity and environment

For local authorities requiring developers to go above and beyond on Biodiversity Net Gain delivery whether requiring 20% gains in local plans, or 80-year maintenance requirements in planning obligations, they must now justify those demands with robust evidence.

Protections for National Parks, National Landscapes and other designated landscapes have been strengthened compared with the consultation draft, reinforcing the need to conserve and enhance these areas.

Climate adaptation is embedded more explicitly throughout the framework, with increased focus on flood risk, drought, overheating, wildfire risk, coastal change, green infrastructure and nature-based solutions.

Tree protections remain prominent, but the final position is less expansive than some expected. The December 2025 draft had proposed widening the definition of veteran trees, which some suggested could have captured significantly more trees and materially affected site layouts through associated root protection zones. That change has not been carried through: the final definition remains focused on trees of exceptional biodiversity, cultural or heritage value. Ancient woodland and ancient and veteran trees remain strongly protected, but without the wider scope feared by some. The framework also places greater emphasis on retaining and integrating established trees, hedgerows and natural features into scheme design.

Infrastructure, resilience and growth sectors

National policy strengthens support for renewable energy generation, electricity networks, water supply, wastewater infrastructure and reservoir development, reflecting the Government’s focus on development to support economic growth and resilience.

One of the more unexpected additions is the clearer support for new reservoir development, with water infrastructure now treated as a central growth and resilience issue rather than a more peripheral utilities concern. This is likely to be significant for strategic sites and local plans in areas where housing or employment growth is constrained by water supply or network capacity.

Greater weight is afforded to infrastructure and development that supports economic growth, productivity and strategic national priorities.

What does the new policy mean for developers, and how can they react?

For developers, the direction of travel is clear. The revised NPPF strengthens commitment to housing delivery and economic growth, gives greater support to sustainable and well-connected development, and opens up fresh opportunities for land within settlements, near transport hubs and in locations capable of meeting housing or economic need.

Developers should focus their proposals to support sustainable growth, housing delivery, infrastructure provision and environmental enhancement, whilst ensuring that the impacts of their schemes are adequately mitigated. If sites have previously been constrained by policy or local plan uncertainty, now is the time to revisit your prospects of securing a permission (particularly if they are close to train stations) and seek advice on whether those have now improved.

To discuss how the recent NPPF changes affect you or to discuss the contents of this article further, please visit our webpage and contact a member of our Planning team: Planning Law.

The Government has very recently confirmed one of the most significant reforms to Local Government and the planning system in decades. From 1 April 2028, the remaining two-tier council areas in England will be reorganised, reducing 134 local, borough and county councils to just 38 new unitary authorities across 14 county areas.

For developers, landowners and local planning authorities alike, the changes represent a major shift in plan making and decision taking.

What is changing?

Under the reforms, the existing two-tier model of county councils and district/borough councils will be replaced by single-tier unitary authorities responsible for all Local Government functions within their area. This will consolidate multiple planning teams, finance departments and leadership structures into a single authority, with the aim of making services more streamlined and accessible for residents and freeing up funding to reinvest directly into local priorities such as road maintenance and social care.

The Government has made clear that many of the proposed authority boundaries have been designed around economic geography, housing markets and growth opportunities, rather than simply replicating existing council areas. When the changes were announced the now replaced Secretary of State, Steve Reed, said that “these reforms create stronger, more efficient councils that lay the foundations for real devolution and the economic growth that will bring new jobs and opportunities to communities right across England”.

Perhaps most significantly from a planning perspective, each new unitary authority will ultimately prepare a single local plan covering its entire administrative area. This means that over time, planning policy will move away from today’s smaller district-based plans towards broader strategic policies covering much larger geographies. As a result, future housing and employment allocations may not follow historic district boundaries or existing local plan priorities. There will however be a transitional period during which current local plans will continue to operate.

Areas most affected

The changes cover 14 county areas across England. Areas of particular interest include:

Gloucestershire

The county’s seven councils will be replaced by a single unitary authority. The Government has stated that this approach will bring together the Gloucester-Cheltenham growth corridor and the Golden Valley cyber cluster under one authority, potentially creating a more unified approach to growth, infrastructure and economic development.

Devon, Plymouth and Torbay

The existing eleven councils will be reorganised into four unitary authorities. According to Government statements, the proposed structure is intended to better align Local Government boundaries with the area’s economic geography and support housing and infrastructure delivery.

London

London will remain largely unaffected by this national transition because the capital’s 32 boroughs have operated as unitary (single-tier) authorities for 40 years, having been broken into the 32 boroughs in 1965 and those boroughs having taken on these full powers in 1986, following the abolition of the Greater London Council. Therefore, they are already responsible for most Local Government functions within their areas.

Cambridgeshire and Peterborough

Alongside West Sussex, plans for how to reorganise Cambridgeshire and Peterborough have been delayed until October 2026, with the Government saying it needs time to make the right decisions.

The return of strategic planning

These Local Government reforms do not sit in isolation. Alongside the creation of new unitary authorities, the Government is also progressing proposals for Spatial Development Strategies (SDSs), a high-level, long-term planning blueprint that guides land use, housing distribution, and infrastructure across a wide geographic region rather than a single local council.

This signals a return to a more strategic, regional approach to planning.

Neighbouring authorities will be able to collaborate through strategic planning boards to prepare SDSs across wider housing and economic market areas. Together, the new unitary authorities and SDS framework could fundamentally reshape how housing targets, infrastructure priorities and strategic growth locations are identified and delivered.

