Quick answer: On 16 July 2026 the Mayor of London published the draft London Plan for consultation, and Chapter 5 rewrites how energy performance is assessed on major schemes. The current approach — Policy SI 2’s four-stage “be lean, be clean, be green, be seen” hierarchy, judged as a percentage improvement on Part L and backed by a carbon offset payment for any shortfall — gives way to four new policies, GHR1 to GHR4. GHR1 introduces absolute Energy Use Intensity (EUI) and Space Heating Demand (SHD) targets, in kWh/m² a year, with both a baseline and a tighter aspirational figure. The draft does not carry forward the carbon-offsetting route: offset payments are proposed to go, replaced by a requirement to meet the numbers at source. The five years of post-occupancy energy reporting that major schemes already owe under “be seen” carries over — now set against the kWh/m² targets the scheme was approved on. The consultation closes on 15 October 2026; examination is expected in 2027 and adoption in early 2028. Nothing in the current London Plan changes today — this is a draft — but the direction of travel, and the closing date, are both worth acting on now.
Why an assessor outside London should still read this
Energycount is a national audience, and this is, on its face, a London-only planning document. Two things make it worth ten minutes of anyone’s time who works on SAP, DER/TER or energy statements anywhere in England.
First, if you work on London schemes at all — and a lot of national housebuilders do — this changes what the energy statement has to demonstrate before the SAP calculation is even run. Second, the London Plan has form as a bellwether: London led on the energy hierarchy itself, on carbon offset funds, and on requiring overheating assessment years before Part O existed. A Mayor’s plan that drops offsetting in favour of absolute, monitored performance targets is a reasonable preview of where national policy — and where more Local Planning Authorities’ own local energy standards — are heading next.
What actually changes: four policies instead of one
The current London Plan runs energy performance mainly through Policy SI 2 and its four-stage hierarchy: be lean (reduce demand), be clean (supply energy efficiently), be green (renewables), be seen (monitor and report). Major schemes are judged on carbon: at least a 35% on-site cut beyond Part L, with any shortfall to zero carbon offset. The draft reorganises energy, heat and overheating into four policies:
| Policy | What it covers |
|---|---|
| GHR1 | Energy efficiency — moves from a percentage-improvement test to absolute Energy Use Intensity and Space Heating Demand targets, with in-use monitoring |
| GHR2 | Low-cost low-carbon heat — every major scheme submits a Low Carbon Heat Appraisal to find the lowest-cost, lowest-carbon heating for the site |
| GHR3 | Whole life-cycle carbon — for referable schemes, links demolition and retention decisions to a whole-life carbon assessment and a pre-redevelopment audit of the existing building |
| GHR4 | Heat risk — overheating and the urban heat island: orientation, glazing, shading, ventilation and layout justified at planning stage, not just a late-stage cooling check |
The reduce-supply logic of the old hierarchy hasn’t disappeared — GHR1 and GHR2 still separate demand reduction from low-carbon supply — but the single carbon number is gone. Each strand now has its own test, and GHR1’s test has changed shape entirely: from “beat Part L by X%” to “hit this many kWh per square metre, and report what the building actually uses.” GHR1 also tells London’s boroughs not to set their own energy-efficiency or emissions standards in local plans — one set of numbers for the whole city.
The end of the offset cheque
Under the current London Plan, a scheme that cannot reach zero-carbon on site pays a cash-in-lieu contribution into the borough’s carbon offset fund for the shortfall, priced per tonne of CO₂. It is a well-worn route, and boroughs have built retrofit and carbon-saving programmes around the money it raises.
The draft does not carry that mechanism forward — its supporting text refers plainly to “the removal of carbon offsetting policy” (paragraph 5.21). The direction is source-level performance — fabric, heat source and efficiency measures that actually deliver the kWh/m² figure — rather than a calculated shortfall bought out at the end of the process. For a design team, that removes a fallback that has quietly absorbed difficult sites (tight urban plots, retained façades, poor solar access) for years. Where an offset payment might once have closed the gap between what was achievable and what the policy required, the draft expects the gap not to exist.
