The 2026 Local Plan now under consultation is broadly in continuity with the 2024 proposal to lower the required affordable housing threshold. The policy uses a value-zone approach: the City Centre is the core zone; there is a higher-value zone covering the southern part of the City Centre and the northern part of the city; a lower-value zone forms part of the city’s inner ring; and a medium-value zone covers the city’s outer ring.
The minimum affordable housing requirement in the Central Zone will be reduced from 35% to 20%. Affordable housing requirements on brownfield sites in medium- and lower-value zones are also set at 20%, while higher-value zones require 25%. Only greenfield sites in high- and medium-value zones retain the 35% threshold.
The main change between the 2024 and 2026 approaches concerns the tenure split.
The 2026 Plan retains the high-level split of at least 70% rented housing and no more than 30% home ownership, but introduces a new sub-target: within the rented element, at least 80% must be social rent, with the remaining 20% able to be affordable rent. However, where the overall affordable housing requirement is only 20%, this would result in approximately 11.2% of total housing provision being social rent. This is broadly comparable with the existing 11.4% provision under the 2017 BDP policy. The new target therefore represents more of a restructuring of the existing approach than a significant increase in social housing provision.
The Plan argues that lower requirements will make more schemes viable and ultimately increase affordable housing delivery, particularly social rent.
However, the evidence presented does not demonstrate that this trade-off will occur.
Indeed, the Council’s own 2024 Whole Plan Viability Assessment identified significant viability constraints in the City Core, Low Value and Medium Value (brownfield) zones and concluded that only 10% and 15% affordable housing targets were viable in some of these areas. Viability assessments typically allow for a 15–20% developer profit margin.
The 2024 Plan acknowledged that these were very low targets and would not meet the city’s affordable housing needs. The 2026 Plan does not appear to provide a sufficiently robust mechanism to demonstrate that reducing the requirement further will result in greater actual delivery.
In this regard, the justification for lowering the affordable housing threshold that has circulated in public debate—that national housing funding will help address the resulting shortfall—is not sufficient. The anticipated national housing funding should not be treated as a substitute for a strong local planning requirement.
While the Government has established a substantial Social and Affordable Homes Programme for 2026–2036, access to this funding is not automatic. The current programme provides significant funding certainty at a national level, but it does not guarantee that every local housing ambition will be funded.
Homes England assesses bids according to criteria including value for money, strategic fit and deliverability, and retains responsibility for final funding decisions. Partners are also expected to minimise the level of grant requested and maximise their own contribution. There is therefore no guarantee that funding will be available for any particular scheme, at the scale required, or on the timescale needed to compensate for a lower planning requirement.
The purpose of the Local Plan is to provide a long-term vision and framework that is future-proof, resilient to changes in funding arrangements and government priorities and meets the needs of the city’s residents. Without firm local policy mechanisms to secure affordable housing, the current version of the Plan risks failing to do so.
The scale of need makes this particularly concerning. The 2026 Plan, drawing on the 2025 HEDNA, identifies around 63,100 households living in unsuitable housing and approximately 13,300 households with no accommodation. The HEDNA identifies a need for around 4,995 affordable dwellings per year, with approximately 97% of this need arising from households unable to buy or rent privately.
Actual delivery has fallen far short of this need. FOI data indicates that 22,483 homes were completed in Birmingham between 2020 and 2025, but only 762 were affordable rent and 407 were social rent. Around 95% of completions were therefore neither affordable rent nor social rent.
This need for social housing is further demonstrated by the scale of demand, which far exceeds the rate at which social housing is currently becoming available. There are currently around 31,000 families waiting for a council home in Birmingham, alongside a significant backlog of applications awaiting assessment. As of April 2024, this backlog stood at least at 10,358 applications.
Birmingham City Council advertises an average of 57 properties a week while receiving approximately 450 applications each week. This means that roughly 20,000 families per year remain without their housing needs being met, contributing to the growing backlog of households on the waiting list and applications still awaiting assessment.
There are also concerns about the operation of the viability process as a whole and how it is managed in the city.
Developers can continue to deliver less than the required level of affordable and social housing, even after the proposed lowering of the minimum requirements, on the basis that schemes are not viable.
Moreover, affordable and social housing secured at the planning stage can subsequently be reduced or removed where viability is reconsidered. Affordable and social housing are often “value engineered out” before completion in Birmingham. Between 2018 and 2023, 4,557 affordable homes were approved, but only 1,539 were delivered. This suggests that the key problem is not simply the level of the policy target, but the effectiveness of the mechanisms used to secure and deliver affordable housing. The substantial gap between affordable homes approved and delivered further demonstrates the importance of addressing delivery, rather than simply setting a lower target.
The Plan should therefore be strengthened before adoption. If the Council considers a lower affordable housing requirement necessary for viability reasons, it should provide clear evidence that the proposed thresholds will result in greater actual affordable and social housing delivery, together with stronger mechanisms to secure delivery and prevent agreed affordable and social housing from being subsequently reduced. Given the scale of unmet housing need in Birmingham, reducing the requirement from 35% to 20% without such safeguards risks institutionalising a lower level of affordable housing provision rather than resolving the underlying delivery problem.
This post is an extract from a longer post about the Birmingham Local Plan, published on the LinkedIn page of the BLUEPRINTS project. Read the longer post here: https://www.linkedin.com/pulse/housing-regeneration-when-local-plan-risks-becoming-marco-di-nunzio-rrise/
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