11th Report - Unlocking land for housing

The Department and Homes England have not been fully transparent about their plans for tracking the number of homes built on land unlocked by legacy programmes. The Department and Homes England are retrospectively tracking how many homes were built on … Read more The Department and Homes England have not been fully transparent about their plans for tracking the number of homes built on land unlocked by legacy programmes. The Department and Homes England are retrospectively tracking how many homes were built on land unlocked by the various legacy programmes that they initially did not track. The Department reports that as at the end of December 2025, 57,671 homes had been delivered by legacy programmes, 24,400 of which were identified through retrospective analysis. The Department is continuing this process and expects to understand the total number of homes built on land unlocked by all its legacy programmes by May 2027. The Department explained it is using geospatial analysis of site boundaries to do this, but it can be hard to assess which homes to attribute to unlocking land investments in certain cases, such as where the funding has provided infrastructure like road junctions. There is a lack of transparency about the Department’s approach to tracking the number of homes built on land unlocked in these more complicated cases. It is essential for the Department to understand the outcomes of its investments in order to make good quality assessments of performance and judgements on value for money which can lead to improvements in the design of future programmes. recommendation a. As part of its Treasury Minute response the Department should set out its methodology for tracking the number of homes built on land unlocked by legacy programmes, and how it plans to evaluate the success of this methodology b. Within the next twelve months the Department should report to the committee with the final number of homes completed on the remaining legacy funds. Show less

It will be important that the Department and Homes England have clear plans to adapt how the NHDF operates to the changes in local government structures. The shift from two-tier councils to unitary authorities, alongside the creation of Mayoral Strategic … Read more It will be important that the Department and Homes England have clear plans to adapt how the NHDF operates to the changes in local government structures. The shift from two-tier councils to unitary authorities, alongside the creation of Mayoral Strategic Authorities with devolved powers and funding from central government, is ongoing. 4 For the NHDF, the Department has devolved £1.3 billion of grant funding to the Established Mayoral Strategic Authorities through integrated settlements to support projects to unlock land for housing. Homes England has a new target operating model, which sets out how it is organised and delivers work, so it can provide more support locally. Its aim is to strengthen collaboration with mayors, local leaders and partners and ensure solutions for housing and regeneration are tailored to, and reflect, local priorities. As local government structures continue to change, it is important that MHCLG and Homes England ensure funding doesn’t get disrupted, accountability remains clear and that areas remain focused on delivery. recommendation By the end of the year, the Department and Homes England should write jointly to the committee setting out their expectation on how their approach to unlocking land will be impacted by changes in local government structures, and what plans they have to mitigate any such impact, and how Homes England’s new target operating model will adapt to the new landscape of unitary authorities. Show less

We remain unconvinced that the Department and Homes England have a strategic approach to allocating the NHDF to ensure a balanced portfolio of projects in a range of locations which support the objectives of the NHDF. The Department launched the … Read more We remain unconvinced that the Department and Homes England have a strategic approach to allocating the NHDF to ensure a balanced portfolio of projects in a range of locations which support the objectives of the NHDF. The Department launched the NHDF without a pipeline of projects suggesting its approach to creating a portfolio of projects is reactive and demand led rather than strategically planned. This means there is a risk that the final portfolio does not contain a strategic balance of projects which support the objectives of the NHDF and maximise the impact of funding and value for money. In addition, we are not convinced a demand-led approach will lead to a balanced portfolio of projects across a range of locations. The Department has 10 Strategic Place Partnerships linked to Mayoral Strategic Authorities which will provide strategic direction in those places. The Department is aiming to work in partnership with local areas to align housing delivery with place-based growth strategies. The Department says the NHDF was deliberately designed to be flexible, and it considers a range of criteria when assessing projects and determining the best investment type, such as grants, loans or equity, but we are not satisfied that the Department has explained this process to us sufficiently well. recommendation As part of its Treasury Minute response, the Department and Homes England should clearly articulate how the NHDF will: 5 a. select and balance projects to maximise impact in a range of locations, in particular, those with Strategic Place Partnerships. b. decide which type of investment to make in projects to achieve the greatest impact and value for money. Show less

