The New NPPF 2026: What Has Changed for Heritage?

Heritage has moved to Chapter 20

The historic environment is now addressed in Chapter 20: Conserving and enhancing the historic environment.

Rather than the previous sequence of paragraphs 202–221, heritage policy is now organised into ten policies, HE1–HE10.

HE1–HE3 principally relate to plan-making and Historic Environment Records, while HE4–HE10 contain the policies most likely to be encountered when preparing and determining planning applications.

For development management purposes, the core sequence is now broadly:

• HE4 – Securing the conservation of heritage assets

• HE5 – Assessing effects on heritage assets

• HE6 – Proposals affecting designated heritage assets

• HE7 – Decisions on non-designated heritage assets

with additional policies for World Heritage Sites, Conservation Areas and the loss or removal of heritage assets.

“Less than substantial harm” has gone

Probably the most noticeable change for heritage practitioners is the removal of the familiar phrase “less than substantial harm”.

Under the previous NPPF, effects on designated heritage assets were generally considered within a framework of no harm, less than substantial harm, substantial harm or total loss.

The new HE5 takes a different approach.

Heritage assessments should now identify whether development would result in:

• a positive effect;

• no effect;

• harm;

• substantial harm; or

• total loss.

For the first time, the NPPF also expressly describes substantial harm as occurring where development would seriously affect a key element of a heritage asset’s significance.

That places even greater importance on getting the significance assessment right at the beginning of a project. It is difficult to understand whether a key element of significance would be seriously affected if that element has never been clearly identified.

Positive effects now have an explicit place in the policy

Another helpful change is the express recognition of positive effects.

• HE5 describes a positive effect as one where the significance of a heritage asset would be enhanced or better revealed.

• HE6 then states that development proposals having a positive effect on a designated heritage asset should be supported.

This is useful recognition that heritage assessment should not simply be an exercise in measuring degrees of harm.

Good development can repair historic fabric, bring buildings back into use, better reveal significance, improve settings and secure the long-term future of heritage assets. The new policy structure gives those outcomes a clearer place within the assessment.

“Great weight” becomes “substantial weight”

The wording applied to designated heritage assets has also changed. The previous Framework required great weight to be given to the conservation of a designated heritage asset. HE6 now requires substantial weight.

The underlying principle remains very strong. The policy states that the more important the asset, the greater the weight should be, and that this applies irrespective of whether the proposal would result in a positive effect, harm, substantial harm or total loss.

Where harm occurs, the NPPF also makes clear that it is a matter of considerable importance and weight.

So the change in terminology should not be read as heritage protection simply disappearing or becoming insignificant.

The harm and public-benefit exercise has changed

Under the previous Framework, paragraph 215 contained the well-known balancing exercise for less than substantial harm. Because “less than substantial harm” no longer exists as a separate category, the new HE6 is structured differently.

Where development would cause harm to the significance of a designated heritage asset, that effect and the significance of the asset should be weighed against the public benefits of the proposal.

The policy expressly recognises that important public benefits may include securing the long-term reuse of a vacant or underused listed building and enabling energy-efficiency and low-carbon heating measures.

Substantial harm and total loss remain subject to a much more demanding test.

The significance assessment matters more than ever

HE5 requires proposals affecting heritage assets to be supported by an assessment of:

• the significance of the assets affected, including any contribution made by their setting; and

• the potential effect of the proposal on that significance.

The assessment must be proportionate to the importance of the asset and no more detailed than necessary to understand the potential effect.

Crucially, HE5 also makes clear that it is the effect on heritage significance, rather than the scale of the development itself, which should be assessed.

A visually large development does not automatically cause substantial heritage harm. Equally, a physically small intervention can have a significant effect if it damages a particularly important element of significance.

The analysis must therefore connect the proposed change directly to the archaeological, architectural, artistic or historic interest of the affected asset.

Heritage Impact Assessments are expressly recognised

There is also a useful change in Annex C of the Framework.

The national information requirement associated with HE5 is expressly identified as a Heritage Impact Assessment, comprising an assessment of the significance of the assets affected, including the contribution made by their setting, and the potential effects of the proposal on their significance.

For applicants, this reinforces the importance of proportionate heritage assessment at an early stage of design rather than treating heritage as something to address retrospectively once a scheme has already been fixed.

Non-designated heritage assets have their own policy

Non-designated heritage assets are now addressed by HE7. Where development would positively affect a non-designated heritage asset, the proposal should be supported.

Where harm would arise, a balanced judgement is required, taking account of the scale of harm or loss, the significance of the asset and the benefits of the proposal. Where substantial harm or total loss would occur, the policy applies a correspondingly stronger test.

Conservation Areas and World Heritage Sites have dedicated policies

The new Framework also separates out policies for these particularly important forms of designation.

HE8 deals specifically with World Heritage Sites and requires consideration of significance, Outstanding Universal Value, setting and any buffer zone.

HE9 deals specifically with Conservation Areas. It requires proposals to consider their special architectural or historic interest and to retain and conserve buildings and other features making a positive contribution where possible.

This provides a clearer decision-making framework than the previous arrangement, where much of this material was contained within the final paragraphs of Chapter 16.

What about archaeology?

Archaeology remains firmly embedded within the heritage policies. HE5 requires an appropriate desk-based assessment where development involves, or has the potential to involve, a heritage asset with archaeological interest, with field evaluation where necessary.

HE10 also states that heritage assets with archaeological interest should be preserved in situ where feasible. Where this cannot be achieved, appropriate provision should be made for investigation, understanding, recording, dissemination and archiving.

What does this mean in practice?

For anyone preparing a Heritage Statement or Heritage Impact Assessment from 17 August 2026, simply replacing the old paragraph numbers will not be enough. Assessments need to reflect the new policy language.

In particular, reports should:

• identify significance clearly through archaeological, architectural, artistic and historic interest;

• explain the contribution made by setting where relevant;

• connect the proposed change directly to that significance;

• identify the resulting effect using the HE5 terminology;

• apply the appropriate HE6 or HE7 balance where harm occurs; and

• use the specific HE8, HE9 and HE10 policies where World Heritage Sites, Conservation Areas, archaeological assets or loss are involved.

The removal of “less than substantial harm” may initially feel like a major change for those accustomed to the old terminology. In practice, however, the underlying task remains familiar: understand what matters about the heritage asset, understand how the proposal changes it, and make the policy judgement from that evidence.

The new NPPF simply makes that chain of reasoning more explicit.

At Aurora Heritage Planning, we have updated our heritage assessment methodology and report templates to reflect the new Framework.

If you are preparing a development proposal affecting a listed building, Conservation Area, archaeological site or other heritage asset and are unsure what level of heritage assessment is required, we can advise on the appropriate and proportionate approach.