The Mayor just admitted London is missing its own housing targets: what AMR21 means for small-site underwriting

The 21st London Plan Annual Monitoring Report — AMR21 — was signed off by the Mayor on 18 February 2026 under decision reference ADD2801. The document covers the 2023-24 monitoring period. It is, on the face of it, a routine administrative product: the Greater London Authority publishes one every year, the trade press summarises it, and the underlying spreadsheet appendices sit on the GLA website for technical readers to mine. What makes AMR21 different from its predecessors is the language in the headline section.

Where AMR20 had hedged, AMR21 is direct. The document names six London Plan key performance indicators on which delivery has formally failed against the targets the Plan set itself. Three of those six KPIs are the load-bearing ones: housing approvals, housing completions, and the supply of affordable homes. The other three are transport mode share, the installation of cycle parking, and cultural floorspace. Income inequality is reported as having “worsened slightly” relative to AMR20.

This is, structurally, a one-sentence event: the Mayor of London has admitted, in writing, that the London Plan is failing on its three primary housing KPIs. It is not a finding from a think tank, a lobby group, a planning consultancy, or a private commentator. It is the Plan’s own author marking its own homework, in a published statutory document, and grading it as a fail.

Why the same document also matters at the demand end

Buried further into the AMR21 narrative is a second finding that has had almost no press coverage at all. The eligibility ceiling for Intermediate Rent — the affordable-housing sub-tenure pitched between Social Rent and London Living Rent, used in 22 of the 33 London borough YAML configurations in our reference set — has been moved upward.

The numbers: the maximum household income at which an applicant qualifies for Intermediate Rent has risen from £67,000 to £75,000. The rationale named in the AMR21 text is straightforward: the 65th-percentile London household income from HBAI 2023-24 stands at £75,193. The previous £67,000 ceiling had drifted out of step with the income distribution it was meant to track. AMR21 corrected the drift.

The effect, in plain demand-pool terms, is that the renter cohort eligible to take up an Intermediate Rent unit in any London small-site scheme has widened by roughly the share of London households sitting in the £67k-£75k band. That is a non-trivial slice of the London renter market. On any borough YAML that runs a 70/30 affordable split with an Intermediate sleeve, the absorption-rate assumption sitting under the bid math has just become more permissive than it was on 17 February.

What this changes at small-site scale

Two things. The first is interpretive. AMR21 turns the structural-supply argument that has been doing background work on every Site Assessment Perfect Scale has issued into a cite-able, Mayor’s-own-words finding. The framing “London is missing its own targets” was previously the third-party version of a story that planning consultancies, housing associations, and the GLA itself had been quietly briefing for two years. As of 18 February it is the first-party version. That changes which sentences a developer’s bid memo can carry in front of an investment committee, and what a lender’s underwriting team can footnote against in its credit paper.

The second thing is operational, and only applies to a specific cohort of schemes. If you are running a small-site scheme that includes Intermediate Rent in its affordable-housing tenure mix — which is the standard mix in 22 of the 33 London boroughs, including all of inner London and most of outer — then the absorption-rate assumption under the Intermediate sleeve needs revisiting. Not by a lot. The change is one band of the income distribution. But on a model where Intermediate units are projected to absorb at 8 to 12 months and the absorption rate sets the developer’s finance line, an upward shift in eligibility tightens that band on the favourable side. Re-run the model, and the Intermediate-inclusive variant of the scheme reads roughly 1.5 to 3 percentage points stronger on IRR than it did three months ago.

For schemes that already excluded Intermediate Rent on viability grounds, AMR21 may be the document that re-opens the conversation with the borough about putting it back in.

The cohort: 22 London boroughs whose policy framework already includes Intermediate

The 22 borough YAMLs in our reference set that encode an affordable-housing tenure split explicitly including Intermediate are, broadly, the inner ring plus the better-served outer boroughs:

Barnet, Bexley, Bromley, Camden, City of London, Croydon, Enfield, Greenwich, Hackney, Hammersmith & Fulham, Haringey, Islington, Kensington & Chelsea, Kingston upon Thames, Lewisham, Merton, Richmond upon Thames, Southwark, Sutton, Tower Hamlets, Waltham Forest, Westminster.

The eleven boroughs whose tenure splits do not currently include Intermediate as a category are mostly outer-east and a few outer-west authorities where the affordable mix has been weighted to Social Rent and London Affordable Rent — in those boroughs AMR21’s threshold change is not, today, a viability lever. It may become one if the borough revises its mix in the next plan-making cycle.

What to do with this before the next bid

Three concrete things are worth doing inside the next two weeks on any live London small-site bid in one of the 22 boroughs above.

First, pull the latest revision of the borough’s affordable-housing supplementary planning document and confirm the Intermediate Rent sleeve is still on the borough’s preferred-tenure list. Most are, but in two boroughs that we know of, an active partial-review process may be re-weighting toward Social and London Affordable Rent at the expense of Intermediate. The free dashboards at perfectscale.uk/boroughs carry the current tenure framing for all 33 in summary.

Second, re-run the absorption-rate line of the Intermediate sleeve under the new ceiling. A £75,000 ceiling against the 2023-24 HBAI distribution moves the eligible-household share materially. On a 70/30 split with 30% affordable and a third of the affordable as Intermediate, the change is small but real. Across a ten-scheme rolling pipeline it compounds.

Third, if the bid memo references the supply-side argument at all, replace any third-party citation (Lichfields, Molior, Savills research) with the AMR21 citation. Same point, better source. The Mayor admitting to KPI failure in a statutory document is the cleanest possible support a London small-site memo can carry on the structural-supply line.

What we will be doing next

The intelligence reports we ship across all 33 London boroughs now surface a one-line AMR21 callout in the Part 1 Policy Framework section, naming the KPI failure and the Intermediate Rent threshold change, effective 14 May 2026 across every borough regenerated from that date. The AMR21 appendices — which carry borough-level housing-delivery numbers we have not yet parsed — are scheduled for a next-pass fetch. Where Greenwich’s 2024 borough AMR or equivalent local monitoring reports carry numbers that pair with the London-wide AMR21 figures, those will land in the next refresh of the Greenwich Intelligence Report.

Sources. Greater London Authority, “ADD2801 London Plan Annual Monitoring Report 21 (2023-24)”, approved 18 February 2026. Households Below Average Income (HBAI) 2023-24, ONS / DWP, for the London 65th-percentile household income figure underpinning the Intermediate Rent threshold change.