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Blog: Reflections on the Proposed Modifications to the City Plan 2040 by Newmark

15 Oct 2025

The City of London Corporation has published the Proposed Modifications to its draft City Plan 2040, outlining the key changes identified by the Planning Inspector as necessary to ensure the plan is sound – a major step towards its adoption. The Plan will be the Square Mile’s main development and planning framework, shaping its built environment up until 2040.

The City of London Corporation’s Local Plans Sub (Planning & Transportation) Committee – chaired by Planning and Transportation Chairman Tom Sleigh – has approved the Proposed Modifications to the draft City Plan 2040 for formal consultation. The Modifications will now go to the Planning and Transportation Committee and the Policy and Resources Committee for approval before the consultation begins.

Following feedback on the draft Plan through representations, Statements of Common Ground, and the formal Examination in Public (EiP) hearings, which concluded in June, the Planning Inspectors have identified a list of Main Modifications required to ensure the Plan is ‘sound’, a legal requirement for adoption.

The CPA has been actively engaged with the City Corporation throughout the Plan’s preparation and examination. The Main Modifications are largely as anticipated, reflecting the key points from the EiP hearings and ongoing discussions between the City Corporation, the CPA, and its members.

The following highlights capture the most important aspects of the Modifications and the Sub Committee meeting:

Offices

The draft Plan’s commitment to deliver a minimum of 1.2m sqm of net additional office floorspace by 2040 has been subtly strengthened, with references to ‘targets’ being replaced by ‘minimum requirement’. It has also been clarified that this figure relates to Net Internal Area rather than Gross Internal Area.

Culture

In response to queries raised during the EiP hearings, additional supporting text has been included to clarify when and how cultural provision will be required as part of development proposals, including major retrofits and extensions. The Plan also now references the forthcoming Cultural Supplementary Planning Document, which will provide further guidance.

Following feedback from the City’s churches, new references have been added throughout the Plan to highlight the important role they play in meeting local cultural needs.

Cycle parking

The CPA has been advocating for a revised approach to cycle parking standards in the City of London, through the publication of its Cycling & the City report and representations on the draft Plan. As a result, amendments have been agreed to the policy wording and supporting text to allow for alternative cycle parking provision in exceptional circumstances, where the minimum long-stay standards cannot be fully met for office developments.

Heritage and tall buildings

The EiP process was temporarily paused to allow the City to prepare additional evidence supporting the identification of four new areas where tall buildings may be appropriate, including the City Cluster, Fleet Valley and Broadgate Tall Building site. The resulting Modifications reflect these updates.

Further amendments have also been made following discussions with heritage bodies, resulting in additional references have been included to the use of the St Paul’s Setting Study in assessing proposals, as well as guidance on how the Outstanding Universal Value of the Tower of London should be considered and interpreted.

Crucially, the Main Modifications do not alter the overall approach adopted by City officers towards tall buildings and heritage.

Housing

The housing targets of 1,706 net additional dwellings, remain as originally proposed; however, the Plan now clarifies that these represent a minimum requirement.

The City Corporation is working with the Mayor of London to identify additional housing capacity to inform the setting of new housing targets in the forthcoming London Plan. The outcomes of this process will be used to guide housing targets for the period beyond 2028/29.

Next steps

The City Corporation intends to consult on the Modifications between December 2025 and January 2026, subject to their approval by the Planning and Transportation Committee and the Policy and Resources Committee.

The Inspector will review all consultation responses and consider them when preparing the final report, expected in May 2026. The examination will conclude once the City Corporation receives the report, with adoption of the City Plan 2050 anticipated for summer 2026.

At this stage, the draft Plan carries limited weight in decision-making, with full weight applied once it is formally adopted. Nevertheless, planning applications are already being assessed with reference to the development framework that will be in place at the point of decision-making.

Read the latest information on the City Plan 2040

Further reading:

Report: Cycling & the City
White paper: Supporting the City’s economic growth and development pipeline
Blog: Reflections on the first week of the City Plan 2040’s Examination in Public by Newmark
Blog: Things to look out for in the City Corporation’s transformative draft City Plan 2040 by Jeremy Randall
Blog: Tall buildings, heritage and the future of the office by Jeremy Randall

Authors

Jeremy Randall

CPA Board Planning Advisor & Partner, Newmark

Beth Hawkins,

CPA NextGen Vice Chair & Associate, Newmark

Suzanne Thurtle

Associate – Knowledge and Policy Lead, Newmark