On 7 May 2026, RTPI Scotland submitted a response to the Scottish Government's consultation on accelerating home-building in Scotland. Read the response below.
About the RTPI
At the Royal Town Planning Institute (the RTPI), we champion the value of planning in building thriving places and communities. With over 27,000 members worldwide, we support planners at every stage of their career: raising professional standards, shaping planning policy, and proudly awarding chartered status, the highest professional accreditation in UK planning. For over a century we have empowered planners to deliver positive impact: creating healthy, inclusive, economically and environmentally sustainable places. As the voice of the profession, we advocate, support, and lead with purpose, professionalism, and passion.
Question 1: Could fiscal incentives offering relief to other charges help to accelerate build-out rates?
Yes
RTPI Scotland agrees that fiscal incentives could have a role to play in reducing the level of risk associated with housing development projects. Housebuilders are typically required to invest significant capital up front for a housing project, for which it will likely be a long period of time before they see any returns. Reducing the tax burden through fiscal incentives could, therefore, have positive repercussions such as enhancing project viability and reducing risk.
This was recognised by the CMA in their Housebuilding Market Study. However, the CMA also recognised that fiscal incentives alone will not deliver enough homes to meet housing need. For example, although incentives could reduce risk and encourage more developments, they will not directly accelerate the planning consenting process, nor will they address other obstacles that cause housing proposals to stall – including obstacles related to remediating contaminated sites, and the provision of infrastructure related to flooding, drainage, transport, education etc. In addition, the CMA study also highlighted that accelerating private sector housing will not necessarily address overall housing need, recognising that “significant numbers of households lack the resources to be able to afford adequate housing on the private market”.
RTPI Scotland is of the view that fiscal incentives (whilst having potential positive implications) should not be applied in a blanket manner for the sole financial benefit of private sector housebuilders. Instead, such incentives should be applied in a spatially targeted way to ensure their main goal is to further the placemaking objectives of NPF4 and deliver positive place-based development and regeneration outcomes for Scotland’s communities. An example of where such incentives could be spatially targeted are on brownfield sites where issues of contamination, flooding, heritage etc. impact their viability and where such incentives could help to derisk and unlock them for future housing development.
1a: Which charges / taxes / levies could the incentives be applied to?
RTPI Scotland has no view on which specific charge, tax or levy incentives should be applied, other than to say that such incentives should be strategically and spatially applied to facilitate a place-based approach to housebuilding in line with the objectives of NPF4.
1b: Should relief be in the form of full exemptions or variable rates?
No comment
1c: Could a tax impact differently on different types of land owners?
No comment
1d: Please provide any evidence of how fiscal measures linked to other charges would impact development finance to influence built out rates.
No comment
Question 2: Should we introduce a tax on sites which have been allocated for residential development and/or have permission for homes, but are not being built out as expected, as set out in option 1?
No.
Just as fiscal incentives alone will not deliver the houses needed, we are also unconvinced that the introduction of a new tax will directly accelerate housing build out rates. On the contrary, we are concerned that such fiscal penalties could undermine confidence in the system and lead to a reduction in the number of sites brought forward for housing allocation and development.
In addition to the ineffectiveness of a new tax or penalty in accelerating housebuilding, we are also concerned about the additional resources that will be required to enforce and administer such a new tax. Local authorities are already under increasing financial pressures, as evidenced in the RTPI’s latest State of the Profession report, and we are concerned that the introduction of a new tax or fiscal penalty will exacerbate this situation. This is particularly so, given that for such a tax or penalty to be effective, it cannot be imposed through blanket mechanisms. There are a variety of reasons why a site allocated for residential development may not have been built out as expected. These are often beyond anyone’s control such as changes in supply chains and construction material costs; weather events that affect site safety or access (high winds, flooding, soil saturation); prolonged transport disruption affecting rail, road or ferry links. In such cases, it would be counterproductive to the aims of this consultation paper to apply a tax or penalty. Ascertaining the reasons for delayed build out to determine where blame and associated penalties should be directed would require a robust investigation that would need to be adequately resourced to be successful. Furthermore, the issuing of any fiscal penalty on the back of this investigation should be a last resort only once all other avenues to rectify the situation and agree a way forward have been exhausted.
