The Revised NPPF and Flood Risk: What’s Changing and What to Do Now

The revised NPPF and flood risk are now tightly linked. The government's December 2025 consultation on a rewritten National Planning Policy Framework closed on 10 March 2026, and the revised framework is expected in summer 2026. For flood risk it points towards a more explicit, rules-based approach, but the sequential test is not being scrapped. This article sets out where the reform has got to, what is likely to change for flood risk and the sequential test, and what to do now while the current framework still applies.

The government describes the rewritten framework as the most significant reform to national planning policy since the original NPPF was introduced in 2012.

Where NPPF reform stands right now

As of July 2026 the revised NPPF has not been published. The December 2025 draft was out for consultation until 10 March 2026, the government is working through the responses, and it has signalled publication in summer 2026. Until that happens, the December 2024 NPPF remains the framework in force, and applications are still decided against it.

The draft sits alongside the Planning and Infrastructure Act 2025, which received Royal Assent on 18 December 2025. Rather than a light refresh, the consultation draft is a wholly restructured framework: policies are re-platformed into coded, plan-style rules, national decision-making policies run through the document, and the old presumption in favour of sustainable development becomes a "permanent presumption in favour of suitably located development". Parliament returned to it in a Westminster Hall debate on 16 July 2026, briefed by the House of Commons Library.

What the revised NPPF changes for flood risk

The draft does not rewrite flood risk policy from scratch. It makes it more explicit and moves it up the running order, signalling that flood risk should be treated as a primary constraint on where development goes rather than a detail settled later. The main flood-related proposals are these.

• Flood risk gets its own chapter. Flood risk and coastal change are separated out of the wider climate change section, which reads as a deliberate signal that flood risk is a first-order siting issue.
• The sequential test is clarified. The draft tightens the wording on when the test applies, how the search area is defined, and the evidence an applicant is expected to bring.
• Vulnerability moves into an annex. Flood risk vulnerability and compatibility are consolidated so the classification that decides which uses belong in which zone is easier to apply.
• Safe for its lifetime, or refused. The draft states more plainly that development which cannot be shown to be safe for its lifetime should be refused.
• National SuDS standards are named. Drainage expectations are pinned to national sustainable drainage standards, with a firmer line on watercourse management.

Taken together, these changes push flood risk earlier in the process and raise the bar on the evidence a scheme has to carry.

Will the sequential test be weakened?

Not in the way the headlines suggest. The sequential test stays, and since the December 2024 NPPF and the September 2025 Planning Practice Guidance update it applies to all sources of flooding, including surface water. The argument is narrower, and it is about surface water specifically: a carve-out lets a site avoid the sequential test where a site-specific assessment shows the development would be safe for its lifetime and would not increase flood risk elsewhere.

Insurers and flood bodies fear that carve-out being widened. In a joint letter to the Secretary of State, the Association of British Insurers set out its concern about allowing development to bypass the test in areas at high risk of surface water flooding, and Unda has covered why the insurance industry is warning against the change. The Town and Country Planning Association has raised similar concerns about the direction of flood policy.

For applicants the practical point is unchanged: surface water is now a siting question, not just a drainage detail, and a site that relies on the carve-out needs the assessment to prove it.

Drainage and SuDS: the direction of travel

The same insurers pressing on the sequential test are using the moment to push a longer-standing demand: mandatory sustainable drainage. Their route is Schedule 3 of the Flood and Water Management Act 2010, which would make SuDS approval a formal requirement but has sat unimplemented since 2010.

Whether or not Schedule 3 is switched on, the draft NPPF already expects drainage to meet the 2025 national standards and to do more than manage runoff on the plot.

That expectation rewards early design. Schemes that fix the drainage strategy against the national SuDS standards from the outset are far less likely to be unpicked at the discharge-of-conditions stage than schemes that treat drainage as something to resolve after permission.

What to do before the revised NPPF lands

Nothing in the draft is enacted yet, so the current NPPF still governs every live application. The sensible response is not to wait for the final text but to make sure existing evidence is robust enough to survive a more explicit, less discretionary regime.

1. Commission the flood risk assessment early, so flood risk shapes the layout rather than being retrofitted to it.
2. Treat the sequential test as a live requirement across all sources of flooding, surface water included, and document the search properly.
3. Design drainage to the 2025 national SuDS standards from day one, not at condition-discharge stage.
4. Get it right first time. Since the April 2026 changes, the appeals process leaves little room to fix flood risk or drainage later.

If you are promoting a site or preparing an application and want to sense-check how your flood risk and drainage evidence would stand up as the framework tightens, Unda's sequential and exception test reports and wider NPPF flood risk assessment guidance are a good place to start.

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