Consenting at speed
What the July 2026 reforms changed at the front end of the Development Consent Order regime, checked against primary law and read against 154,723 published DCO documents.
How we approached it
Check the change against the source, and then look at how the regime actually runs before deciding where the effort should go.
- Status
- Research, with supporting tools
- Purpose
- Give promoters a checked statement of what changed and an evidence base on how DCOs actually run
- Sector
- Roads, rail, ports, airports, power generation including nuclear, power lines, pipelines, reservoirs, water and waste
- Scope
- The DCO regime in England and Wales
- 154,723
- Published DCO documents downloaded and classified
- 54
- Standard document types, from 107,000 free-text labels
- 61%
- Of published documents belong to the examination stage
How we went about it
What changed in July 2026
The reforms rewrote the front end of the regime and left the rest of it in place.
On 24 July 2026 the Planning and Infrastructure Act 2025 changed the front end of the Development Consent Order regime. Six statutory pre-application provisions of the Planning Act 2008 went (ss.42, 43, 44, 45, 47 and 49), and with them the Statement of Community Consultation, the Consultation Report and the duty to publish preliminary environmental information before finalising the Environmental Statement. The acceptance test was rewritten, and a 10% biodiversity net gain requirement applies to applications made on or after 2 November 2026.
The pre-application duties, after 24 July 2026
What acceptance now tests
- ContentThe application form and accompaniments (s.37(3) to (5))
- PublicityThe applicant's approach to s.48
- AdviceRegard to the Inspectorate's s.51 advice
- GuidanceRegard to guidance under s.50(1)
How the reforms arrived in 2026
- Costs power and compulsory purchaseThe Examining Authority can award costs (s.96B). The first compulsory purchase changes take effect.
- Biodiversity gain machinerySchedule 2A to the Planning Act 2008 in force (SI 2026/492): a gain objective of at least 10%.
- Biodiversity gain statementsDefra publishes the statements that set the objective for each infrastructure type.
- The main packagePre-application duties omitted; s.46 and the s.55 acceptance test rewritten (SI 2026/641).
- Biodiversity net gain appliesTo applications made on or after this date.
Not yet in force Post-consent changes to Orders (Planning and Infrastructure Act 2025, s.12), and temporary possession of land (s.112, which waits on s.18 of the Neighbourhood Planning Act 2017).
How the work was built
Four pieces of work, all of them built from public sources.
The tools sit alongside Project:OS, which sets out consenting as nine connected sub-processes, from consenting strategy and route selection through examination support, consent conditions and secondary consents to capturing precedent for the next scheme.
What the record shows
Examination is a spike rather than a curve. 61% of all published DCO documents belong to the examination stage, so that is the resourcing peak to plan for. The reforms do not move it: the examination timetable, the decision tests and the judicial review window are unchanged.
The change is all at the front end, where the consultation record is no longer a compliance document but a judgement a promoter may later have to defend. We also found no published benchmark for DCO consenting cost in any sector, which is why the Cost Estimator shows its evidence for each coefficient.
Where the documents are produced: 154,723 published DCO documents by stage
The examination peak: documents published per scheme each month
Months before and after the examination opened
What the documents are: the eight largest of 54 types
Where they come from: documents by sector
Who a promoter will meet: organisations in the most projects
Skipping engagement does not make the objections go away; it moves them to examination, or to a challenge of the granted Order, where they are harder and more expensive to deal with.
What we cannot tell you yet
The reforms are recent, and the evidence on their effect simply does not exist yet.
- No reformed application yet. As at 31 August 2026 we had identified no application accepted after the complete reformed pre-application route.
- Time saved is a forecast. The government's expectation of about twelve months saved is a forecast, not a result.
- Commencement is still moving. Provisions are commencing in tranches, so check the current position before relying on any of them.
- What the corpus covers. 154,723 published documents across 268 projects, from 17,108 organisations. The charts analyse 179 projects in detail; 83 are excluded because they were decided or withdrawn before 2018, hold fewer than five documents, or are minimal legacy records (2,083 documents in all).
- How the types were made. About 107,000 different free-text document labels were sorted into 54 standard types by a language-model classifier. 138,877 documents (89.8%) were classified at high confidence, 4.1% at medium and 6.1% at low; the lower-confidence share should be read with that in mind.
- Cost is a structured judgement. The Cost Estimator is not a quotation. Design maturity and regime certainty are judgement levers, and its coefficients rest on the evidence it shows.
- A dated corpus. The reference corpus was verified against source on 30-31 July 2026. Later guidance, instruments and judgments are not reflected until it is updated.
Related solutions and services
The evidence base and the tools support promoters through consent.
Talk to us about a scheme heading into consent
If a scheme is heading into consent under the reformed regime, we can help set out what has changed and where the effort is likely to fall.
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