Key takeaway

For local planning authorities, the challenge will lie in managing the transition from existing district-based policy frameworks to new authority-wide plans, while simultaneously engaging with emerging Spatial Development Strategies and an evolving national planning framework.

Whilst many of the practical details remain to be worked through, one thing is already clear: the planning landscape that developers and local authorities are operating within today could look very different by 2028 and beyond. Those promoting land, preparing planning applications or developing long-term growth strategies should keep a close eye on how these reforms evolve and what they may mean for local plan coverage, housing delivery expectations and future development opportunities.

To discuss the potentially far-reaching implications for housing growth, site promotion and strategic development these changes may have on you or your land, or to discuss the contents of this article further, please visit our webpage and contact a member of our Planning team: Planning Law – Michelmores.

From young Arthur becoming the legendary king, Frodo venturing beyond the Shire to save Middle-earth and Shrek leaving the swamp to rescue Princess Fiona and embrace who they truly are, some of our favourite stories follow a similar pattern.

The narrative structure is known as the Hero’s Journey, where an ordinary person embarks on an adventure, overcomes challenges and returns transformed by the journey. While often associated with myths, sci-fi and fantasy, many real-life challenges follow a similar path, including a legal career.

Looking back at my own path into law, I noticed how it follows similar stages:

1. Call to adventure (deciding to do law)

You decide that you want a career in law. You may be attracted to helping people, challenging yourself, or the continuous learning. Becoming a solicitor can feel like standing at the bottom of a mountain with no clear route to the top.

I often see questions online like, “can I become a solicitor with X grades?“, “is it too late?” or “am I good enough?“. These questions crossed my mind too, but I soon learned that self-doubt creates obstacles before you’ve even begun. In reality, your background and timing matters far less than your commitment to the journey.

2. Meeting the mentor (support network)

Often, the best people you can speak to are the ones who have already walked the path that you want to follow. The people who encouraged me helped me realise that there was no reason why I couldn’t succeed too.

• If you work at a law firm, open up to your colleagues about your journey. Senior members of your team can help you gain experience to bolster your CV, while trainees and NQs can offer practical advice on applications;
• If you don’t work at a law firm, attend open days, careers fairs and networking events. Speaking to current trainees can give you a first-hand account of what the profession is actually like and help you to identify which firms are right for you.

3. Trials and challenges (applications)

Applying for training contracts was a humbling experience! It’s rare for somebody to get it right first time. The only way to improve your applications is with reflection and practice.

My top tips are:

• Tailor every application to the firm you are applying for. You can get a strong feel for the firm by looking at their website, looking at partner profiles to see who their clients are and what work they are doing if they are in an area that interests you, and reading Legal Cheek and Chambers Student;
• Prepare for psychometric tests using free online resources. Check YouTube for videos offering explanations about the different types of tests and to see people taking practice tests.

4. Approaching the cave (assessment centres)

As an introvert, I found group exercises particularly daunting, so I spent the most time preparing for them. There’s an old cliché suggesting that you can volunteer to keep time or take notes, but these are some better ways to show the skills that assessors are looking for:

Listening skills: Praise and build on other people’s ideas;

• Team-working: Refer to people by their names and encourage quieter members to contribute;
• Leadership: Help the group stay focused and encourage them to feel confident in reaching a decision;
• Commercial awareness: You will often be asked to make a business decision, so read the news beforehand to contribute a real-life analysis.

5. The reward (training contract offer)

You finally receive the telephone call with your training contract offer. This moment is long-awaited so you haven’t thought about what comes next!

• If you’re relocating, think about your lifestyle outside of work and where you would like to live. I commute to the Bristol office from Gloucestershire as I enjoy martial arts and there are some great places for training near me
• Our Early Careers and Knowledge teams will provide ample resources to prepare you for your first seat. However, it can be helpful to look at your university notes to refresh your memory of some of the key legal principles
• Connect with current trainees on LinkedIn, introduce yourself and ask them about the seats they have completed. Current trainees are often excited to meet members of the next cohort and share their experiences; this can also provide valuable insight into the culture and day-to-day work of the firm you’ll be joining
• If, like me, you completed the LPC and need to study the SQE2, take a short break before recapping your LPC notes using the SQE syllabus. SQE2 exams are closed book and cover a high volume of content; giving yourself a head start before the course begins means that you can focus on the skills part of the assessment without being completely lost on the knowledge. Check out Alex Peltiez’s blog for more tips on how to ace your SQE2

You don’t need a magical sword, a ring of power or a talking donkey to begin your journey. To be the hero in your own story, all you need is determination to take the first step and the resilience to keep going when the journey gets tough. You shall pass.

As AI and digital infrastructure accelerate, power is a decisive factor in which data centre projects get built. That creates a significant opportunity for energy developers who can combine generation, storage, land strategy and long-term power supply into bankable co-located projects.

Why are data centres on the radar for energy developers?

For energy developers, the UK data centre market is fast becoming a core growth area.

The reason?  The next phase of digital infrastructure will be constrained less by demand for services, and more by access to reliable, deliverable power.

Demand for digital infrastructure is accelerating, particularly with the rise of AI and high-performance computing. At the same time, access to grid capacity is increasingly difficult, connection dates are moving up the board agenda, and developers are looking for credible routes to secure power before committing capital, tenants or land.

This is changing how data centre development is being delivered.

Rather than simply competing for limited grid capacity, developers are increasingly looking at co-located models where data centres are paired with generation, storage and private wire arrangements. For energy developers, this is a natural adjacency: it builds on existing expertise in land assembly, grid strategy, project structuring, revenue certainty and long-term asset optimisation.

