Scotland has been in a declared housing emergency since May 2024, yet the delivery of new homes continues to fall. While government attention has focused on homelessness and affordability, the underlying problem is more fundamental: not enough new homes are being built, and current planning policy is making that harder, not easier.

Scotland’s population is ageing, households are getting smaller and demand for housing is rising accordingly. Meeting those needs requires a steady pipeline of new, all-tenure housing. Instead, completions and starts have both declined since 2023, despite recovery from the pandemic.

The Scottish Government’s Housing Emergency Action Plan states that planning must do all it can to overcome delivery challenges. In practice, current policy is limiting delivery. National Planning Framework 4 (NPF4) was adopted in February 2023 and now sits alongside Local Development Plans (LDPs) as the statutory development plans across Scotland. Its adoption triggered the replacement of all 34 LDPs by May 2028.

At the point NPF4 came into force, 15 local authorities already had out-of-date LDPs. By the end of 2025, that figure had risen to 22. Although councils have been operating under the new system since 2023, progress has been slow. As of January 2026, only eight authorities had completed the evidence gate check required to move their new plans forward. Thirteen have indicated they will miss the May 2028 deadline, while one has provided no timetable at all.

This matters because NPF4 offers only very limited support for housing on sites that are not allocated in an adopted LDP. With most LDPs now out of date, the stock of viable allocated housing land has shrunk sharply. The result is a planning system that restricts new supply at the very point when delivery needs to accelerate.

The impact is already visible in the data. Since NPF4 was adopted, housing starts and completions have dropped back to levels last seen after the 2008 financial crisis. Planning permissions are following the same trend. In 2019, 175 applications for housing sites of 50 homes or more were determined. The ten-year average prior to NPF4 was around 140 a year. In 2023/24, that figure fell to just 77. Although there was a modest recovery to 101 in 2024/25, this still represents a 25 per cent drop on the long-term average.

With fewer permissions being granted, there is little prospect of a near-term recovery in housing starts. This is not a cyclical slowdown driven by market conditions alone - planning policy is now a material constraint on supply.

The Housing Emergency Action Plan does not address this problem. While it requires notification to the Scottish Government for applications of more than 10 homes on unallocated sites, it offers no policy flexibility to support those proposals. Given the cost and risk involved, most housebuilders are simply not bringing forward unallocated sites under the current policy framework.

If the housing emergency is to be taken seriously, interim planning measures are needed. These should apply until new, up-to-date LDPs are in place and should recognise the housing emergency as a material consideration in decision-making. That would allow otherwise acceptable unallocated sites to come forward and help rebuild the pipeline of deliverable housing.

Without changes to planning policy, Scotland will continue to talk about housing delivery while constraining it in practice.