The Department failed to put in place external evaluation at the launch of the NHDF, risking gaps in early data collection and limiting opportunities for timely improvements. Despite launching the NHDF in March 2026 the Department has given itself another … Read more The Department failed to put in place external evaluation at the launch of the NHDF, risking gaps in early data collection and limiting opportunities for timely improvements. Despite launching the NHDF in March 2026 the Department has given itself another twelve months to finish its scoping and feasibility work for external evaluation. It is important the Department concludes this work at the earliest opportunity so it knows which data is needed to conduct quality evaluations and can put in plans to collect it. Early learning based on robust analysis of performance increases understanding of what works to unlock land and enables timely improvements to the NHDF, increasing its effectiveness over the long term. The Department is planning to run internal evaluations alongside its external evaluation and plans to have clear review points with HM Treasury and the National Infrastructure Service Transformation Authority (NISTA) to ensure lessons can be learned and applied. It is important the Department continues work to get its evaluation in place without delay. recommendation a. As part of its Treasury Minute response, the Department should update the committee on progress letting contracts for the evaluation of the NHDF. b. The Department should write to the Committee setting out in detail how its evaluation of the NHDF will work once it has finalised its plans. 6 1 Measuring the success of unlocking land funding Introduction Show less

On the basis of a report by the Comptroller and Auditor General, we took evidence from the Ministry of Housing Communities and Local Government (the Department) and Homes England on Unlocking land for Housing.1

As stated above the Department launched the £21 billion NHDF in March 2026.11 The remit of the NHDF will include activity beyond unlocking land programmes, including support for social housing providers and small housebuilders.12 7 C&AG’s Report, para 7 8 … Read more As stated above the Department launched the £21 billion NHDF in March 2026.11 The remit of the NHDF will include activity beyond unlocking land programmes, including support for social housing providers and small housebuilders.12 7 C&AG’s Report, para 7 8 C&AG’s Report, paras 2 and 3 9 C&AG’s Report, para 2 10 Committee of Public Accounts, Unlocking land for housing written evidence 11 Q 1 12 C&AG’s Report para 7 8 Show less

The Department told us it is finalising the business case for the NHDF now.13 We asked it how much of the NHDF will be available for unlocking land investments. It told us that it has deliberately set the NHDF to … Read more The Department told us it is finalising the business case for the NHDF now.13 We asked it how much of the NHDF will be available for unlocking land investments. It told us that it has deliberately set the NHDF to be flexible so it can support a range of interventions that will lead to new homes. As such it has not specified a sum of money that it expects to be used on unlocking land projects.14 Show less

We questioned the Department on what it wants the NHDF to deliver, including how many homes will be built on land unlocked by the fund. The Department told us that it has a broad range of objectives for the NHDF … Read more We questioned the Department on what it wants the NHDF to deliver, including how many homes will be built on land unlocked by the fund. The Department told us that it has a broad range of objectives for the NHDF including increasing the housing supply, boosting economic growth, improving the quality of new homes and contributing to placemaking.15 We pressed the Department further on how it will know whether it is maximising the impact of the £21 billion funding without clear delivery targets.16 The Department told us that the aim was to deliver as many homes as possible in the right places rather than to set a specific numerical target whilst at the same time meeting the wider objectives.17 It emphasised that setting a single figure could create the wrong incentives, prioritising volume over quality or longer-term outcomes.18 Show less

We challenged the Department on when it would be able to set out its expectation of how many homes will be built on land unlocked by the NHDF. The Department told us that it is too early to provide a … Read more We challenged the Department on when it would be able to set out its expectation of how many homes will be built on land unlocked by the NHDF. The Department told us that it is too early to provide a meaningful estimate because the NHDF does not yet have a pipeline of projects.19 The Department said a specific number of homes would be available when a portfolio of projects is agreed but emphasised that its expectations may change over time.20 Tracking homes built on legacy unlocking land programmes Show less