The result is a move from standalone renewable energy projects towards power-led digital infrastructure platforms.

What does co-location mean?

For energy developers, co-location has traditionally meant pairing a generating asset with an adjacent source of demand. In the data centre context, this could include solar PV or wind generation located alongside a data centre, BESS to manage intermittency and resilience, private wire arrangements supplying electricity directly behind the meter, or a hybrid model combining on-site generation with grid import and export.

The core objective is to unlock development potential, improve deliverability and enhance value through a more predictable energy supply strategy.

Why are energy developers interested?

1. Offtake certainty

Data centres offer continuous, high-volume baseload demand and long-term operational need. In many cases, counterparties will also have strong covenant strength, particularly where the customer is a hyperscale, cloud or enterprise operator.

That creates the potential for long-term power supply arrangements which reduce merchant price exposure and support more predictable income streams. For investors and funders, that revenue visibility can be highly attractive.

2. Grid constraints are creating new models

Grid access is now a major barrier to deploying both generation and demand assets in the UK. Co-located models can reduce reliance on already congested grid connections, support more flexible import and export strategies, and better align generation and demand timelines. For data centres, private wire structures, BESS and flexible generation can form part of a credible power strategy where traditional grid-led delivery is delayed or uncertain.

3. A route into wider infrastructure platforms

Energy developers have an opportunity to move beyond single-asset energy projects and into integrated energy and infrastructure platforms, working alongside data centre developers, operators and investors. Projects are likely to attract strongest interest where the energy supply strategy is credible, deliverable and aligned with the demand profile of the data centre.

What are the key legal issues?

The opportunity is significant, but co-located schemes bring a different risk profile from a standard clean energy project. The legal structure needs to support not only construction and operation of the energy assets, but also the uptime, resilience and investment requirements of the data centre.

1. Land and site structuring

Instead of planning for a single asset, developers need a multi-use site strategy. Key questions include whether generation and data centre operations should sit within the same vehicle or separate vehicles, whether land rights should be separated or linked to the relevant asset, and how cable routes, substations, access rights and shared infrastructure should be owned, operated and protected.

2. Power arrangements

Power supply will be central to the project structure. The parties will need to address private wire ownership and operation, PPAs between generator and data centre operator, back-up supply, resilience obligations, curtailment risk and the interaction with grid import and export arrangements. The data centre operator will be focused on continuity of supply; the energy developer will need to ensure that those obligations are technically deliverable and commercially bankable.

3. Planning strategy

Co-located developments may offer planning advantages, but they also require a coordinated strategy. Developers will need to decide whether to pursue an integrated or phased planning approach, how generation, storage and data centre uses are treated within planning policy, and how environmental and community considerations are managed across the whole site.

As data centres are increasingly recognised as critical infrastructure, there may be greater scope to position well-structured co-located schemes as strategically important developments.

4. Financing structure

From a financing perspective, co-location introduces additional layers of analysis. Funders will look closely at asset interdependence, revenue certainty, counterparty covenant strength, credit risk, security arrangements and step-in rights. The structure will also need to make clear whether the assets are being financed as an integrated platform or as separate operational assets with linked contractual rights.

5. Operational alignment

Co-located projects require long-term operational alignment. Taking into consideration customer requirements for near-continuous uptime, the documents need to deal with outages, planned maintenance, downtime, performance failures, matching generation output to demand, and the consequences if one part of the project affects the other. These issues are not simply operational details; they go directly to project value and bankability.

What does this mean for energy developers and investors?

The growth of co-located data centres reflects a broader shift in the market. Power is now a critical constraint on digital infrastructure, which means energy developers can play an increasingly important role in unlocking new capacity. Those with experience of complex project delivery, grid risk, long-term revenue arrangements, storage, private wire structures and investor requirements are well placed to move into this space.

The key will be early structuring. The most successful projects are likely to be those where land, power, planning, offtake, financing and operational risk are considered together from the outset. For energy developers, co-located data centres are not just another route to market for power. They may become one of the most important infrastructure opportunities created by the growth of AI and digital demand.

A key element of the Planning and Infrastructure Act 2025 was to unlock developments otherwise constrained by their potential impact on designated environments. To this end the Act introduced ‘Environmental Delivery Plans’. EDPs set out the conservation measures that will be taken to address the impact of specified types of development on protected habitats and species. The EDPs are to be managed primarily by Natural England. The EDPs will be paid for by developers.

The legislative provisions for financing the EDPs are the Nature Restoration Levy Regulations 2026 (“the Regulations”).

The first draft of the Regulations has recently been published.

How the Levy Operates

Applicability

Natural England can make participation in the EDP mandatory or discretionary. If discretionary then developers will be able to opt into the regime where an EDP provides the mitigation type their development needs to proceed. Natural England will make this clear for each EDP.

Calculation of the Levy

The levy rates (i.e. how much a developer will have to pay towards a specific set of nature restoration efforts) will be calculated individually for each EDP.  For discretionary EDPs this cost, relative to the cost of the developer’s ability to provide their own mitigation will be a key workability aspect of the scheme.

It is up to Natural England to create a charging schedule for each EDP, setting out the index linked Levy rates (which can be changed) whilst paying attention to:

1. The administrative cost of delivering and managing the EDP measures; and
2. the conservation measures and environmental requirements of the EDP area.

