Following rigorous analysis of local authority published housing land audits (which forecast supply), the research has found that housing completions could fall to as low as 5,000 per annum by 2031 as a direct result of failing planning policy. This compares with the 19,797 homes completed in 2024, the latest calendar year for which statistics are available.

Furthermore, this figure does not include the impact of wider regulation which continues to make it increasingly difficult and more expensive to build the range of homes required to ensure the country’s social wellbeing and economic success.

The report highlights that there simply isn’t enough land coming through the planning system to maintain a delivery pipeline that comes anywhere close to meeting Scotland’s housing needs – a situation HFS attributes to the introduction of National Planning Framework 4 in 2023 which has seen 60 per cent of Local Development Plans (LDPs), which guide where new development should take place, become out of date.

On average, new LDPs aren’t due for publication until 2029. As delays persist, the more deliverable of previously allocated sites have been, or are currently, being built out. At the same time, sites which may be constrained/unviable for a range of reasons, (such as contamination or access issues) remain in the system and are unable to be removed in favour of new ones that can deliver much-needed homes.

Given the fact that it takes around four years from submitting a planning application until delivery, this means that the number of new homes being built will continue on a downward trajectory and that it could be 2033 before new homes start coming through again.

HFS director of planning Kevin Murphy said: “Let’s be clear, the housing emergency has been decades in the making. Whilst we have welcomed the principle of the recently announced More Homes Scotland agency, this won’t be fully operational until 2028/29. We just don’t have that time to lose.

“Frustratingly, this new report only confirms the specific concerns we have been expressing to Ministers and officials since before NPF4 was introduced. However, rather than the Scottish Government addressing these and taking the necessary corrective action, we find ourselves with yet another consultation which describes ‘a living pipeline of land’ with planning permission being ‘in place for at least 164,000 homes’ which have not yet been built.

“As our research shows, this simply isn’t the case. Such narrative belies the wide-ranging, lengthy, complex and costly challenges that the home building sector has to face in delivering much-needed homes of all tenures.”

In response to the claim that planning permission is in place for at least 164,000 homes which have not yet been built, Homes for Scotland research has found:

• Just over half (c86,000) are in the control of home builders and have detailed planning consent, with over three quarters of these sites, ranging from four homes to over 3,000, already under construction.
• Over a quarter (43,000) are controlled by non-home builders which could include local authorities and public agencies.
• With the Scottish Government having stated its ambition to build 25,000 homes per annum, this means that there is less than three years of consented supply, well below what is required for businesses to confidently plan their investment and work programmes.

Kevin Murphy added: “The truth is planning policy, particularly transition from NPF4 to LDPs, is exacerbating rather than addressing the fundamental problem which lies at the heart of the matter: the chronic undersupply of effective land on which to build homes.

“In the context of only 1.4 per cent of Scotland’s land being in residential use, it is a shocking and untenable state of affairs that more than one in four Scottish households have been identified as being in some form of housing need.”

In terms of action and in order to provide investment confidence and certainty, HFS has put forward a suite of suggestions, including the immediate reinstatement of the presumption in favour of sustainable development (or the introduction of a similar mechanism) to allow new deliverable sites to be built out earlier and aid the transition between the publication of NPF4 and new LDPs. Masterplan Consent Areas, which are being rolled out in Highland, also have the potential to be part of the solution.

Murphy concluded: “We continue to stand ready to work with the Scottish Government to implement effective, data-driven solutions and have demonstrated our commitment to this through the identification of specific barriers and the action required to overcome them.

“I sincerely hope ministers and officials ensure positive rhetoric translates into effective action before we see any more investment diverted elsewhere in the UK and lose any more of our SME home building base which is now at its lowest level in 20 years.”