Delivery of new homes is one of the key long-term outcomes the Department expects from its financial support for unlocking land.21 However, it did not put in place arrangements to track the number of homes built on land unlocked by … Read more Delivery of new homes is one of the key long-term outcomes the Department expects from its financial support for unlocking land.21 However, it did not put in place arrangements to track the number of homes built on land unlocked by some of its legacy programmes.22 The legacy 13 Q59 14 Q10 15 Qq 23 and 30 16 Qq 13 and 19 17 Qq 13 and 23 18 Q 13 19 Q 63 20 Q 63 21 C&AG’s Report Para 11 22 C&AG’s Report Para 11 9 unlocking land programmes are the seven that predate the NHDF.23 The Department reported that as at the end of December 2025 housing developers had delivered 57,671 homes on land unlocked by its legacy programmes, 24,400 of which were identified through retrospective analysis, out of an expected capacity of 713,000.24 Show less

We asked the Department whether it has a clear understanding of the homes delivered resulting from its legacy investments to unlock land. The Department acknowledged the initial lack of tracking and told us it is now retrospectively tracking how many … Read more We asked the Department whether it has a clear understanding of the homes delivered resulting from its legacy investments to unlock land. The Department acknowledged the initial lack of tracking and told us it is now retrospectively tracking how many homes have been built on land unlocked by initially untracked legacy programmes.25 Homes England explained that it has completed retrospective tracking for 90% of land projects and 30% of infrastructure projects and expects to take 12 months to complete this analysis.26 Show less

We asked how the number of homes delivered through legacy programmes were being tracked. Homes England told us it is using geospatial imaging to set boundaries around sites, and identify which homes can be attributed to unlocking interventions.27 The Department … Read more We asked how the number of homes delivered through legacy programmes were being tracked. Homes England told us it is using geospatial imaging to set boundaries around sites, and identify which homes can be attributed to unlocking interventions.27 The Department explained that attributing homes to financial investments is more challenging for some projects.28 It gave the example of improvements to junction 10 of the M5, where it is not straightforward to define a boundary and attribute all new homes within it to the intervention, noting that a degree of judgement is required.29 Show less

We challenged Homes England on how it ensures transparency and consistency in its method. It confirmed its method is evaluated and checked internally and suggested the NAO could review it as well.30 We expect the Department and Homes England to … Read more We challenged Homes England on how it ensures transparency and consistency in its method. It confirmed its method is evaluated and checked internally and suggested the NAO could review it as well.30 We expect the Department and Homes England to include timely and robust review of the methodology for tracking the number of homes built on land unlocked by legacy programmes, including making use of external expertise, to ensure robust challenge and improve decision-making. Homes England noted in most cases it is quite clear which homes to attribute to its investment such as Beaulieu Station in Essex where 23 C&AG’s Report Figure 3. The legacy programmes covered by the NAO report were: Housing Infrastructure Fund; Home Building Fund – Long Term Fund; Land Release Fund; Land Assembly Fund; Brownfield Land Release Fund; Brownfield, Infrastructure and Land Fund; Home Building Fund – Infrastructure Loans. 24 Letter from MHCLG, 19 May 2026; C&AG’s Report Para 11 25 Q 2 26 Q 3 27 Q 3; Geospatial imaging is using map-based images of the Earth to see, measure, and verify what’s happening in a specific place. 28 Qq 51 and 54 29 Qq 3 and 51 30 Qq 4 and 54-55 10 the local authority said no homes could be built without the infrastructure.31 It told us the alternative to using geospatial imaging was to make reporting of homes contractual but explained it did not want to put the extra burden on developers.32 31 Q 54 32 Q 4 11 2 Delivering the National Housing Delivery Fund (NHDF) Planning for local government reorganisation Show less