Process and payment

Procedurally, the regime borrows heavily from the structure and administrative logic of Community Infrastructure Levy (which has been running for 15 years or so):

1. The developer, defined as ‘liable person’ starts the process by contacting Natural England to request to pay the levy, and if accepted, the developer will receive a ‘commitment to pay’
2. Local Planning Authorities will impose a pre-commencement condition on the planning permission requiring payment of the Levy
3. Once their permission is granted (or if appropriate, prior approval is given), the developer must serve an assumption of liability notice on Natural England. A liability notice calculated according to the permission is served on the developer, detailing payment dates. Natural England confirms receipt of payment to the LPA

The finer details provide for:

1. Transfer of liability (provided notice is given to Natural England) and joint and several responsibility if there is more than one ‘liable person’
2. Payments in instalments (helpful for phased developments) and a duty to return overpayments
3. Enforcement powers ranging from the imposition of surcharges and late payment interest, to warning and stop notices on the development if payments are not made
4. Appeals provisions relate to the enforcement powers, as well as the Levy charge calculated. Unlike CIL, there are no exemptions or reliefs available. There is also no mention of Natural England taking into account the effect the Levy will have on individual schemes’ viability

We expect detailed guidance from the Secretary of State in due course.

What can developers do to prepare?

While the Levy is intended to provide simplified form of environmental mitigation. By opting into the Levy developers effectively cede control over mitigation delivery to Natural England’s strategic programmes rather than finding tailored solutions at project level often delivered over the life of the development.

Unless funding the EDP is mandatory, then unlike CIL developers will have an option to pay the Levy. Developers will not just be considering the Levy cost and cashflow (with instalment payments being a possible option), but also both ease of delivery and ongoing maintenance liabilities of onsite scheme, as well as securing a clean site exit. Clarity on a developer’s best option may not be secured until the permission is granted.

For some sites onsite delivery of mitigation may be physically impossible. For these sites, subject to the cost, choosing to pay the Levy may be the only option to secure planning permission and build-out their development.

Despite what we know so far, the release of further government guidance on the Levy, the EDPs and charging schedules in due course will be vital for developers considering opting into the Levy, meaning anticipatory preparation for it at present is difficult to achieve. Staying ahead of EDPs and Levy will be another important task on developers desks, and we will continue to help with further bulletins and knowledge sharing.

Michelmores has advised Cranford Sports Club on a lease agreement with LED Community Leisure, a not-for-profit Community Benefit Society. This secures the long-term future of the Club and supports the continued provision of sports and wellbeing facilities in the local community.

Cranford Sports Club, a community amateur sports club, had faced financial challenges in recent years, with membership levels declining amid increased local competition. In response, the Club took the strategic decision to grant a lease of its premises to LED Community Leisure, an experienced operator of community leisure facilities.

Under the new arrangement, LED Community Leisure will operate the site, enhancing its facilities and broadening the range of activities available to members. Early indications following completion of the lease are encouraging, with an increase in membership renewals already observed.

The Michelmores team advising on the deal was led by Partner, Richard Walford and Associate, Zilah Nelson, from the Firm’s Transactional Real Estate team.

Richard Walford commented:

“We are pleased to have supported Cranford Sports Club in completing this important agreement. The partnership with LED Community Leisure provides a strong foundation for the Club’s long-term sustainability and continued role as a valued community asset.”

Jill Anderson, one of the volunteer directors, reflecting on the Club’s position and future outlook, added:

“This has been a really important step forward for the Club. Like many community organisations, we have had to adapt to changing circumstances, and securing this agreement ensures that the Club can continue to play a central role in the local community. We are already seeing renewed interest from members and look forward to working with LED Community Leisure to build on this momentum and develop the facilities and activities we can offer.”

The transaction highlights the role of specialist real estate advice in supporting community organisations to adapt and thrive in changing circumstances. Read more about the work that we do here.

In our earlier article, “ICO guidance explained: the new data protection complaints regime from June 2026”, we outlined the new obligation introduced under section 103 of the Data (Use and Access) Act 2025 for all organisations to operate a data protection complaints process from 19 June 2026 where there has been any infringement of UK data protection law. Such processes are designed to address, for example, complaints about how personal data has been collected or used by an organisation, the way in which a Subject Access Request has been responded to or concerns following a data breach incident.

With that deadline fast approaching, organisations should now be carrying out final checks that their processes work in practice, and not just on paper.

Complaints can be made in various ways

The guidance from the data protection regulator, the Information Commissioner’s Office (ICO) makes clear that organisations must accept complaints however they are received, including through channels outside any formal complaints process.

In practice, this means complaints may be received by:

• email or online forms
• telephone or in person
• general enquiry inboxes
• post
• social media or other public platforms

Complaints picked up by customer facing teams, marketing teams or social media managers should be identified and promptly escalated to the relevant team or contact tasked with responding to data protection complaints. Organisations should also be careful to ensure that all social media accounts, email inboxes, and postal addresses are actively monitored. A good process will have clear signposting as to how data protection complaints can be raised with organisations to assist with this. Further, organisations should be careful not to respond to a complaint on social media and should instead request alternative contact information from the complainant as the ICO has highlighted that social media is not a secure form of communication.

30 days to acknowledge

The 30 day timeframe for acknowledging a complaint begins the day after it is received, regardless of the channel by which it was submitted.

The ICO advises that you do not need to acknowledge a complaint within 30 days if it is resolved before the 30-day deadline. However, it is advisable that organisations put in place automated acknowledgements in the form of a text or email to avoid the acknowledgment deadline being missed.

If complaints are made and/or acknowledged in person, clear written records should be kept, particularly where it may not be possible to follow up with an acknowledgement email or text message, in order to stay within the 30 day timeframe.

