01 – Planning Market Integrity Portfolio (PMI) 🏗️

🎯 Objective


To restore fairness, accountability, and functional land use in the UK planning system by ensuring land is developed responsibly, transparently, and in alignment with public need — not held speculatively or manipulated for private timing advantages.

⏱️ Policy P1 – Time-Bound Delivery Enforcement (with Financial Consequences)


What it does:
Mandates developers to begin and complete construction within defined timeframes post-permission. Non-compliance triggers:

  • Financial penalties
  • Potential revocation of permission

Why it’s needed:
To end speculative land banking and ensure planning approvals translate into housing supply.

International Analogy:
In Germany, planning approvals often expire if unused — forcing delivery or release.

🌍 Policy P2 – Progressive Land Tax or “Use-It-Or-Lose-It” Measures


What it does:
Applies escalating annual taxes to undeveloped land with planning permission.

Why it’s needed:
To disincentivise land hoarding and unlock land supply.

International Analogy:
France imposes a rising tax on idle, zoned land to push development forward.

📉 Policy P3 – Deliverability Penalty Points for Developers


What it does:
Implements a national points system where developers accumulate reputation penalties for:

  • Delivery failure
  • Repeated renegotiations
  • Speculative withholding

Points affect access to future planning approvals and land release opportunities.

Why it’s needed:
To reward track records — not merely capacity — and deprioritise habitual manipulators.

International Analogy:
New South Wales (Australia) uses a performance-based weighting system for future bids.

🧾 Policy P4 – Mandatory Transparency: Land Ownership and Control Monitoring


What it does:
Requires developers to disclose:

  • Full beneficial land ownership
  • Offshore structures and related parties
  • Changes in control post-permission

Why it’s needed:
To expose land speculation via shells and trusts, and stop ownership opacity being used to evade delivery duties.

International Analogy:
The UK’s Register of Overseas Entities (ROE) addresses similar opacity in real estate.

🏘️ Policy P5 – Front-Loading Affordable Housing & Infrastructure


What it does:
Mandates that a significant share of affordable housing and essential infrastructure be delivered in the first phases of large developments.

Why it’s needed:
To prevent deferral tactics and ensure communities see real benefit early.

International Analogy:
The Netherlands requires upfront provision of infrastructure and social housing in masterplan agreements.

🧮 Policy P6 – Raised Affordable Housing Requirement on Speculative or Tilted-Balance Sites


What it does:
Increases affordable housing quotas where applications are:

  • Approved under reduced policy standards (e.g. due to 5YHLS shortfall)
  • Made outside plan allocations or on appeal

Why it’s needed:
To ensure speculative gain is matched by elevated social return.

International Analogy:
Many U.S. cities use inclusionary zoning escalators in high-opportunity or speculative locations.

🏚️ Policy P7 – “Stay or Pay”: Primary Occupation Requirement for New Residential Properties


What it does:
Requires new homes to be occupied as primary residences within 12 months of legal completion. Failure to do so triggers a progressive annual vacancy tax. Applies to individuals and legal entities (e.g. developers, trusts, holding companies).


🔐 Anti-Circumvention Clauses:

  • Rolling Occupancy Clock: Clock continues through ownership transfers — resale or shell transfers do not reset it.
  • Portfolio Holding Limits: Entities may not retain >2 unoccupied units/phase beyond 12 months without triggering tax.
  • Strict Exemptions: Only registered social landlords, Homes England-accredited affordable schemes, or key worker leasing models are exempt.

📊 Reporting Obligation: Vacancy-to-Delivery Ratio (VDR)

Developers must publish quarterly:

Vacancy-to-Delivery Ratio (VDR):

VDR = Units unoccupied > 6 months Total completed units that year

VDR is used to:

  • Influence S106 negotiations
  • Inform developer penalty scoring (P3)
  • Guide permission eligibility

💸 Vacancy Tax Schedule:

Vacancy DurationAnnual Tax (% of property value)
Year 1 (grace)0%
Year 22%
Year 34%
Year 4+5%
  • Assessed on Land Registry sale price or banded council valuation (whichever is higher)
  • Indexed annually to inflation or price indices

🧾 Enforcement & Public Transparency:


  • LPAs must maintain a “Homes In Use” register
  • Tax revenue ring-fenced for affordable housing and local infrastructure
  • Randomised audits and occupancy declarations annually

⚖️ Strict Auditable Exemptions:


  • Probate/delay due to owner death
  • Hospitalisation or institutional care
  • Active key worker tenancy
  • Armed service deployment

International Analogies:


  • Vancouver’s Empty Homes Tax: 3% vacancy tax → >$115M raised for housing funds
  • Singapore’s ABSD: Up to 30% surcharge on unoccupied second properties
  • Banking Analogy: Similar to capital charges on idle or underperforming assets

📘 Summary


The Planning Market Integrity Portfolio (PMI) dismantles the speculative logic embedded in the UK’s planning system. It ensures land is not only approved for use, but used for homes — with delivery, transparency, and occupancy enforced. PMI transforms speculative permissions into enforceable promises, and realigns private strategy with public need.