Draft London Plan 2026 Signals Major Changes to Energy Standards for New Developments
Since the release of the Future Homes Standard in March 2026 the industry has been questioning what this would mean for the energy requirements within the current London Plan.
The current London Plan has an established energy hierarchy for major developments requiring ‘be lean, be clean and be green’ stages of analysis. The impact is that major residential developments built under the London Plan requirements demonstrate greater levels of energy efficiency and lower carbon emissions than current national Building Regulations.
On 16th July 2026 the Mayor of London published the Draft London Plan. This proposes some significant changes to building energy and carbon requirements, with new performance-based standards set to reshape how developments are designed, assessed and delivered.
The proposed changes, outlined in Chapter 5 of the draft plan, mark a decisive move away from percentage-based compliance methods and towards absolute energy performance targets, alongside continued measured building performance, embodied carbon reduction and climate resilience.
The consultation closes on 15th October 2026, with adoption expected in early 2028.
VIEW THE DRAFT LONDON PLAN CONSULTATIONNew Absolute Energy Targets Introduced
At the heart of the proposals is Policy GHR1, which introduces absolute performance targets for new developments.
Under the draft policy, all building typologies would be expected to achieve a space heating demand (SHD) of 20 kWh/m² per year, with an aspirational target of 15 kWh/m² per year. The draft also sets Energy Use Intensity (EUI) targets for different building types, including 40 kWh/m² per year for residential buildings and 90 kWh/m² per year for offices. The policy would also retain the requirement for major developments to monitor and report annual in-use energy demand for at least five years after construction.
Significantly, the policy measures both regulated and unregulated energy consumption. This signals a departure from the long-established approach of demonstrating percentage improvements against a notional building model as per national Building Regulations.
The draft plan also seeks to create consistency across the capital, stating that plan-making authorities should not set their own energy-efficiency or emissions-reduction standards in local plans.
End of the Traditional Energy Hierarchy
The proposals would fundamentally alter London’s familiar “be lean, be clean and be green” energy hierarchy.
While many of the principles behind the existing energy hierarchy remain, the Draft London Plan restructures these requirements across a new set of policies:
- Energy efficiency (GHR1) introduces absolute SHD and EUI targets, alongside requirements for renewable energy and in-use energy monitoring.
- Low-cost low-carbon heat (GHR2) introduces a technology-neutral Low Carbon Heat Appraisal, considering factors including whole-life carbon and costs to occupiers.
- Whole life-cycle carbon (GHR3) strengthens requirements around embodied carbon.
- Heat risk (GHR4) strengthens the approach to overheating and climate resilience.
One of the most notable changes is the proposed removal of carbon offset payments, which previously allowed developments to contribute financially towards achieving zero-carbon requirements. The draft policy instead places greater emphasis on reducing emissions at source.
New Targets for Embodied Carbon
The Draft London Plan also strengthens the focus on embodied carbon through Policy GHR3.
For referable applications, developers would be required to assess opportunities to retain existing buildings and structures, demonstrate how upfront embodied carbon has been reduced through design and material efficiency, and calculate and report whole life-cycle carbon emissions.
The policy also introduces baseline and aspirational upfront embodied carbon targets for specified building types, placing greater emphasis on the carbon impact of construction materials and development over the entire life of a building.
Stronger Measures to Address Overheating
The Draft London Plan also strengthens requirements relating to overheating through Policy GHR4.
The policy would apply to all major development and all building uses, extending beyond current Building Regulations on overheating, which currently apply only to residential uses.
The policy specifically references industry-standard methodologies including TM59, TM52 and TM49, embedding them directly within planning policy. Developments will also be expected to incorporate external shading on façades exposed to direct sunlight where appropriate.
Residential schemes would be required to submit a Good Homes Alliance (GHA) ‘Early Stage Overheating Risk Tool’ checklist.
The broader scope of the policy reflects growing concerns over the impact of rising temperatures and increasing heat risk across London’s built environment.
A Fundamental Shift in Planning Policy
Taken together, the draft proposals represent a fundamental shift in London’s approach to sustainable development.
Rather than focusing on theoretical carbon savings or compliance against modelled benchmarks, the new framework prioritises actual building performance, operational efficiency, embodied carbon reduction and climate resilience.
If adopted in its current form, the Draft London Plan would establish some of the UK’s most demanding building performance standards and could significantly influence planning and development practices across the wider construction industry.
New Build Dwellings Manager, Jason Hewins, commented:
Since the release of the Future Homes Standard we have been anticipating changes to the London Plan to reflect this. The draft plan and consultation provide further details of how building standards in London will be implemented in future.
There is still further detail to come, and Elmhurst will keep members updated with developments in this area.