What the Department's National Planning Statement of 4 September 2026 requires, what it leaves to judgement, and what it is likely to mean for every apartment application decided after it issues.
The Planning Design Standards for Apartments National Planning Statement is the first apartment standard to be issued under section 25 of the Planning and Development Act 2024. It replaces the Design Standards for Apartments, Guidelines for Planning Authorities, issued in July 2025 under section 28 of the 2000 Act. A first draft was consulted on from 9 June to 7 July 2026 and drew 58 submissions; the amended draft was published on 14 September 2026 with a revised Strategic Environmental Assessment report, and submissions on it close at 5.30pm on 12 October 2026.
The Department is candid about the purpose. The revised National Planning Framework requires planning for about 50,000 homes a year to 2040; apartment delivery is where the viability gap is widest; and the Statement is meant to "strike an effective regulatory balance" between standards and output. The ministerial forewords say the same thing in plainer terms. On our reading it is a document about cost first and amenity second, and the individual measures make sense on that basis.
Two lines in Chapter 1 matter more than anything in the tables. The Statement "applies to any application for planning permission that is determined after the issuing of this NPS", so a scheme lodged under the 2025 guidelines is likely to be decided under the Statement if the decision comes after it issues. And within two months of issue every planning authority and regional assembly must report to the Office of the Planning Regulator on whether its plan is materially consistent with the National Planning Policies and Measures, and if not, how it will remove the inconsistency.
Section 25 splits a National Planning Statement into two parts. National Planning Policies and Measures (NPPMs) are the part every development plan must be "materially consistent" with. National Planning Policy Guidance is the part plans must "take due account of". Under the 2025 guidelines the equivalent split was between Specific Planning Policy Requirements and the rest; section 27 of the 2024 Act carries the old SPPRs forward with the force of NPPMs until they are replaced, which this Statement is intended to do.
The practical effect, on our reading, is that a development plan objective which contradicts an NPPM would have to be varied out under section 62, and the Office of the Planning Regulator oversees that. What happens at the decision in the meantime is less settled than it looks, and it turns on the date.
Until Part 4 of the 2024 Act commences (deferred on 9 October 2026; new date to be notified), section 34(2)(ba) of the 2000 Act does the work: where a national requirement differs from the plan, the Act provides that it applies instead of the plan. On our reading, a decision-maker applying it is applying national policy and is not contravening the plan, because the conflicting plan provision does not apply.
Once Part 4 commences, section 34 is replaced by section 86 of the 2024 Act, which does not appear to contain an equivalent provision. An authority is to have regard to the provisions of a National Planning Statement that are not already the subject of a provision in a plan, and section 86(5) expressly contemplates a decision that is inconsistent with a Statement provision, requiring only that the authority identify the provision and give its main reasons. On the face of the new Act the automatic override does not appear to have been carried forward. If that reading is right, a scheme that meets an NPPM but breaches a surviving plan standard would be a material contravention of the plan, and would need the section 99 route and a resolution of not less than three-quarters of the members, where today it could have been permitted. The NPPM is not irrelevant to that vote: section 99(2)(b) permits the resolution only where the development is consistent with the NPPMs dealing with the same subject, and the chief executive must advise the members on compliance with National Planning Statements. So the Statement would become the argument that makes a vote available rather than the provision that decides the application, and an applicant would move from entitlement to persuasion until the plans are varied into consistency under section 62. This is subject to how the courts interpret section 86. That is a further reason to engage with the consultation now rather than rely on the Statement later.
The minimum areas are unchanged from the 2025 guidelines for the studio, one-bed and two-bed types. The three-bed four-person unit at 76 m² is a type the guidelines did not have; it sits between the two-bed four-person unit and the 90 m² three-bed and is the Department's answer to the cost of three-bed apartments, which the text singles out as the type most damaging to viability. The Statement also sets the studio at 32 m² expressly to allow "mix and match" modular construction alongside the 63 m² two-bed three-person unit.
| Unit type | Minimum area | Living room width | Storage | Private amenity |
|---|---|---|---|---|
| Studio (1 person) | 32 m² | 4.0 m | 3 m² | 4 m² |
| One bedroom (2 persons) | 45 m² | 3.3 m | 3 m² | 5 m² |
| Two bedroom (3 persons) | 63 m² | 3.6 m | 5 m² | 6 m² |
| Two bedroom (4 persons) | 73 m² | 3.6 m | 6 m² | 7 m² |
| Three bedroom (4 persons) | 76 m² | 3.8 m | 6 m² | 7 m² |
| Three bedroom (5 persons) | 90 m² | 3.8 m | 9 m² | 9 m² |
Widths and bedroom areas carry a 5% tolerance. Communal amenity space is set at the same per-unit figures as private amenity space. On our reading, none of the Appendix 1 figures other than the overall areas in NPPM 2 are binding; the draft describes them as "recommended minimum" guidance.