The scope of regional devolution has increased since the early years of the the Department’s unlocking land programmes, with Established Mayoral Strategic Authorities due to receive funding from the NHDF through their integrated settlements.33 In addition, local government is undergoing … Read more The scope of regional devolution has increased since the early years of the the Department’s unlocking land programmes, with Established Mayoral Strategic Authorities due to receive funding from the NHDF through their integrated settlements.33 In addition, local government is undergoing reorganisation to create unitary authorities where there are currently district and county local authorities.34 Show less

We questioned Homes England on how it is adapting its delivery approach to the changes in local government structures. It acknowledged that local government reorganisation is absorbing a large amount of energy and attention.35 In response, Homes England told us … Read more We questioned Homes England on how it is adapting its delivery approach to the changes in local government structures. It acknowledged that local government reorganisation is absorbing a large amount of energy and attention.35 In response, Homes England told us it has introduced a new target operating model to allow it to work directly with local authorities. It told us it wanted to be a genuine delivery partner and gave us an example of where its teams were working directly with local authority staff in Leeds and Sheffield.36 Show less

We asked how accountability and delivery would be maintained where funding has been devolved to the Established Mayoral Strategic Authorities. The Department told us that it had devolved about £1.5 billion of funding from the NHDF to the Established Strategic … Read more We asked how accountability and delivery would be maintained where funding has been devolved to the Established Mayoral Strategic Authorities. The Department told us that it had devolved about £1.5 billion of funding from the NHDF to the Established Strategic Mayoral Authorities as they have demonstratable capacity to deliver.37 However in subsequent correspondence it said it had devolved £1.3 billion.38 The Department said it had agreed and published bespoke measures against which it will measure 33 C&AG’s report, para 3.16 34 MHCLG , English Devolution White Paper, CP1218, 16 December 2024 35 Q 29 36 Q 29 37 Qq 9 and 29 38 Letter from the MHCLG, 1 June 2026 12 delivery by the Established Strategic Mayoral Authorities, and that these measures would be monitored through governance arrangements such as a quarterly National Housing Delivery Fund Board.39 Show less

We also explored how areas without established mayoral structures would be supported. Homes England told us that it would assess their capacity and readiness to deliver and could provide both funding and advisory support, including helping local authorities develop pipelines … Read more We also explored how areas without established mayoral structures would be supported. Homes England told us that it would assess their capacity and readiness to deliver and could provide both funding and advisory support, including helping local authorities develop pipelines and masterplans.40 Homes England acknowledged that some authorities do not have the capacity to, for example, develop master plans and that Homes England could provide support in these cases.41 Achieving the objectives of the National Housing Delivery Fund Show less

The Department has taken various approaches, driven by shifting policy priorities, to where it invests unlocking land funds. However, frequent change reduces confidence in the sector and risks wasting applicants’ efforts in developing plans that are unlikely to be supported.42 … Read more The Department has taken various approaches, driven by shifting policy priorities, to where it invests unlocking land funds. However, frequent change reduces confidence in the sector and risks wasting applicants’ efforts in developing plans that are unlikely to be supported.42 To support the delivery of the NHDF and National Housing Bank, Homes England is developing an overarching agency-wide investment strategy. The first part of this strategy was the publication of the Homes England Investment Roadmap in December 2025 which set out the scope of the NHDF, the Bank and the agency-wide investment principles and investment themes that will guide the future activity of Homes England.43 Show less