It is the view of RTPI Scotland that instead of a new tax or fiscal penalty, an approach centred around collaboration should be the focus of efforts to accelerate the build out of delayed or stalled housing developments. This should sit within the remit of More Homes Scotland, or any similar housing body that is created, to investigate and design innovative solutions for site specific and other external barriers that are causing delay.
2a: Should this apply to allocated sites, sites with permission, or both?
RTPI Scotland does not support the introduction of a tax on sites which have not been built as expected. As stated previously, we do not believe that the adoption of punitive measures will result in the acceleration of housebuilding in Scotland. This is likely to disincentivise development by creating additional risk for housebuilders.
Instead, an approach should be adopted that focuses on collaboration to accelerate the build out of delayed or stalled housing sites. This should sit within the remit of More Homes Scotland, or any similar housing body that is created, to investigate and design innovative solutions for the broader and site-specific barriers that are being faced.
2b: How should the tax be calculated? Please explain your answer.
No comment.
2d: Should the tax operate as a local or a national tax?
We are opposed to the introduction of a new tax. If introduced at the local level, we are concerned that this would place additional pressures on the capacity of local authorities to monitor, administer and enforce such a tax on top of their other duties. Before a new tax is introduced, a detailed assessment must be undertaken to demonstrate that the income generated would adequately offset the additional resources required to administer it.
2e: How should any income be used? Please explain your answer.
RTPI Scotland does not support the introduction of a new tax. However, if a tax were to be introduced, the income generated should be used to support the acceleration of housing development in Scotland by, for example, bringing forward infrastructure to support the delivery of new homes and implement an infrastructure-first approach to development, as called for in RTPI Scotland’s Planifesto. Using the income from a new tax in this way could help to de-risk new sites, creating additional confidence for developers who are facing uncertain market conditions.
2f: Please provide any evidence of how a tax connected to sites allocated or permitted not being built out would influence build-out rates.
No comment.
Question 3: Should we bring forward powers for reporting on development progress and powers to intervene where it is considered to be unreasonably slow, as set out in option 2?
Unsure.
RTPI Scotland recognises that reporting on development progress could assist to identify barriers to housing delivery. This could then build additional transparency into the housebuilding delivery process and help to facilitate a collaborative approach to addressing such barriers with support from, for example, a new housing delivery body such as More Homes Scotland. However, simply reporting on progress or delay will not necessarily produce a better or accelerated outcome. For such additional reporting and monitoring processes to be successful they must be coupled with an adequate resourcing and action strategy to ensure that local planning authorities (LPA) are not overburdened and have the right tools and resources to deliver positive outcomes in line with Scotland’s Development Plan.
We also do not believe that reporting and monitoring of individual projects alone will provide us with an accurate picture of the housebuilding situation across Scotland. Such practices also need to be coupled with a way to collect, collate, analyse and interpret the data from such reports in a way that will help us to understand the overall picture of housing delivery, as well as learn from and adapt to changing circumstances in an agile manner. This point extends beyond reporting on development progress and relates also to data that local authorities already collect through the planning consenting and other processes. It also extends beyond housebuilding to other areas of the built environment – including energy infrastructure, transport, biodiversity enhancement and nature restoration projects etc.
In addition to the above, we are also concerned that the language that the consultation paper suggests should trigger reporting on development progress is far too vague and open to interpretation. The term “unreasonably slow” suggests that there would be a specific time-period that projects would have to exceed to then be placed in this category. However, this cannot simply be a question of imposing a blanket timeframe. What is considered “unreasonably slow” will vary depending on the size of the development, the spatial context of the site, and the number and type of conditions attached to the planning consent, as well as other site, project and external factors – such as broader economic factors, adverse weather conditions, material and labour shortages etc. Depending on the circumstances, it could be argued that any delay caused by one or multiple of the above factors should be considered entirely reasonable and should not then result in a development being labelled “unreasonably slow”.
