Draft London Plan: a new approach to student housing delivery?

PBSA no longer benefits from its own standalone policy, with current Policy H15 replaced by HN5 – Managing Specialist Accommodation – which brings PBSA together with large-scale purpose-built shared living and other forms of specialist housing. Despite this consolidation, the overall direction of the policy remains supportive of further PBSA delivery, with a much clearer expectation of where new bedspaces should be provided.

There is, however, a potential tension within this new approach. While borough-level targets provide greater clarity on where growth is expected, there is a risk that local authorities may begin to interpret these figures as maximums rather than minimum requirements and potentially use them as a basis for resisting further proposals once a target has been met.

From a London-wide requirement to borough targets

The current London Plan identifies a strategic requirement for 3,500 PBSA bedspaces per year, but it deliberately does not distribute this requirement between individual boroughs.

The new National Planning Policy Framework, published in August 2026, also places greater emphasis on planning positively for purpose-built student accommodation. It expressly identifies student accommodation as a form of housing that development plans should plan for and, where need is identified, requires suitable sites to be identified.

The Draft London Plan takes a more spatially targeted approach. Policy HN5 establishes a requirement for 31,549 PBSA bedspaces between 2027/28 and 2036/37, with specific targets now assigned to individual planning authorities.

The distribution varies considerably across London. For example:

• Barnet: 2,127 bedspaces
• Ealing: 2,003 bedspaces
• Southwark: 1,737 bedspaces
• Newham: 1,576 bedspaces
• Westminster, City of London and Richmond: no numerical target

Importantly, these targets are accompanied by a requirement for boroughs to seek to meet their PBSA need and allocate sites for a level of provision that will satisfy them. They should therefore be viewed as a basis for planning positively for PBSA delivery, rather than as a ceiling on the amount of student accommodation that individual boroughs can accommodate.

This interpretation is also consistent with the wider direction of national policy, which expects development plans to plan positively for identified needs as a minimum and, where appropriate, provide for growth above identified requirements.

For the market, this provides a much clearer indication of where the Mayor expects PBSA growth to be accommodated. Where suitable sites come forward beyond the identified target, the policy does not appear to provide a basis for resisting further PBSA simply because the numerical requirement has already been met.

The practical impact will, however, depend on how individual boroughs respond through their Local Plans, particularly in areas where existing policy has sought to manage concentrations of student accommodation.

A more flexible route for new schemes

There are also some potentially significant changes to the way individual PBSA proposals will be assessed.

Under the current London Plan, the majority of the beds (more than 50%), including all affordable student rooms, must be secured through a nomination agreement with one or more higher education providers. This requirement is not carried across into HN5.

Instead, the draft Plan expressly requires nomination agreements for affordable student accommodation only, potentially giving operators greater flexibility over the remaining accommodation.

The approach to location is also clearer. HN5 requires PBSA to be well connected to local services and, where relevant, higher education providers by walking, cycling and public transport. The supporting text defines a journey of up to 30 minutes by these modes as being well connected to a higher education provider.

At the same time, boroughs are encouraged to identify existing concentrations of PBSA and large-scale shared living where these may affect mixed and inclusive neighbourhoods. This may become increasingly important as boroughs seek to balance their new delivery targets against local concerns around concentration.

Affordable student accommodation

Affordable housing remains a central requirement, although the policy framework has been reorganised.

Current Policy H15 contains its own detailed affordable student accommodation provisions, including the 35% Fast Track threshold, nomination arrangements and detailed requirements around rents and accommodation.

HN5 is considerably shorter and instead requires PBSA to provide affordable housing in accordance with Policy HN3 Delivering Affordable Housing.

This consolidation will require careful consideration, particularly in understanding how the new framework affects viability, affordable PBSA thresholds and the existing exemption from conventional C3 affordable housing contributions.

What could this mean for PBSA delivery?

Taken together, and viewed alongside the new national policy framework, the changes point towards a more proactive approach to planning for student accommodation.

The Draft Plan moves away from a single London-wide requirement towards identifying where PBSA should actually be delivered, while also simplifying some of the detailed requirements that currently apply to individual schemes.

There are still important points that will need to be considered through the consultation process, particularly around affordable housing and how quickly borough-level targets translate into site allocations and Local Plan policy.

However, the combination of identified need, borough targets and an expectation to plan positively for PBSA should provide a clearer basis for bringing forward new schemes in suitable locations. Crucially, those borough-level figures should not be treated as caps, particularly where further suitable PBSA proposals can contribute to meeting wider student housing need.

For London’s higher education sector, and for a PBSA market facing continued pressure to increase supply, the implementation of these policies will ultimately be just as important as the targets themselves.

Further information

Contact Esam Yahouni and Scott Hudson