Identifying complaints early

Complaints may be raised in general or informal terms and may also be mixed with broader service complaints or data subject rights requests. Organisations should have a clear triage process to identify when a complaint engages data protection obligations and ensure it is handled accordingly.

This may mean that any complaint which mentions or references personal information, personal data, or data protection, should be escalated and assessed as to whether it is a data protection complaint and therefore needs to be dealt with under the organisation’s data protection complaints policy, acknowledged within the 30 day timeframe and responded to without undue delay (see below).

It is important that complaints are not dismissed simply because they include minor mention of data protection. If in doubt, those handling the complaints should be trained to contact the complainant and request further information to establish if the complaint can be classified as a data protection complaint.

Acting promptly, not just acknowledging

While complaints must be acknowledged within 30 days, the ICO expects organisations to investigate and respond without undue delay, starting when the complaint is received.

Organisations should have internal processes to enable:

• early triage (ideally within one working day of the complaint being received)
• diary tracking of acknowledgment deadlines
• escalation of urgent or high-risk complaints

Updating notices and communications

The ICO expects organisations to inform individuals of their right to complain, including in privacy notices and when responding to subject access requests.

Compliance requires reviewing not just complaints policies, but also privacy notices, template responses, for example, template data subject access request replies, and website content and customer communications to ensure that they all reference the right to complain.

Record-keeping

Organisations should keep records of complaints, how they are handled and their outcomes, and monitor trends or recurring issues. Complaint logs allow organisations to evidence compliance and identify potential systemic risks.

Putting the complaints process into practice

Compliance is less about introducing new systems and more about ensuring that existing processes capture and respond to complaints wherever they arise, including less obvious channels such as post and social media.

With the deadline approaching, organisations should ensure their processes are operational, documented and understood across the business, not just by legal or compliance teams. Training sessions for all employees are advisable, particularly as complaints can be made in person, and knowledge of the requirements will therefore be needed across organisations.

This article was first published in AgriLore Summer 2026. To explore the full edition and related insights, click here.

Key facts:

• The Nature Restoration Levy (NRL) is a levy payable by developers operating within the boundaries of an Environmental Delivery Plan (EDP).
• EDPs may be voluntary or mandatory. They are intended to streamline developers’ route to planning permission, thereby accelerating timescales to build-out.
• An EDP constitutes a suite of conservation measures designed by Natural England (NE) targeting environmental recovery at scale. The measures will be funded by the NRL (and therefore, by developers), with the first EDPs due to target nutrient pollution in sensitive catchment areas.
• Part 3 of the Planning and Infrastructure Act 2025 (PIA 2025) introduced the framework for EDPs and the NRL, with secondary legislation anticipated to flesh out the details later this year.

NRL and nutrient pollution

We have previously written about the legislative status quo for developers operating in sensitive catchment areas (click here) – namely the requirement for developments to be ‘nutrient neutral’ under The Conservation of Habitats and Species Regulations 2017 (Habitats Regulations 2017) (the NN Route).

Under the new regime, where development is caught by an EDP boundary, (assuming that the EDP in question is voluntary) developers will now have a choice. Either, a developer may offset their development via the traditional NN Route, or they may opt to pay the NRL to Natural England.

Should developers opt to pay the NRL, legislative obligations under the NN Route will be disapplied (Schedule 3, Part III, PIA 2025). Developers will therefore have to weigh up the cost and time benefits of each regime once the detail of the secondary legislation is known.

Section 73 PIA 2025 makes it clear that the levy must not make ‘development economically unviable.’ What this means is difficult to assess as there is no detail at this stage as to the likely amount of the NRL or the basis of charging e.g. a per dwelling cost or some other metric. It remains to be seen how pricing might impact the private nutrient credit market.

What does seem likely is that the costs of the NN Route will adjust to track the NRL charging as the presence of a marketplace competitor has the usual effect. If NE apply a standard rate for the NRL then bespoke solutions from individual landowners under the NN Route may be able to undercut the NRL approach. However, it will be for developers to determine which route to take on a case-by-case basis, and the simplicity of a direct payment may well be attractive.

Of interest to developers will be the temporal and spatial benefits afforded to them under the new regime. Rather than engage in negotiations with landowners under the NN Route, developers can simply pay the levy and move forward in the planning process. Mitigation, unlike under the NN Route, need not be in place prior to planning permission being obtained. The levy will fund conservation measures to address the negative effects of development during the ten year lifespan of an EDP.

Furthermore, while conservation measures will be proximate to development (as per the NN Route), there is scope for less proximate measures where a greater contribution to the environmental feature in question can be achieved. These are known as ‘network measures’ (section 63(3) PIA 2025).

A new statutory test: the Overall Improvement Test

The Secretary of State may make an EDP only where it considers the EDP passes the Overall Improvement Test (Section 65(3)) (OIT). To pass the OIT, the suite of conservation measures must materially outweigh the negative effect (defined as the ‘maximum amount of development to which an EDP may apply’) of development on the conservation status of each identified environmental feature. Environmental features will either be ‘protected species’, or ‘protected features of a protected site’ (such as habitat at a European Site or SSSI, for example).

Satisfaction of the OIT is not a one-stop shop. Rather, EDPs are subject to continued assessment and reporting at both the mid and end point of an EDP’s lifespan. Monitoring the effectiveness of conservation measures is therefore required (section 82(1) PIA).

The new regime also makes a nod to the additionality principle. EDPs must include an overview of ‘other measures’ being taken by NE and public authorities targeting similar environmental goals in that area. This will ensure conservation measures do not fund measures that are already being funded – i.e. avoiding ‘double counting’.