3a: Should this include creating a legal framework for reporting on development progress?
No.
RTPI Scotland does not believe that the introduction of additional duties, legislation, policies or frameworks will help to accelerate housebuilding in Scotland in practical terms. Scotland’s planning system is a plan-led and discretionary system. This is necessary to ensure that decisions achieve place-based outcomes based on professional planning judgement having regard to the Development Plan as well as to local, regional and national contexts. We are concerned that creating extra layers of legislation and rules will add confusion and further complications to the planning system.
First and foremost, LPAs, key agencies and other public actors involved in supporting housing delivery need to also be supported with sufficient resources to carry out their duties. In relation to LPAs, this not only relates to development management teams but also to plan-making teams to ensure that LDPs, which are the policy foundation for housebuilding in Scotland, are in place, up to date, and provide sufficient land supply to deliver the homes, services and infrastructure communities in Scotland need to thrive. RTPI Scotland’s Planifesto calls for a whole system approach to funding the planning service to ensure there is sufficient investment in forward plan-making. This includes long-term investment in future planners, as well making optimal use of data and digital tools.
3b: Should there be a power for planning permission to be revoked, without compensation being payable, where reporting demonstrates that progress is unreasonably slow?
No.
RTPI Scotland does not believe that the introduction of punitive measures will have a positive impact on accelerating housebuilding on the ground. Whilst we understand the frustrations surrounding slow build-out rates for local authorities and communities, it is not always the case that slower than anticipated delivery is due to the inaction of housebuilders or landowners. Rather than accelerating housebuilding, the utilisation of a ‘use it or lose it’ mechanism for planning permission runs the risk of leaving communities with unfinished housing development sites with no practical way forward to ensure their completion, creating areas of blight in the process. Such reactive punitive measures will not bring about the proactive place-based approach to housing delivery that Scotland’s communities need.
As mentioned in other of our responses to this consultation, approaches to accelerate housebuilding in Scotland should be proactive, productive and collaborative rather than punitive, addressing the real barriers to housebuilding using place-based principles rather than seeking to punish those perceived (whether fairly or not) to be responsible.
3c: How would the pace of development be set and agreed – for example how would reasonable-ness be measured? Please explain your answer.
We do not believe there is a one-size-fits-all method that could be adopted to ensure the fair implementation and utilisation of such an approach. Any use of such a mechanism would need to be based on a robust assessment and determined on a case-by-case basis having regard to the unique circumstances of the site, development, and wider economic contexts. We foresee that such an assessment would be time and resource heavy and would not necessarily have the outcome of accelerating housebuilding on the ground. As such, we cannot support it until further details are set out that evidence how it could be implemented in a way that would support local planning authorities, developers and communities.
3d: Please provide any evidence of how reporting on development progress would influence build-out rates.
As mentioned in Question 3, while reporting on development progress may help to inform local planning authorities of build out rates, it will not necessarily guarantee a better outcome unless coupled with measures and resources that would enable local planning authorities to proactively work with developers, landowners and housebuilders to address the findings of the report. Reporting alone runs the risk of creating more administrative work for local authority planners, further slowing down the planning and housing delivery process.
Question 4: Should we bring forward legislation to amend the development hierarchy, to enable us to introduce more streamlined planning processes on planning applications for smaller sites, as outlined in option 3?
No.
RTPI Scotland fully supports embracing proportionality in the plan and decision-making process. We are aware of the specific challenges that SMEs face – including the upfront costs associated with planning applications, the length of time to achieve the necessary consents, as well as post-consent outlays associated with rising material and labour costs. We consider that proportionality is critical to accelerate homebuilding in Scotland, and that SMEs, in particular, are worthy of support in this regard.
