December 2025 NPPF Draft | Flood Risk and Sequential Test

That said, consultation drafts of this nature are intended to signal policy direction, test how reforms may operate, and shape how national policy is expected to be applied in practice if adopted.

Flood risk, drainage and the Sequential Test sit at the heart of that signalling. While the draft builds on existing policy, it proposes a clearer and more rules-based framework which, if taken forward broadly as drafted, would materially affect how flood risk and drainage are addressed in both plan-making and decision-taking. These themes sit within a longer policy lineage that can be traced through the NPPF’s approach to flood risk and the post-2007 reforms following the Pitt Review.

Flood risk policy in the December 2025 NPPF draft

One of the clearest signals in the December 2025 NPPF draft consultation is structural rather than substantive. Flood risk and coastal change are separated into a standalone chapter, rather than sitting within a wider climate change section as they do in the current Framework.

If adopted, this would reinforce the established role of flood risk as a gatekeeper issue under the NPPF flood risk framework and place greater emphasis on how evidence is assembled and interrogated at application stage, including reliance on national datasets and mapping tools such as NaFRA2 and the evolving Flood Map for Planning updates.

Sequential Test: December 2025 consultation proposals

The December 2025 NPPF draft consultation does not replace the existing Sequential Test, nor does it suspend current policy. The present NPPF remains fully in force.

However, the draft proposes clearer wording on when the Sequential Test is required and how it should be applied, particularly in relation to the appropriate search area and the evidential burden on applicants. This sits alongside recent refinements to national guidance, including the September 2025 PPG update on the Sequential Test.

These proposals are not yet policy, but they signal a move towards more transparent and defensible Sequential Test submissions, consistent with how the test has always been intended to function within the NPPF flood risk hierarchy.

If adopted, this would place greater emphasis on properly scoped Sequential and Exception Test evidence, particularly where site selection relies heavily on mapped risk, standing advice from the Environment Agency, or constrained land supply assumptions.

Exception Test and flood vulnerability in the draft NPPF

The consultation draft also proposes to consolidate flood risk vulnerability and compatibility into a new annex. Existing guidance and policy remain applicable for now.

The intention is to reduce reliance on interpretation and embed key relationships directly into national policy. If carried forward, this would sharpen how flood vulnerability classifications are applied and how compatibility is assessed against evidence derived from the Flood Map for Planning and datasets and guidance referenced alongside mapping updates, including NaFRA2-related mapping guidance.

In practice, this reinforces the need for Flood Risk Assessments that explicitly address vulnerability, compatibility and residual risk, rather than relying on high-level assertions.

Lifetime safety and refusal risk

The requirement for development to be safe for its lifetime is not new. What the December 2025 NPPF draft consultation proposes is to make the consequence of non-compliance more explicit, by stating more clearly that development which cannot be demonstrated to be safe should be refused.

This is not enacted policy, but it is a strong signal of intent. If adopted, it would further elevate Flood Risk Assessments as central planning documents and increase scrutiny of how long-term risk is managed, including the way emergency planning and forecasting information is understood and contextualised (for example, the roles of the Flood Forecasting Centre and the Met Office).

Drainage policy signals in the December 2025 draft

The draft consultation also proposes clearer national expectations around drainage, including explicit reference to national SuDS standards and a stronger policy position on watercourse management.

These proposals are not currently in force. Local policy and existing NPPF wording continue to apply.

However, the direction of travel is clear. If adopted, drainage would be expected to:

• be addressed early in design;
• demonstrate compliance with national standards; and
• contribute meaningfully to flood risk management rather than simply managing runoff on-site.

This aligns closely with the 2025 National Standards for Sustainable Drainage Systems and with emerging best practice on early-stage SuDS planning.

At local level, this also reinforces the influence of Lead Local Flood Authorities, local planning authorities’ approach to flood risk and SuDS, and specialist bodies such as Internal Drainage Boards where water level management is critical. In London-specific contexts, it also interacts with strategic expectations set out in the 2025–30 London Surface Water Strategy.

From flood strategy to condition discharge

A more rules-based framework would also increase scrutiny at condition stage. Where flood risk and drainage are central to acceptability, decision-makers are likely to expect clear, deliverable strategies up front, with less reliance on open-ended conditions.

This has practical implications for how drainage and flood mitigation measures are ultimately approved, particularly through the discharge of drainage-related planning conditions, and how responsibilities are shared with water authorities.

Coastal change and devolved policy context

The same consultation caveat applies to coastal change. The December 2025 NPPF draft proposes clearer wording on the inappropriateness of permanent residential development in areas at risk of coastal change, but this is consultation wording only.

Its inclusion nonetheless reflects a broader consistency across jurisdictions, including the approach taken in TAN15 in Wales and the role of Natural Resources Wales in embedding long-term flood and coastal risk into planning decisions.

What the December 2025 NPPF draft consultation signals overall

Taken together, the December 2025 NPPF draft consultation does not change flood risk, drainage or the Sequential Test overnight. Instead, it signals an intention to:

• make flood risk policy more explicit;
• reduce ambiguity at decision-taking stage; and
• align flood and drainage policy with a more rules-based planning system.

This sits within a wider statutory and policy framework shaped by the Flood and Water Management Act 2010 and overseen at national level by Defra.

If adopted broadly as drafted, the likely practical effects would include:

• more structured Sequential and Exception Test assessments;
• greater emphasis on evidential quality; and
• earlier integration of drainage into scheme design, with clearer outcomes where flood or drainage policy tests are not met.

Final thoughts

It bears repeating: this is a consultation draft, not enacted policy. The existing NPPF remains fully in force until any revised Framework is formally adopted.

However, consultation drafts of this nature are intended to influence future practice. In flood risk, drainage and Sequential Test terms, the signal is clear. If the draft is taken forward broadly in its current form, the NPPF flood risk framework would operate in a more explicit, more rules-based and less discretionary way than at present.