Enhancing Design Review in England: The Code of Conduct

As the government moves to integrate design review more firmly into mainstream planning practice, we have published a free, open-source Code of Conduct — a model-neutral governance framework for independent design review in England.

Design review has been a part of the English planning landscape for many years. However, it has never had a single, widely recognised governance standard. Different panels operate under various models, leading to inconsistencies in procedural transparency. The approaches to key issues such as independence, conflicts of interest, and the status of panel feedback vary significantly. Consequently, we see a patchwork system. Some elements function well, while others remain opaque to those outside the process.

Timeline of Key Policy Developments: The NPPF was adopted as a national policy in December 2024. A draft design and placemaking PPG is set for consultation from January to March 2026, leading to the publication of a model-neutral governance framework, highlighted as free and open-source, under the Code of Conduct.

This situation is increasingly important as policy direction shifts towards giving design review greater significance. The current National Planning Policy Framework (NPPF) expects local planning authorities to access and encourage appropriate use of design review. This is particularly vital for significant projects, such as major housing and mixed-use developments. The outcomes of these processes must be taken into account. The draft Design and Placemaking Planning Practice Guidance, consulted on between January and March 2026, aims to consolidate existing guidance into a more accessible resource. Its draft policy DP4 would place greater emphasis on design quality throughout the evolution, assessment, and delivery of development proposals.

These instruments carry different legal weights — the NPPF is adopted national policy, while the PPG, once finalised, will serve as guidance. However, the trajectory remains consistent: design review is being tasked with more responsibilities. To fulfil this role credibly, the governance behind it must be visible, testable, and consistently applied.

That is why we have published the Code.

What the Code of Conduct Does

The Code of Conduct for Design Review Panels is a model-neutral governance framework. It is free to use, open-source, and intended as a resource for the entire sector: independent panels, those operated by or on behalf of local planning authorities, applicants, promoters, and design teams. It does not favour any single delivery model and does not presuppose any particular commercial arrangement.

A design team presents a masterplan to the Panel. The Code covers how such sessions should be governed, from panel composition to the status of written feedback.

The Code covers seven areas of practice:

1. Panel Composition: It should be fair, representative, and drawn from a national pool of appropriately qualified professionals.

   
   

2. Transparency: The relationship between panels and commissioning bodies must be clear. Commissioning arrangements should not influence panel composition, the conduct of reviews, or the content of panel comments.

   
   

3. Management: Panels should be well-managed, with a panel manager who is structurally separate from both the commissioning body and the local planning authority.

   
   

4. Quality of Feedback: Feedback must be high-quality, proportionate, and expressed as observations and suggestions rather than advice or recommendations. It should be issued through a written report that reflects the collective view of the panel.

   
   

5. Policy Informed Process: The process should be informed by national and local policy.

   
   

6. Conflict of Interest Management: Conflicts of interest must be declared, managed, and recorded.

   
   

7. Public Governance Arrangements: Governance arrangements, including the legal entity operating the panel, its leadership, and any material commercial relationships, should be publicly available.

   
   

The Code incorporates the Nolan Principles of Public Life. It requires that all contextual input is shared transparently within the review session itself, rather than through private briefings. Additionally, if a scheme has previously been reviewed by another panel, that earlier feedback should be part of the material considered.

None of this is revolutionary. Most of it reflects what good panels already do. The point of codifying it is to make the standard visible. This way, everyone involved — applicants, authorities, inspectors, and communities — can see what is expected and test whether it is being met.

Design Review Panel Independence is Structural, Not Just Verbal

The Code’s treatment of independence deserves particular attention because it goes beyond the usual assurances.

Most panels describe themselves as independent. However, fewer clarify what they mean by this. The Code addresses this directly. It requires structural independence in thinking, processes, and conclusions, maintained regardless of who commissions or funds a review. The panel manager must not be an officer, employee, or agent of the commissioning body or local planning authority. Panel member identities should not be disclosed in advance to commissioning parties. Conflicts of interest must be declared and managed through a documented process. The written feedback document — not the views of any individual panellist — constitutes the panel’s output.

The importance of impartiality in design review panels: ensuring applicants and authorities trust the separation of decision-making processes.

This matters because the credibility of design review depends on separation in two directions. Applicants and their design teams need confidence that the panel is genuinely separate from the decision-maker. They must trust that it is not a proxy for the local authority’s position. Equally, local authorities, inspectors, and the public need assurance that the panel is separate from the applicant and is not merely an extension of the applicant’s professional team. If either side of that equation is compromised, the evidential value of the process is weakened.

This diagram illustrates the concept of two-directional independence in design reviews, emphasizing the need for a neutral Design Review Panel that maintains clear separation from both the Applicant & Design Team and the Local Planning Authority, ensuring it is neither an extension of the applicant’s team nor a proxy for the local authority’s position.

A code of conduct cannot guarantee independence on its own. However, it can make the standards against which independence is judged more transparent, consistent, and capable of external scrutiny. That is what this Code is designed to achieve.

Why This Matters for Major and Complex Proposals

The value of robust governance becomes most apparent in larger schemes, such as strategic housing sites, mixed-use developments, sensitive landscape proposals, and infrastructure-scale projects.

Site visits are an integral part of extended design review for major proposals, enabling panellists to understand place, context and constraints at first hand.

The NPPF identifies design review as particularly important for significant projects. Planning Inspectorate guidance on Nationally Significant Infrastructure Projects emphasises that good design depends on an effective, intentional, transparent, and deliverable process. This process should be supported by a collaborative multi-disciplinary approach. For proposals of this scale, the value of design review rarely lies in a single session. Instead, it lies in structured, iterative scrutiny with the right range of expertise, sufficient time to test the proposal properly, and a clear written record produced while the design remains capable of meaningful evolution.

For applicants and promoters working on such schemes, a well-governed review process can strengthen the design audit trail. It can reduce ambiguity in pre-application discussions and demonstrate that independent scrutiny has been real, structured, and professionally managed. These are practical benefits with significant weight in the planning process.

A Constructive Offer to the Sector

This Code has not been produced as an abstract exercise or a competitive gesture. It arises from a practical concern shared widely across the professions involved in design review. Confidence in the process depends on more than the expertise around the table; it also relies on the framework behind it.

Extended review combines formal panel sessions with site visits, enabling structured scrutiny of larger and more complex proposals over multiple stages.

The Code was shaped through discussions with experienced professionals from various fields, including planning, architecture, landscape, urban design, and development. It is published openly so that others can use, adopt, or refer to it as they see fit. For local planning authorities, it may provide a benchmark for the safeguards that should underpin any panel arrangement. For independent panels, it may serve as a useful framework against which to review their own procedures. For applicants and design teams, it may help distinguish between panels whose independence rests on process and those whose independence relies primarily on assertion.

As design review is asked to carry more weight in the planning system, this distinction will become increasingly important. A serious governance framework helps make it possible to tell the difference.

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