16. S.28 Guidelines – NPF Implementation: Housing Growth Requirements (2025)

On the 29^th of July 2025, the Department of Housing, Local Government and Heritage published the NPF Implementation: Housing Growth Requirements, as guidelines in accordance with Section 28 of the Planning and Development Act 2000 (as amended). These guidelines replaced the ‘Section 28: Housing Supply Target Methodology for Development Planning (2020)’.

The purpose of these guidelines is to:

• Require planning authorities to bring forward a variation of their development plan “as soon as possible” to increase their housing delivery targets in core strategies to reflect the Revised National Planning Framework (April 2025).
• Facilitate the revision and update of development plans in accordance with the ‘National Planning Framework – First Revision (2025)’.
• Interpret the national housing growth requirements to the local level for implementation through development plans.
• The increased housing delivery targets, combined with a requirement to include up to 50% ‘additional provision’ in the quantum of zoned land, will lead to an increase in the extent of zoned land in most authorities/areas.

These guidelines estimate a total housing demand of c. 55,000 dwellings per annum to 2034 (including unmet demand of 13,900) and an estimated total housing demand of c. 41,000 dwellings per annum between 2034 and 2040 will need to be provided for in development plans. The new housing targets aim to evenly distribute new homes between the Eastern & Midland Region and the rest of the country, promoting balanced regional growth.

The guidelines support a plan-led approach to growth, emphasising consistency with national and regional strategies and are intended to guide the review and variation of Development Plans, and directs planning authorities to commence the review or variation of same as quickly as possible.

Key Figures and Objectives

• Housing Demand Projections by 2040

• Unmet demand from 2017-2040 is estimated at 140,000 dwellings.
• The housing growth projections follow the NPF’s 50:50 Cities strategy, meaning 50% of the new housing is targeted for the Eastern & Midland Region, and the other 50% across the rest of the country.

NPF Housing Growth Requirements

• Planning authorities must update their City or County Development Plans to include the housing growth requirements from Appendix 1 of new S. 28 Guidelines.
• Planning Authorities are also advised to begin revising or varying their plans as quickly as possible, based on the current stage of their Development Plans. JSA have analysed Appendix 1 of the Guidelines to identify the additional housing units to supplement existing targets for each local authority (see Appendix 1).
• Building on previous guidelines that allowed up to 25% headroom for housing provision, the new Section 28 guidelines now require planning authorities to include up to 50% additional provision of zoned land beyond the baseline targets, in acknowledgement that a relatively significant proportion of zoned lands are not activated over the period of a development plan.

Tiering and Phasing of Land

• Planning Authorities are also required to conduct Settlement Capacity Audits as part of the variation process to access serviced or serviceable lands and infrastructure needs.
• Planning Authorities should promptly assess land suitability for development over a 12 plus year period to cover current and subsequent ten-year development plans.

Long-Term Strategic and Sustainable Development Sites/Opportunity Areas

• Identification of Long-Term Strategic and Sustainable Development Site/Opportunity Areas should be focused on the 5 cities, MASP Areas, designated Regional Growth Centre and designated Key Growth Centres. This targeted approach supports the provision of required infrastructure, aligns with Transit Oriented Development and complies with the legislative provision of UDZs and Candidate UDZs.
• Lands that support the goals of the guidelines but cannot be serviced during the current plan period may be designated as ‘Long-Term Strategic and Sustainable Development Sites/Opportunity Areas’ to guide future development, in coordination with infrastructure providers. These lands may be contemplated as further ‘additional provision’ of zoned land beyond the baseline housing growth requirement (or “headroom”).

Review and Variation of Development Plans

• Planning Authorities are directed to review the core strategies and zoning objectives of the current development plans against the objectives of these guidelines.
• Planning Authorities must review whether existing zoned lands are sufficient to meet the housing growth targets and be developed within the current plan period. If it’s unlikely that these lands will be developed within the remaining period of the current plan, authorities may be required to consider zoning alternative lands that can support housing delivery in the short to medium term.
• Under the Planning and Development Act 2024, development plans will transition to a 10-year duration, and must include zoning of all settlements, however, this provision has not yet been commenced. Once enacted, Section 46 of the Act will require planning authorities to incorporate housing growth targets and ensure that sufficient and suitable land is zoned through the preparation of a Housing Development Strategy.
• Planning authorities must take all necessary measures to vary or review the current adopted development plans as soon as possible, and this presents the opportunity for zoning maps for all settlements to be incorporated into the relevant development plan as part of the variation process, rather than being covered by LAPs in certain instances, consistent with the requirements of the new Act.

Most Significant Uplifts in Housing Numbers

The following table presents the local authorities with the highest annual increase in housing units under Appendix 1 of the new Guidelines.

Conclusions

The ‘NPF Implementation: Housing Growth Requirements (2025)’ marks a significant shift in Ireland’s housing strategy and requires all development plans to be updated as a matter of urgency to align with the Revised NPF targets. These guidelines estimate a total housing demand of c. 55,000 dwellings per annum to 2034 (including unmet demand of 13,900) and an estimated total housing demand of c. 41,000 dwellings per annum between 2034 and 2040 will need to be provided for in development plans. It promotes balanced regional development, compact growth, and strategic land use, requiring planning authorities to swiftly update development plans to reflect new targets, including up to 50% additional provision of zoned land or ‘headroom’ in the extent of zoning.

The Guidelines require planning authorities to assess whether zoned lands can be serviced within the current plan period. If not, alternative lands must be zoned to support housing delivery, along with additional lands for future growth beyond the current development plan period. This proactive approach promotes sustainable development and long-term housing provision across the State. Aligned with the ‘50:50 Cities’ strategy, the guidelines emphasize tiering, phasing, and identification of strategic sites to ensure sustainable, infrastructure-ready housing, while promoting a proactive, plan-led approach and increased residential zoning.

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Appendix 1: Housing Growth Requirements for each Planning Authority