How will NE realise conservation measures?

While not set out in the legislation, it is anticipated this will be through land use agreements with landowners and other stakeholders such as environmental NGOs.

Helpfully, public authorities are under a regulatory duty to co-operate with NE under PIA 2025; this might be through the provision of information to NE, imposition of a condition of development, or assistance with the implementation of conservation measures.

What’s to come?

Further detail on the inner workings of the NRL will be set out in the Nature Restoration Levy Regulations and we anticipate further guidance from NE on key issues.

The Employment Rights Act 2025 is introducing significant changes to the collective redundancy framework. While some of the detail is still to be confirmed, the direction of travel is clear: more employers will be required to collectively consult, and the consequences of getting it wrong will be more severe.

What is the current position?

Under the existing regime, employers are required to collectively consult where they propose 20 or more redundancies at one establishment within a 90-day period.

This “single establishment” test has, in practice, allowed employers to structure redundancy exercises across different sites in a way that avoids triggering collective consultation obligations altogether.

However, the risk of non-compliance has already increased. From April 2026, the maximum protective award for failing to collectively consult has doubled from 90 days’ to 180 days’ pay per affected employee, significantly increasing financial exposure for employers.

What is changing?

The Employment Rights Act 2025 will retain the current test, but introduces a new, additional trigger. In future, employers will also need to collectively consult where redundancies reach a specified threshold across the organisation as a whole, even if no individual site meets the 20-employee threshold.

The precise threshold is yet to be set and will be determined by further regulations. However, the policy rationale is clear: to prevent large-scale redundancy programmes from falling outside the collective consultation regime simply because they are spread across multiple locations.

What does this mean for employers?

Although the new organisation-wide threshold is not expected to come into force until 2027, employers should begin factoring it into workforce planning now.

First, the scope for avoiding collective consultation by structuring redundancies across different sites is likely to reduce significantly. Employers will need to consider redundancy numbers across the whole employing entity, rather than looking at individual locations in isolation.

Secondly, this change places a greater emphasis on early-stage planning. Whether collective consultation is required is a threshold question which will shape the timeline of any redundancy exercise. That assessment will become more complex where multiple teams or sites are involved.

Finally, the increased protective award underlines the importance of getting the process right. Collective consultation is not simply an administrative step – it requires meaningful engagement with employee representatives about the proposals, including ways to avoid redundancies, reduce numbers, and mitigate their impact.

What should employers be doing now?

Our key tips are:

• Train managers: ensure those leading restructures understand the distinction between collective and individual consultation, and that collective consultation may be triggered more easily once the new organisation‑wide test comes into force
• Stress-test your process: sense-check whether your current approach would withstand scrutiny in a scenario where consultation is required across multiple sites or teams, and ensure the focus remains on genuine consultation and mitigation
• Keep records: maintain a clear audit trail of how redundancy numbers have been assessed across the organisation and how consultation has been conducted, particularly given the increased financial exposure
• Take advice early: particularly where redundancies are being considered across different parts of the business, as the new rules will make the threshold analysis more complex and fact-sensitive

The London Stock Exchange has today published AIM Notice 62 (4 June 2026), which launches an important consultation on proposed far-reaching amendments to the AIM Rules for Companies and the AIM disciplinary framework. These proposals form part of the ongoing “Shaping the Future of AIM” initiative commenced in April 2025 and progressed in November 2025  “Discussion Paper Feedback Statement” and represent a continued move towards a more flexible, proportionate regulatory regime for AIM issuers.

Key themes

The consultation reflects a clear strategic direction to:

• Reduce regulatory burden, particularly at IPO/admission stage
• Facilitate fundraisings and transactions
• Better support founder‑led and growth companies
• Attract international issuers
• Enhance the role of nominated advisers (Nomads)
• Reinforce AIM’s “buyer beware” model, with greater reliance on investor judgement

Headline proposals

Streamlining AIM admissions – The Exchange recognises that the AIM admission document has become increasingly complex and resource‑intensive and is proposing to simplify and modernise the document to reduce cost and duplication.

Codifying existing regulatory flexibility – A number of changes already being applied in practice (via guidance and derogations) will be formalised into the AIM Rules, improving certainty for issuers and advisers.

Continued deregulatory approach – The proposals reflect a broader shift towards a lighter‑touch regime, with more proportionate disclosure and increased flexibility in relation to

• capital raisings
• corporate transactions
• ongoing compliance requirements

Greater reliance on Nomads – The consultation signals a continued recalibration of the Nomad role, with an emphasis on corporate finance judgement over procedural compliance.

Updates to enforcement framework – Changes are also proposed to the AIM Disciplinary Procedures and Appeals Handbook to align with the revised rules.

Proposed material changes to the AIM Rules

Removing the requirement to provide a working capital statement – on the basis that this is a narrow absolute statement based on a short-horizon, the proposal is to substitute a requirement to clearly disclose certain details of the capital resources available and the financial obligations of the applicant, together with details of proposed future 12-month fundraising needs.

Expanding Accepted Accounting Standards – given the cost of IFRS conversion and complexity, it is proposed that AIM companies that are UK incorporated may now use UK GAAP (FRS 102) instead of IFRS.

Clarifying exceptions to Rule 7 regulatory lock-ins – in line with current policy it is proposed to allow a sell down in the first 12 months post-admission to AIM in the following circumstances:

• transfers between spouses or into a pension plan;
• intra-group transfers; or
• in the event of financial hardship.

