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The old strategy was simple and it worked for a decade: register the whole site early under the current standards, then build it out at whatever pace the market allowed. Anything you had registered was protected.
That strategy is dead, and a good number of land banks are still being managed as though it were not.
The dates
The Future Homes and Building Standards were published on 24 March 2026 — Approved Document L Volumes 1 and 2 and Approved Document F Volume 1, issued with Building Circular 01/2026.
They come into force on 24 March 2027, except for certain regulations that apply from 24 September 2027 for higher-risk building work and work to existing higher-risk buildings.
The transitional test, and the part that catches people
To stay on the current standards you need both:
- A building notice, initial notice or full plans application submitted before 24 March 2027; and
- Work commenced before 24 March 2028.
Here is where the old strategy dies. Commencement is defined per building, not site-wide, and it means:
All foundations for that building, any basement level, and the ground-floor structure complete.
Not started. Complete. Starting foundations is not enough. Site clearance, earthworks, hoarding, utility diversions and partial foundations do not count.
So a site with an initial notice covering 120 plots does not get 120 plots’ worth of protection. It gets protection for however many individual buildings reach completed ground-floor structure before 24 March 2028, and every other plot on that site meets the Future Homes Standard.
24 March 2028 is a hard backstop. After that date every home complies regardless of when it was registered.
And the older transitionals are revoked
The 2013 and 2021 transitional provisions have been revoked. Plots relying on those to build to older standards must now meet the Future Homes Standard. There are limited exceptions for the higher-risk building provisions and for work registered before 15 June 2022 that started before 15 June 2023.
If any part of your land bank has been sitting on a 2013 or 2021 transitional — and some long-running sites have — that relief is gone. That is worth checking this week rather than discovering it during a technical review.
What is actually required
For dwellings:
- Heat pumps for space and water heating, effectively ending fossil fuel heating in new homes
- A new functional requirement for minimum on-site renewable generation — in practice rooftop photovoltaics
- The notional dwelling based on “Option 1”: PV plus mechanical ventilation with heat recovery
- Three metrics retained from Part L 2021 — Primary Energy Rate, Carbon Emissions and Fabric Energy Efficiency — with tighter targets
For non-domestic buildings, under the Future Buildings Standard: “zero carbon ready” new buildings, strengthened fabric, low-carbon heat and heat networks, more on-site renewables, and much less flexibility to trade fabric against services.
Compliance methodology: SAP 10.3 only, initially. The Home Energy Model becomes an alternative pathway later — expected at least three months after publication. SBEM updates for non-domestic are still pending.
The plot-by-plot exercise, which is the actual work
This is not a policy question. It is a programming and appraisal exercise, and it needs doing building by building.
Step one: list every plot with a registration date and a realistic slab date. Not a phase. Not a parcel. Every building.
Step two: mark which plots can credibly reach completed ground-floor structure before 24 March 2028. Be honest. Eighteen months sounds generous until you account for a live land assembly, an unresolved section 278, a utilities diversion, funding not yet drawn, or a groundworks package you have not procured.
Step three: for every plot that cannot, re-appraise on the Future Homes specification. Heat pump, PV and MVHR carry a capital cost per plot and, on some layouts, a spatial cost too. That number needs to be in the appraisal before it is in the build cost.
Step four: check the layout still works. External heat pump units need space, acoustic separation from habitable rooms and neighbours, and access for maintenance. PV needs orientation and roof area. A layout optimised for a gas boiler and a plain roof is not automatically a Future Homes layout, and discovering that at technical design on plot 40 of 60 is expensive.
Step five: decide deliberately. On a site where only part of the plots can be protected, running two specifications in parallel has its own cost — two kits of parts, two sets of details, two supply chains, two sets of site instructions. On some sites the right answer is to build everything to the new standard and take the certainty.
Two adjacent things
Part O has not moved with it. A full review of the overheating requirements was confirmed in April 2026 — addressing false failures from the simplified method, and conflicts between Part O’s night-ventilation expectations and Parts B, F, K, L and Q. But no publication date has been committed, so Approved Document O 2021 remains binding. The practical implication is to stop relying on marginal simplified-method passes, particularly where the pass depends on opening windows on a noisy or insecure elevation, and to prioritise fixed passive measures — orientation, glazing ratio, external shading, thermal mass — that survive a methodology change. Note also that CIBSE TM59 was updated in 2026 while Approved Document O still references the 2017 edition.
EPC reform has slipped to the second half of 2027 — the move to four headline metrics on a Home Energy Model basis, delayed from October 2026. Meanwhile the requirement for rented domestic property to reach EPC C by October 2030 is unchanged. New methodology in late 2027, compliance required in 2030, and a property rated C under SAP may score differently under the new model.
The one-line version
Model your land bank plot by plot against 24 March 2028, assume “commenced” means slab complete, check whether anything is relying on a revoked 2013 or 2021 transitional, and re-appraise everything that cannot make it.
If you have a land bank where nobody has run that exercise building by building, it is a contained piece of work and it is considerably cheaper than finding out in 2028.