Notwithstanding the above, we do not believe that introducing more legislation to amend the development hierarchy will bring about the level of acceleration sought in this consultation paper. The introduction of additional thresholds for smaller developments is unlikely to benefit the entire SME sector. Whilst SME developers do play a critical role in delivering housing on smaller sites that are unappealing to larger developers, it is inaccurate to assume that all small housing sites are delivered by SMEs, or that all SMEs only deal with smaller sites. We understand that not all SME business models are the same, with some SME homebuilders seeking consent for larger sites that they plan to deliver over a longer period.
In addition, we are concerned that the introduction of additional thresholds with built in streamlined decision making, could encourage adverse behaviour change within the housebuilding sector to make the most of any new ‘streamlined’ process for smaller developments. One risk we foresee is a rise in the number of smaller housing proposals that take advantage of the ‘streamlined’ threshold, but which together represent a large-scale housing project that would otherwise warrant the full rigour of the planning consenting process. Without a mechanism to address the cumulative impact of such small-scale proposals that could be captured by a new ‘streamlined’ threshold, there is a risk that opportunities to achieve positive place-based outcomes could fall through the cracks.
Rather than setting out blanket legislative streamlining requirements for smaller sites, the identification of small sites suitable for more streamlined processes should be identified through the LDP preparation process. Tools are already available to enable this type of frontloading approach through, for example, the adoption of master plan consent areas (MCA), which could also be used to identify small-scale housing sites within a larger masterplan area. We are aware that some local planning authorities are already seeking to utilise MCA schemes in innovative ways that support Scotland’s plan-led discretionary system, and this could be another such innovative approach.
Approaching the streamlining of consenting processes through plan-making, rather than through broad-brush legislative change, would ensure a front-loaded place-based approach is taken that will result in a more streamlined consenting process once an application is submitted. This type of approach requires LPA plan-making teams to be adequately resourced to carry out this important frontloading work. In addition, we would also support the introduction of mechanisms into the LDP process to support enhanced flexibility by enabling the removal of allocated sites from the LDP that have proven themselves to be inviable, and the inclusion of new sites for allocation where there is sufficient evidence to support this. This would help to ensure that LDPs remain up to date and can continue to support housing delivery throughout their 10-year lifespan.
Delivering benefits for SME housebuilders cannot and should not be the role of the planning system, which is a spatial, plan-led and discretionary system. Whilst planning supports housebuilding in Scotland through the plan-making and consenting processes, housing delivery by SMEs also relies on a range of factors that are external to planning. We recommend, therefore, that a targeted approach to support SMEs will be best achieved through a new housing delivery body, such as More Homes Scotland, with support from other public bodies such as SNIB and Scottish Futures Trust.
4a: How many categories should be defined by the development hierarchy, and what size of development should these cover? For example, four categories, that define major, medium, small and very small developments.
No comment.
4b: What are your views on, and do you have any evidence relevant to whether creating more categories in the development hierarchy might have an overall effect of speeding up or slowing down build-out of housing?
In theory it could help to streamline consenting for smaller development proposals, a proportion of which will no doubt be put forward by SMEs. However, it could also encourage the strategic fragmentation of proposals by large-scale housebuilders to take advantage of a streamlined consenting process for smaller sites. If introduced, measures would need to be put in place to ensure that such new streamlined process would not result in negative outcomes that fail to deliver the objectives of NPF4.
4c: What are your views on whether we should review and rationalise policy requirements for smaller housing sites, or introduce a new rules based policy for smaller housing sites?
There is most certainly a need for NPF4 requirements to be interpreted proportionally having regard to the specific attributes of the site and development outcomes of the proposal. The Scottish Government has previously issued guidance encouraging assessment against NPF4 in the round rather than cherry picking policy or attempting to satisfy all policy requirements as a tick box exercise. We have heard from our members, however, that taking a proportionate and rounded approach to NPF4 has proven difficult for many reasons – including mounting staff work pressures.