Introduction of Trading Halts (Capital Access Windows) – Given the challenges of ensuring confidentiality when fundraising (with the creation of market volatility) it is proposed that an AIM company undertaking an equity fundraise will be entitled to voluntarily request a temporary suspension in the trading of its shares whist it manages a fundraising. The duration of such suspension is intended to be agreed a case by case basis.

Relaxing the circumstances where an acquisition triggers an RTO – it is proposed that an acquisition will not be considered a reverse takeover solely because it exceeds 100% in the class tests, where there is no fundamental change to the AIM company’s business (with guidance on this being provided in the rules), board and/or voting control. In such circumstance the transaction will be classified as a substantial transaction pursuant to AIM Rule 12 with disclosure calibrated to what investors need in order to understand the acquisition and its impact.

Avoiding a suspension of trading on the announcement of a possible RTO – It is proposed that the nominated adviser to a company can request that an AIM company is not suspended on the announcement of a reverse takeover in contemplation, where the nominated adviser is satisfied that appropriate alternative disclosure can be made to enable investors to make an informed assessment of the proposed enlarged group. This is intended to preserve market orderliness through disclosure.

Increasing the threshold for a “Substantial Transaction” – It is proposed to align AIM with the Main Market by amending AIM Rule 12 to increase the class test threshold for determining whether a transaction constitutes a substantial transaction from 10 per cent to 25 per cent

Responding to Bulletin Boards and Social Media speculation – Given the negative impact of certain conduct on these on-line forums, it is proposed that AIM companies will be given a voluntary ‘right of reply’. This will mean that an AIM company can, if it chooses, respond to any third-party commentary, speculation or criticism.

Why this matters

If implemented, the reforms are expected to:

• Reduce cost and execution timelines for AIM IPOs and fundraisings
• Enhance AIM’s attractiveness for growth and international companies
• Increase reliance on advisers and disclosure quality, rather than prescriptive rules
• Further position AIM as a flexible capital markets venue distinct from the UK Main Market

Next steps

The Exchange is currently seeking feedback from market participants, with further detailed rule changes and implementation timelines expected following the consultation process.

Please contact Ian Binnie or Dearbhla Quigley if you would like to discuss how these proposals may impact your business or any forthcoming AIM transaction.

Wastewater has increasingly become a critical constraint on development.

Although developers benefit from statutory rights to connect and water companies are under a duty to provide adequate sewerage systems, local planning authorities are now frequently delaying or refusing permissions, or imposing conditions preventing occupation, where there is uncertainty as to whether sufficient capacity will be available. These capacity pressures, regulatory scrutiny and infrastructure delivery risk mean that securing a connection is no longer a routine technical step. For many schemes, it is a determinative issue affecting planning, construction program and scheme viability.

It is a constraint that needs developers’ early attention. Developers now need to consider a range of delivery routes, each with different cost, risk and timing implications.

The starting point: can the development connect to the public network?

In most cases, the preferred outcome is a connection to the existing public sewer network, with infrastructure installed by the developer and then adopted by a sewerage undertaker.

Where capacity is available, this is typically the most straightforward and lowest-risk solution. Where it is not, developers need to consider alternative delivery routes at an early stage. It requires the completion of a section 104 agreement (under the Water Industry Act 1991) which remains the primary mechanism for securing adoption of new sewerage infrastructure.

In broad terms, the developer designs and constructs the network and the sewerage undertaker adopts it once it has been completed to the required standard.

Key points in practice:

• Infrastructure must meet approved technical standards to secure the sewerage undertaker’s technical approval
• Adoption follows inspection and a maintenance period
• Agreements are largely in standard form with limited scope for negotiation

Adoption is typically essential to satisfy funders, transfer maintenance responsibility and align with planning.

A delay in the adoption of sewers can impact on plot sales and can cause the adoption of the estate roads to be delayed, which can also impact on plot sales. So avoiding delay is advisable.

Adoption can be derailed if ‘non-developer’ parties need to be party to the section 104 agreement, such as the owners of the new plots or adjacent owners on whose land an easement is required. Good design and timing is essential to avoid these issues.

Once adopted, the sewer and any pumping or balancing infrastructure vests in the sewerage undertaker, so the future upkeep is for them, and they can charge the individual owners and occupiers for the treatment of sewerage.

Requisitions: delivering new infrastructure

Where there is no readily available sewer connection point, developers can rely on the statutory requisition regime to require the undertaker to deliver new infrastructure.

This involves:

• The undertaker designing and delivering the works
• The developer funding the infrastructure
• Formal agreements and security requirements

Requisitions can unlock sites. A sewer requisition effectively removes the need for the developer to assemble third‑party rights upfront, by shifting the burden onto the undertaker’s statutory powers. However, the sewerage undertaker’s costs have to be covered, and the delivery program will be outside the developer’s control.

Appeals and dispute resolution: managing disagreement

The Water Industry Act 1991 provides for disputes with sewerage undertakers—such as the reasonableness of conditions, costs or refusal to connect—to be referred to the regulator (principally Ofwat) for determination.

In practice, while these appeal mechanisms can provide useful leverage in negotiations, they are often time-consuming and are typically used as a last resort where commercial resolution cannot be reached.

Licensed wastewater providers (NAVs): a growing alternative

An increasingly common alternative to dealing with the traditional water companies is for developers to make arrangements with licensed wastewater operators (NAVs), such as ICOSA, IWNL and ESP.

They can offer:

• Greater commercial flexibility
• Potential program advantages
• Alternative security arrangements

However, they often involve bespoke arrangements, including asset transfers and easements, and require careful consideration of long-term operational and funding implications.