The numbers
GHR1’s policy box sets the targets out in full, in kWh/m² a year on gross internal area:
| Target | Baseline | Aspirational |
|---|---|---|
| Space Heating Demand — all typologies | 20 | 15 |
| Energy Use Intensity — residential | 40 | 35 |
| Energy Use Intensity — office | 90 | 70 |
| Energy Use Intensity — primary school | 40 | 35 |
| Energy Use Intensity — industrial | 40 | 35 |
| Energy Use Intensity — hotel | 120 | 80 |
| Energy Use Intensity — student accommodation | 65 | 50 |
EUI counts regulated and unregulated energy — everything the building uses in a year — so it is a wider number than the regulated energy a Part L calculation covers. Uses outside these typologies, and major refurbishments, still have to minimise and report EUI and SHD against industry benchmarks such as LETI and the UK Net Zero Carbon Buildings Standard. These are consultation figures, taken from the GHR1 policy box in the draft London Plan, and they can still change at examination before the Plan is adopted.
One independent check worth reading alongside the GLA’s own text: an analysis on BE News (27 August 2026, by Andy Crowther of Cundall) points out that an office meeting the 90 kWh/m² baseline would beat the CRREM decarbonisation pathway in 2030 but exceed it from 2040 — and would not meet the UK Net Zero Carbon Buildings Standard pathway in any of the years compared. Multi-family residential is the one typology where both London Plan targets stay under both pathways out to 2050. The practical point for anyone advising a client: a single “policy compliant” figure doesn’t automatically mean “net-zero-aligned” for the building’s whole life, and it’s worth being able to explain the difference when a client asks why their scheme clears planning but a lender’s ESG due diligence still flags it.
GHR4: overheating moves earlier
The current London Plan already requires overheating assessment ahead of national Part O. The draft’s GHR4 (Heat risk), which applies to all major development, goes further by tying overheating, shading and passive design into masterplanning and layout rather than treating it as a check run once the layout is fixed. Applicants have to justify, in the planning application, how the design maximises passive measures — orientation, less unnecessary glazing, external shading, high-albedo materials, openable windows and cross-ventilation — and minimises the energy used for any cooling, allowing for a warmer future climate. We’d treat the detail of which CIBSE methodology (TM59, TM52 or TM49) applies to which building type as one to confirm from the policy text itself once you’re working a live scheme against it, rather than from a summary — including ours.
Five years of reporting — now against a kWh target
Post-occupancy reporting isn’t new in London: the current Plan’s “be seen” stage already requires major developments to report their energy performance to the Mayor for at least five years. GHR1 keeps the duty (Part D) but changes what the reported figure is measured against. Today the planning test is a percentage cut in regulated CO₂ beyond Part L, so a building’s metered energy use isn’t the number it was approved on. Under GHR1 it is — the target itself is kWh per square metre a year of everything the building uses. That is the performance gap EPC accuracy research has been quantifying nationally — the difference between a compliant design-stage calculation and what a building actually uses — set directly against the planning permission. A design that scrapes GHR1’s baseline on paper and then under-delivers in year one will show up in the Mayor’s own data, on a five-year clock.
What to do before 15 October
- If you have live or upcoming London schemes, read GHR1 to GHR4 in the consultation document itself, not just the summaries — this article included. The figures above are from the GHR1 policy box, but they are consultation figures and may change before adoption.
- Model early. An absolute kWh/m² target with no offset fallback means the fabric-first, demand-reduction stage of the hierarchy has to work harder before you get to heat source and renewables — there’s no longer a cheque waiting at the end for the shortfall.
- Treat GHR4 as a masterplanning input, not a late-stage report. Orientation and massing decisions made before an overheating consultant is appointed are the ones the draft is trying to catch.
- Respond to the consultation if the targets, the loss of offsetting, or the five-year monitoring duty affect a scheme you’re working on. Responses are taken through the GLA’s draft London Plan consultation until 5pm on 15 October 2026.
- Watch for the ripple effect even if you never work in London. A Mayor’s plan that abandons percentage-improvement targets for absolute, monitored ones is exactly the kind of precedent that turns up in the next round of local plan energy policies elsewhere.
Nothing here changes a live Building Regulations submission today. But if you’re pricing, designing or writing an energy statement for a London scheme that will still be in the pipeline in 2028, this is the version of the rules it’s likely to meet.