We do not, however, believe that adopting a rules-based approach will effectively address this issue. As previously stated, Scotland’s planning system is a plan-led and discretionary system. This is necessary to ensure that decisions achieve place-based outcomes based on professional planning judgement having regard to the Development Plan as well as to local, regional and national contexts. We are concerned that creating extra layers of rules-based policy will add further complications and cause additional confusion over how they should be interpreted and applied across the whole of the country. For example, there are already difficulties in applying certain of NPF4 policies in rural areas and we are concerned that rather than alleviating confusion, a rules-based approach could further compound the issues we have already witnessed.
Rather than introducing additional nation-wide rules for the application of NPF4 policy, we would encourage LPA planning officers to be empowered to utilise their professional expertise to deliver place-based outcomes having regard to the broad policy objectives of NPF4 and the relevant LDP. Implementing additional rules could have adverse limiting consequence, restricting LPA officers from utilising their professional planning judgement and preventing them from embracing innovative solutions that could support homebuilding in ways previously unanticipated.
Facilitating this approach should also require local authorities to review their schemes of delegation to ensure that planning officers have the necessary agency to execute their professional planning judgement.
4d: Do you think that further advice on planning application information requirements would support faster delivery of housing on smaller sites?
No.
We understand the need for alignment and agreement across Scotland as to the interpretation and application of legislation and policy. Guidance and advice can certainly help with this by providing additional clarity. However, the form that such advice takes and how it is relayed, stored and accessed is equally important as the advice itself. What we have seen since the adoption of NPF4 in February 2023 is a proliferation of supplementary guidance and advice, the cumulation of which is creating a cluttered policy landscape which (in some areas) has caused increased confusion rather than clarity. Such advice has taken many different forms, including blogs, chief planner letters, planning advice and guidance notes, and a variety of other strategies, plans and case studies which are stored in different locations on the Scottish Government website and elsewhere, making them difficult to locate and causing their links to one another and to NPF4 difficult to decipher.
What we have learnt over the last three years since NPF4’s adoption is that confining such an ambitious policy framework in the format of a static document is not working to enable its practical usability and application. NPF4 has rightly been heralded as groundbreaking, winning the Planning Awards in 2023 and being commended in the Best Plan category of RTPI Scotland’s Planning Excellence Awards in 2025. However, its ability to be applied practically on the ground across Scotland has been, in our view, hampered by its static nature and the way that supplementary guidance and advice around its interpretation and implementation have been published at arm’s length from NPF4 itself.
In RTPI Scotland’s Planifesto we have called for the creation of a digital planning lighthouse as a focal point for digital planning innovation in Scotland. This would include an interactive NPF4 portal to house the framework, providing links to all the guidance that has been published since its adoption. This would realise a vision of NPF4 as a proactive tool which supports planners to navigate the path towards a sustainable, liveable and productive future.
Providing more advice, in addition to what we already have, will only prove useful if there is clear evidence of current advice gaps that are causing delays. Moreover, and as previously stated, whilst planning supports housebuilding in Scotland through the plan-making and consenting processes, housing delivery also relies on a range of factors that are external to planning. Consequently, whilst providing additional advice may help to support the planning consenting process, it is unlikely to have a direct impact on housing delivery rates.
4e: Do you think there are any further options that creating more categories in the development hierarchy might open up, further to those outlined in option 3?
Unsure.
No comment.
4f: Do you think that this measure would have any particular benefits for SME housebuilders?
Unsure.
As previously stated, whilst SME developers do play a critical role in delivering housing on smaller sites, it is inaccurate to assume that all small housing sites are delivered by SMEs, or that all SMEs only deal with smaller sites. Consequently, although this measure could have benefits for some SME housebuilders, not all SME housebuilders will benefit, and the measure could encourage others to adapt their usual business models to take advantage of a streamlined consenting process for smaller sites.