On-site solutions: package treatment plants

Where connection is not viable, developers may be able to consider on-site wastewater treatment, such as package treatment plants discharging to a watercourse.

Key considerations include:

• Environmental permitting requirements
• Private ownership and management arrangements
• Planning acceptability and long-term maintenance

These solutions can unlock sites but shift long-term risk away from the statutory regime. Arrangements will be needed to ensure these treatment plants are properly maintained.

Conclusion

Wastewater is now a front-end development issue.

Developers need to identify delivery routes early and integrate them into planning, design and viability.

Handled proactively, wastewater need not delay development. Left too late, it can become a critical barrier to delivery.

The UK remains an attractive destination for international investment and growth. Access to a deep talent pool, a stable legal system and a strong global reputation continue to make it a compelling market for international businesses.  However, the practical reality of bringing staff into the UK has shifted significantly. Recent updates to the Home Office sponsor licence guidance (May 2026), alongside a marked increase in enforcement activity, signal a fundamental change in approach.

The sponsorship framework has moved decisively from a system that facilitates international recruitment to one that is compliance-driven, actively enforced and increasingly risk-based. For business leaders, this has important implications – not just for hiring, but for operational planning, governance and risk management.

1. Accessing international talent in the UK is no longer straightforward

For most international businesses, a sponsor licence is now the essential gateway to deploying staff into the UK. Without it, the ability to recruit or relocate overseas talent is significantly constrained.

The challenge is that obtaining that licence is becoming more difficult in practice. The Home Office is placing far greater emphasis on whether an organisation is genuinely operating in the UK, whether its roles are credible and aligned with its business model, and whether it has the systems in place to meet ongoing compliance obligations.

As a result, what was once seen as a relatively procedural application, has become a more rigorous and, in some cases, more uncertain process.  For businesses entering the UK market, this introduces an additional layer of complexity. Workforce planning, timings for market entry and even corporate structuring decisions are increasingly interconnected with immigration considerations.

2. A sponsor licence is not a one-off approval – it is an ongoing regulatory burden

A common misconception is that once a sponsor licence is granted, the key hurdle has been cleared. In reality, the position is the opposite.

The sponsor licence regime imposes ongoing and active obligations on employers, including monitoring sponsored workers, maintaining detailed records, reporting changes to the Home Office and ensuring that roles remain compliant throughout the period of sponsorship.

Recent changes reinforce this approach. For example, sponsors must now ensure that workers are informed of their UK employment rights and retain evidence of this, while also demonstrating that sponsored roles remain “eligible” and aligned with the business’s operations.

In this context, a sponsor licence is no longer simply a permission to hire overseas workers. It is a continuous compliance framework, requiring sustained oversight and internal coordination between HR, operations and senior management.

3. Increased enforcement is elevating immigration compliance to a business-critical risk

Alongside these changes, the Home Office has significantly increased its enforcement activity. Sponsor licences are now subject to greater scrutiny, including data‑driven checks, unannounced audits and closer alignment with HMRC and Companies House records.

Crucially, enforcement action can now be taken on the basis of “reasonable suspicion” of non-compliance, rather than requiring proven breaches. This materially lowers the threshold for intervention.

The consequences of getting this wrong are significant. Suspension or revocation of a sponsor licence removes an organisation’s ability to recruit internationally and, in some cases, to continue employing existing sponsored workers. This can have immediate operational and commercial implications, particularly for businesses reliant on global talent.

In this environment, immigration compliance should be understood not as an administrative task, but as a core business risk with direct impact on workforce stability and growth.

4. Where international businesses are most exposed

In practice, the highest risk does not usually arise from deliberate non-compliance, but from structural gaps in how organisations approach the sponsorship regime.

For businesses entering the UK, a common issue is that immigration considerations are addressed too late. Entities are established, hiring plans are agreed and roles are advertised before the sponsor licence framework has been properly assessed.

For established UK operations, the challenge is often different. Processes evolve over time, workforce models become more complex, and compliance systems do not always keep pace. What appears to be a functioning system on the surface may not meet the level of documentary evidence and consistency now expected by the Home Office.

Recent guidance changes underscore this risk. Greater scrutiny is being applied to whether:

• organisations are genuinely operating or trading in the UK;
• roles are commercially credible and sustainable; and
• businesses are, in substance, operating as employers rather than simply facilitating immigration.

These are not technical points – they go to the core of how a business is structured and how it operates in practice.

5. Why early immigration strategy is now essential

Against this backdrop, early and strategic immigration advice has become increasingly important for international businesses.

For organisations planning to enter the UK market, immigration considerations should be integrated into initial planning. This includes aligning corporate structure, hiring strategy and timelines with the requirements of the sponsor licence regime, and ensuring that the UK entity can demonstrate both genuine activity and compliance capability from the outset.

For those already operating in the UK, there is a growing need to take a more proactive approach. This typically involves conducting an audit of existing sponsor licence arrangements, reviewing HR systems and ensuring that processes are not only compliant, but clearly documented and capable of being evidenced if challenged.

In both cases, the objective is the same: to ensure that access to international talent is not disrupted by avoidable compliance issues.

6. A changing operating environment

The UK continues to offer significant opportunities for international businesses. However, the framework for accessing talent has evolved.

The sponsor licence regime now sits at the intersection of immigration control, corporate governance and operational risk. Businesses that approach it strategically – embedding compliance within their structures and processes – will be best placed to continue accessing global talent with confidence.

Those that do not may find that what was once a routine administrative step has become a point of friction in their growth strategy.