We questioned the Department on how it is selecting and prioritising projects for the NHDF. The Department explained that funding decisions for individual projects are based on a range of criteria including deliverability, affordability, and strategic fit with government policy … Read more We questioned the Department on how it is selecting and prioritising projects for the NHDF. The Department explained that funding decisions for individual projects are based on a range of criteria including deliverability, affordability, and strategic fit with government policy and the local area’s priorities.44 It added that it is oversubscribed with projects coming forward and so it must be “hard-nosed” about whether the costs are realistic.45 The Department told us that for loans it will look at ability to repay and risk ratios.46 It acknowledged that the process is complex and it tries to look at all aspects of the criteria and then make a decision.47 39 Q 44 40 Q 43 41 Q 43 42 C&AG’s report, para 4.10 43 C&AG’s report, para 4.12 44 Qq 26 and 28 45 Qq 28 and 40 46 Q 28 47 Q 28 13 Show less

We asked the Department how it is prioritising locations for funding. It told us its Ministers want to see a balanced portfolio across the country. It explained that it works with 10 Strategic Place Partnerships (SPPs) which are linked to … Read more We asked the Department how it is prioritising locations for funding. It told us its Ministers want to see a balanced portfolio across the country. It explained that it works with 10 Strategic Place Partnerships (SPPs) which are linked to Mayoral Strategic Authorities to help bring projects forward that the area needs most.48 It uses agreed measures with the Established Mayoral Strategic Authority to ensure it delivers in line with the NHDF’s priorities.49 We asked about places not part of a SSP and the Department told us it looks at relevance and readiness to deliver.50 It emphasised that when deciding whether to invest in an area it considers housing affordability and densification as criteria.51 Show less

We pressed the Department on how it expects to ensure an overall balanced and effective portfolio of projects which maximises the impact of the funding. It acknowledged that the final distribution of funding will depend on what projects come forward.52 … Read more We pressed the Department on how it expects to ensure an overall balanced and effective portfolio of projects which maximises the impact of the funding. It acknowledged that the final distribution of funding will depend on what projects come forward.52 It added that the NHDF has been designed to be flexible, and it does not want to constrain itself by being overly scientific when some of this is about judgment, previous examples and where it would want to prioritise funding.53 Evaluating the National Housing Delivery Fund Show less

Evaluations of the legacy unlocking land programmes helped shape the design of the NHDF.54 However, the NHDF will launch before the outcomes of these programmes have been fully evaluated. The Department will need to put in place evaluation that provides … Read more Evaluations of the legacy unlocking land programmes helped shape the design of the NHDF.54 However, the NHDF will launch before the outcomes of these programmes have been fully evaluated. The Department will need to put in place evaluation that provides timely evidence from the early implementation of the NHDF to inform its understanding of the likely outcome of its interventions.55 Show less

We asked the Department what evaluation arrangements were in place for the NHDF and when these would be available. The Department told us that it is finalising the business case for the NHDF now and that further work is still … Read more We asked the Department what evaluation arrangements were in place for the NHDF and when these would be available. The Department told us that it is finalising the business case for the NHDF now and that further work is still required before the evaluation is fully established.56 But it aims to procure 48 Qq 26 and 42 49 Q 44 50 Q 43 51 Qq 24-25, 27 and 40 52 Q 40 53 Q 28 54 C&AG’s report para 15 55 C&AG’s report, para 15 56 Q 59 14 the evaluation by the end of the year.57 In subsequent correspondence the Department told us it is designing the external evaluation and will have completed its scoping and feasibility work within the next 12 months.58 Show less

We also asked how the Department intends to ensure that lessons are learned and applied early in the life of the NHDF. The Department told us that it is designing its evaluation with clear review points so that it can … Read more We also asked how the Department intends to ensure that lessons are learned and applied early in the life of the NHDF. The Department told us that it is designing its evaluation with clear review points so that it can learn lessons continuously and amend its approach to delivering the NHDF.59 In its letter following the session the Department told us that these review points will include working with and reporting to HM Treasury and the National Infrastructure and Service Transformation Authority (NISTA).60 57 Q 60 58 Letter from the MHCLG, 1 June 2026 59 Q 60 60 Letter from the MHCLG, 1 June 2026 15 Show less