NPPF 2026: What the New Flood Risk Planning Rules Mean for Developers
The National Planning Policy Framework (NPPF) was updated on 17th August 2026, bringing significant changes to how flood risk is considered through the planning process in England.
The revised Framework replaces the December 2024 NPPF and introduces a dedicated Chapter 18, Managing Flood Risk and Coastal Change, supported by Policies F1 to F9 and a new Annex F.
For developers, architects and planning consultants, the important question is what these changes mean in practice for getting a project through planning. At Ashfield Solutions, we have already reviewed and updated our Flood Risk Assessment process to reflect the new requirements, ensuring our assessments are aligned with the current Framework.
In this article, we break down the key changes and what they mean for development proposals, including when a Flood Risk Assessment (FRA) is required, how the Sequential Test has changed, new exemptions, surface water drainage, development safety, SuDS and the implications for infrastructure such as EV charging.
Flood Risk Needs to be Considered Earlier
One of the key changes is the emphasis on understanding flood risk from all sources, both now and in the future.
Under Policy F4, Flood Risk Assessments remain required for development in Flood Zones 2, 3a and 3b. In Flood Zone 1, an FRA may also be required for sites of 1 hectare or more, sites within critical drainage areas, and land identified through a Strategic Flood Risk Assessment or the Flood Map for Planning as being at risk of flooding from any source, now or in the future.
This means that simply checking a site’s Flood Zone is no longer enough. Surface water, groundwater, sewer and other sources of flood risk can all be relevant.
For project teams, early flood risk screening is therefore increasingly important. Identifying constraints before a site layout is fixed can help avoid costly redesigns and delays later in the planning process.
What’s changed with the Sequential Test?
The Sequential Test is essentially a way of demonstrating that a development has been directed towards the areas at lowest risk of flooding that are reasonably available and suitable for the development.
The 2026 NPPF changes how this needs to be approached. The search area should not automatically cover the whole local planning authority area. Instead, it should reflect the anticipated catchment of the development, based on its likely occupiers or users, with the search area appropriately justified.
There are also new circumstances where the Sequential Test may not be necessary.
Where surface water is the only source of flood risk, an FRA can demonstrate that the development can be safely designed and mitigated for its lifetime without increasing flood risk elsewhere. The test may also not be required where an FRA clearly shows that no built development, access or escape route, land raising or other potentially vulnerable element would be located within an area at risk of flooding.
This makes the approach more proportionate and site specific. A site being identified as at flood risk does not automatically mean a wide ranging search for alternative sites is required. In specific circumstances, a well evidenced Flood Risk Assessment can demonstrate that the Sequential Test is not necessary, based on where the flood risk affects the site and whether the development itself can be safely located and designed.
Demonstrating safety Over the Development Lifetime
Policy F7 places a stronger emphasis on demonstrating that development will remain safe throughout its anticipated lifetime.
It is not enough for an FRA simply to conclude that a development is “safe”. The assessment should demonstrate how the proposal meets the relevant safety requirements, including its layout, lifetime flood risk, residual risk, safe access and escape where appropriate, flood resistance and recoverability, and the requirement not to increase flood risk elsewhere.
Flood resistance measures are those intended to help keep water out of a building or structure. Where some residual flooding remains, recoverability measures can help reduce damage and support a quicker return to use. These can include raised electrics, water resistant flooring, flood compatible insulation, sump pumps and materials designed to tolerate immersion.
For developers, this reinforces the value of integrating flood risk into the design process. Finished floor levels, access, drainage, resistance, recoverability and the wider site layout should be considered together rather than treated as separate issues.
SuDS, Drainage and Changing Development Types
Policy F8 also strengthens the policy position around Sustainable Drainage Systems (SuDS). Developments affecting drainage should incorporate SuDS proportionate to the proposal and designed in accordance with the National Standards for Sustainable Drainage Systems, as well as relevant local guidance.
The policy also places greater emphasis on avoiding unnecessary enclosure of watercourses and supporting de-culverting and re-naturalisation where appropriate.
Annex F is particularly relevant to certain infrastructure projects. Electric vehicle charging stations are now explicitly identified as Essential Infrastructure, alongside infrastructure including electricity networks, solar farms, hydrogen facilities, heat networks and data centres.
This is an area where Ashfield Solutions are already seeing increasing demand. We are helping a growing number of clients assess flood risk associated with EV charging developments, including understanding when a Flood Risk Assessment is required and how flood zone, vulnerability, drainage and design considerations affect a proposal. Our recent Flood Risk Assessment for EV Charging case study demonstrates how we apply this expertise in practice.
The new NPPF makes the early assessment of these projects particularly important. While the Essential Infrastructure classification can provide greater flexibility in higher flood risk areas, it does not mean that EV charging developments are automatically acceptable. The proposal still needs to demonstrate that flood risk can be appropriately managed and that the development will remain safe over its lifetime.
How Ashfield Solutions Are Already Responding
At Ashfield Solutions, we have already reviewed and updated our Flood Risk Assessment process to reflect the August 2026 NPPF requirements.
Our approach now places greater emphasis on early flood risk screening, including whether the new Sequential Test exemptions may apply, defining an appropriate search area where a Sequential Test is required, and demonstrating how development will remain safe throughout its lifetime.
We have also updated our assessment of vulnerability for infrastructure such as EV charging and energy projects, alongside our approach to surface water drainage strategies and the National Standards for Sustainable Drainage Systems.
This means our clients can be confident that their Flood Risk Assessments are prepared with the latest national planning requirements in mind, while focusing on the practical flood risk and design considerations that can affect whether a development is deliverable.
What about developments in Wales?
These changes apply only to England. In Wales, flood risk planning continues to be governed by Planning Policy Wales and TAN 15, meaning Welsh projects follow a different set of tests, SuDS requirements and zone definitions.
The update does, however, widen the policy gap between the two nations, so cross border developers should ensure assessments are prepared against the correct national framework.
If you are preparing a planning application, developing a site layout or reviewing an existing proposal, Ashfield Solutions can help you understand what the latest flood risk requirements mean for your project and ensure the appropriate assessment is built into the planning process from the outset.
Planning a development in an area at risk of flooding?
Whether you are at the early site appraisal stage or preparing a planning application, Ashfield Solutions can help you understand how the latest NPPF requirements apply to your project. Our flood risk specialists can provide Flood Risk Assessments, Sequential Test advice and surface water drainage strategies tailored to your development, helping you identify constraints early and demonstrate compliance with current planning policy.
Get in touch with Ashfield Solutions to discuss your project.
