Architects across London are expressing significant concerns about proposed changes to the city's housing design standards, arguing that the modifications will fail to address the underlying causes of record-low home construction levels. The changes, announced last month by the Ministry of Housing, Communities and Local Government (MHCLG) and London Mayor Sadiq Khan, are intended to accelerate house-building but have drawn criticism from industry professionals who view them as inadequate solutions to a complex crisis.
The proposed modifications include several major policy shifts aimed at reducing regulatory barriers to development. Key changes involve removing the blanket presumption favoring dual-aspect homes, which typically provide natural light and ventilation from two sides. Additionally, London's affordability target would be dramatically reduced from 35 percent to 25 percent, alongside new guidance on core dwellings and bicycle storage requirements. These design standard changes are still awaiting public consultation, but the announcement comes as London faces a severe housing shortage, with one-third of councils failing to begin construction on any new homes during the first quarter of this year.
Jas Bhalla, principal at Jas Bhalla Works, told the Architects' Journal that while individual policies may be well-intentioned, insufficient consideration appears to have been given to the combined effects of various regulations. He pointed to increasing regulatory complexity in recent years, including changes to Building Regulations Parts B, L, O, and S. "Like many others, I suspect the announcement of these emergency measures won't provide the jump start the housing industry desperately needs," Bhalla stated. "In this context, focusing too heavily on the temporary removal of certain standards feels like a red herring."
Bhalla emphasized the need for more comprehensive reform, arguing that "the challenge now should be to move beyond reactive policymaking and work collectively toward a regulatory and delivery framework that empowers architects to create lasting, inclusive, and genuinely livable homes for all Londoners." His criticism reflects broader concerns within the architectural community about the government's approach to addressing the housing crisis through piecemeal regulatory adjustments.
Fiona Scott, director at Gort Scott, echoed these concerns while highlighting more fundamental issues with current housing policy. She argued that the proposed changes fail to address "the more complex overarching issues that we should build less and refurbish more." Scott emphasized that "housing must be understood as social infrastructure, cutting across everything from public health to the economy – not real estate." While she welcomed the focus on affordable home delivery, noting that "almost none are currently being delivered," she called for crisis-level support for low-carbon construction and refurbishment initiatives.
Doug Hodgson, founding principal of New Works, provided particularly sharp criticism of the proposed changes, arguing they distract from the real housing crisis. "The proposed changes to London's housing design standards risk distracting from the real crisis: the shortage of genuinely affordable and high-quality social rent homes," he told the Architects' Journal. Hodgson noted that core design, daylight, and ventilation standards are already regulated and that design justification remains required under the new proposals.
Hodgson highlighted the scale of London's affordable housing crisis, pointing out that over 65,000 families currently live in temporary accommodation across London boroughs. He calculated that even if 60 percent of the 20 percent fast-tracked affordable homes were designated as social rent, this would contribute only around 5,000 new social rent homes annually – far short of community needs. "The expectation that private developers can solve our housing crisis is flawed," Hodgson argued, noting that London has delivered an average of under 40,000 new homes per year over the past decade, with only about one-third classified as affordable or social rent.
To address the shortfall in meeting the new target of 88,000 new homes per year, Hodgson proposed a radically different approach. He called for "publicly led development paid for by UK pension funds, providing 100 percent affordable and social rent new homes, that are sustainable, high-quality and robustly designed by architects in collaboration with communities." He advocated for replicating this model across the country to meet local housing needs.
However, not all industry voices were critical of the proposed changes. Paul Rickard, chief executive of developer Pocket Living, expressed strong support, particularly for modifications to dual-aspect requirements. "It's been a real issue to maximize dual aspect where possible, with no wiggle room, so you end up designing in complexity and cost that gives us zero benefit for the resident," Rickard explained. He emphasized that having flexibility through the planning process doesn't mean building to lower standards but rather "driving appropriate design so you get the right homes in the right places with the right features."
Rickard acknowledged that while the changes represent marginal gains, they could provide meaningful assistance given London's housing crisis. "House-building in London is so much in crisis, any marginal difference helps," he stated. "Up until now, we've had the death by a thousand cuts. So why don't we want to reverse some of those cuts? There are a thousand levers we need to pull. The government is pulling some of them, and I'm hugely supportive of that."
Rob Perrins, chair of Berkeley Group, also praised the government's initiative, stating: "We commend the secretary of state and Mayor of London's leadership in bringing forward this package, which goes a long way towards resolving London's viability challenge." He emphasized that for the measures to succeed, "every organization involved in housing delivery must now get behind them, and act with real urgency and conviction to increase homebuilding at pace."
The housing design changes form part of a broader emergency package aimed at reviving London's construction sector. Additional measures include granting Mayor Sadiq Khan enhanced powers to review and call in housing schemes of 50 homes or more that boroughs indicate they will refuse. City Hall will also gain authority to rule on developments exceeding 1,000 square meters on greenbelt land. According to MHCLG, Khan will be able to conduct call-in processes without full hearings, potentially reducing planning timelines by six months.
The government also confirmed an initial £322 million to establish the City Hall Developer Investment Fund, previously announced in June. Industry insiders had reportedly pushed for even lower affordable housing targets – between 10 and 15 percent – according to Financial Times reporting, making the proposed 25 percent target a compromise position.
Under the new framework, housebuilders will be eligible for time-limited emergency relief from the Community Infrastructure Levy (CIL) where necessary to unlock development, provided at least 20 percent of housing in their schemes remains affordable. This relief will apply to projects starting after new regulations take effect and before the end of 2028.
Mayor Khan defended the changes by citing challenging market conditions that have created what he called "a perfect storm for house-building," including construction inflation, high interest rates, the pandemic, and Brexit impacts. "Affordable housing has always been one of my top priorities," Khan stated. "Urgent action is required, which is why I've been working with the government on this package of bold measures. I grew up in a council house, so I know the importance of social and affordable homes. I'm not willing to stand by while the supply of affordable housing for Londoners dries up."
Despite the urgency expressed by government officials, consultation dates for the proposed changes have not yet been announced, leaving the timeline for implementation uncertain. The debate reflects deeper tensions within London's development community about how best to address the city's persistent housing shortage while maintaining design quality and affordability standards.