Question 5: Do you think that encouraging more diverse housing outputs across the pipeline of deliverable housing land would increase the pace of build-out?
Unsure.
It is already a requirement of NPF4 that homes be delivered in the right locations providing a choice across tenures that meet diverse housing needs. Encouraging the delivery of homes that meet this requirement should be plan-led using the tools we already have at our disposal – for example, through the LDP and the adoption of MCA schemes.
We agree with the consultation paper that the sharing of good practice and collaboration with industry and wider stakeholders will help to encourage diverse housing outputs in a manner that supports housebuilding in Scotland.
5a: Should we use legislation to require a diversity of housing types and tenures on sites above a certain threshold?
No.
Determining the type, size and tenure of new housing should be a place-based and plan-led exercise in collaboration with housebuilders and other housing delivery partners. We see little benefit in setting out additional legislative requirements that cannot take into account the unique spatial, economic and housing market contexts that will determine the optimal outcome for Scotland’s diverse places and communities. Such an approach runs the risk of disincentivising development, particularly for projects where viability margins are already tight. Such an approach is also at odds with Scotland’s plan-led and discretionary planning system.
5b: Do you think that this measure would have any particular benefits for SME housebuilders?
No comment.
5c: Please provide any evidence of how increasing diversity would influence build-out rates. Please explain your answer.
No comment
Question 6: Do you have any other suggestions for measures which could use levers available, or which could be put in place through the planning system, to deliver more homes at pace?
RTPI Scotland does not believe that the introduction of additional duties, legislation, rules-based frameworks or taxes and penalties will help to accelerate housebuilding in Scotland in practical terms. Such approaches are at odds with Scotland’s discretionary planning system. Scotland needs a fully resourced planning system that is able to proactively respond to shifting pressures through collaborative practices that use data and digital tools to their full potential. This would create the foundations for a robust and streamlined planning system that would, as a natural consequence, deliver efficient planning consenting outcomes.
To achieve this, first and foremost LPAs, key agencies and other public actors involved in supporting housing consent and delivery need to be supported with sufficient resources to carry out their duties. In relation to LPAs, this not only relates to development management teams but also to plan-making teams to ensure that LDPs, which are the policy foundation for housebuilding in Scotland, are in place, up to date, and provide sufficient land supply to deliver the homes, services and infrastructure communities in Scotland need to thrive.
RTPI Scotland is of the view that there is a need for LDPs to be prepared and implemented in an agile way. Up to now, LDPs have been static documents. However, with a new 10-year lifespan, it is unreasonable to expect a static document to respond to circumstances that were previously unforeseen during its initial preparation. Ensuring flexibility in the planning system is necessary to respond to changing housing market conditions and ensure that planning remains a tool to enable quality housebuilding across Scotland. A mechanism to replace sites which have been allocated in LDPs, but are not yet consented or built out, would be beneficial to ensure that housing land supply remains implementable over the 10-year lifespan of the LDP.
In addition to the above, existing tools that we already have at our disposal could be utilised to support housing delivery in Scotland. For example, MCAs could be used to identify housing sites, setting out the planning outcomes and application requirements that will deliver quality homes that have regard to the site and local area. We are aware that some local planning authorities are already seeking to utilise MCA schemes in innovative ways that support Scotland’s plan-led discretionary system, and this should be further encouraged and supported.
Finally, the Scottish planning system will not, by itself, influence housing buildout rates. Beyond planning consent, housing delivery relies on a range of other factors that are external to planning and which planning has little to no power of influence. To accelerate homebuilding in Scotland, a response is needed that looks at the whole picture and not just at a single (albeit important) piece. It is our view that a new housing delivery body would be well placed to take such a whole picture approach, working collaboratively with local planning authorities, key agencies, developers, housebuilders, and other key actors in the housing delivery sector.
6a: Please provide any evidence of how these potential measures would influence build-out rates.
As above.