The rule that at least 25% of units should exceed the minimum by 10% survives as guidance, with the Statement inviting more than 25% in suburban schemes, social and Part V housing and older persons' housing. It does not apply to schemes under ten units, to refurbishment of existing buildings on any site, or to urban infill on sites up to 0.25 hectares, and for ten to 49 units it may be reduced or removed case by case.
A pattern runs through Chapters 3 and 4. For "building refurbishment schemes on sites of any size or urban infill schemes on sites of up to 0.25 ha" a planning authority may, subject to overall design quality, go below 25% dual aspect, relax the 2.7 m ground-floor height, relax storage in part, relax private amenity space further, and relax communal amenity space in part or in whole. Together with section 2.5, which asks authorities to apply the Statement "practically and flexibly" to over-the-shop and historic building conversions, and the 2025 exemption for change of use of vacant commercial upper floors (S.I. 648 of 2025), this is likely to be the most consequential part of the document for anyone holding a town-centre building.
The threshold is worth memorising. A quarter of a hectare is 2,500 m². A great many town and city centre sites fall under it, and on those sites the Statement would give the authority discretion on almost every amenity standard it contains.
Children's play is retained as guidance: a small play space of 85 to 100 m² in schemes of 25 or more units with two or more bedrooms, and a play area of 200 to 400 m² in schemes of 100 or more such units. Read that against Abbey Park Residents v An Coimisiún Pleanála [2026] IEHC 365, decided in June, where a 104-unit grant was quashed for an unidentified contravention of a development plan objective requiring 4 m² of play space per unit. The Statement's play guidance is softer than Fingal's objective was; whether a plan objective of that kind survives the material-consistency test under NPPM 6 is a question the consultation should ask, because the Statement only forbids plans from requiring communal, community and cultural facilities on a threshold basis, and play space is not clearly in that category.
Car parking is left to the Sustainable Residential Development and Compact Settlement Guidelines 2024 (SPPR 3 maximum rates), with the Statement adding that ratios should be "minimised, substantially reduced or wholly eliminated" at accessible locations, that car-free development is permissible, and that accessible spaces should be leased on need rather than sold with units. Bicycle parking is likewise cross-referred to SPPR 4 of those guidelines, with a new emphasis on a funded maintenance regime. Waste storage now cites the EPA's May 2026 report on food waste from apartments for design.
Co-living keeps the presumption against that has applied since 2020, now with a Housing Need and Demand Assessment as what appears to be the only route through. Student accommodation gets its own chapter and NPPM for the first time. The Statement adopts the standards of the Department of Further and Higher Education's Design Guide for State Sponsored Student Accommodation 2025, applies them to private schemes, and prevents development plans from adding to them. An 8 m² study bedroom without an en-suite is the headline; it is likely to be argued over.
Chapter 7 asks for a schedule with every application: the mix and bedspaces, the area of each unit, which units exceed the minimum by 10% in schemes of ten or more, private and communal amenity including play, storage inside and outside each unit, and the aspect and, for single-aspect units, the orientation of every unit. Drawings are to show the principal dimensions and area of every room. A costed building lifecycle report is expected, and conditions requiring compliance with the Multi-Unit Developments Act 2011, an owners' management company and a sinking fund are recommended. Daylight is referred out to section 5.3.7 of the 2024 settlement guidelines.
Three things stand out. First, the Statement would convert what were arguable guidelines into national policy that development plans must match within two months, and the draft applies it to applications already in the system on the day it issues. Anyone with an apartment application lodged this autumn should plan on the basis that it is likely to be decided under the Statement and should check the schedule in Chapter 7 now. The planning authority can confirm how it is applying the Statement to a particular file.
Second, the 0.25 hectare infill relaxations, taken together, amount in our view to a different regime for small urban sites. They are discretionary, so the quality of the design case is likely to decide whether the discretion is exercised, but the direction appears to favour the building owner over the objector.
Third, the relationship with development plans is not fully worked out. NPPM 6 stops threshold-based demands for community facilities; it does not obviously stop a quantified play-space objective, and the courts have recently shown what an unidentified contravention of one of those costs. The Department could settle this in the final text with a sentence. That is the submission we would make.
For the alteration route the Planning and Development (Amendment) Act 2026 opened for uncommenced apartment permissions, and how it interacts with these standards, see our comparison of the Acts.
Submissions go by email to nrupconsultation@housing.gov.ie or by post to National Strategic Planning, Department of Housing, Local Government and Heritage, Custom House, Dublin 1, D01 W6X0, by 5.30pm on 12 October 2026. A submission should cite the NPPM or section number it addresses, say what should change and why, and give evidence where it exists; the Department publishes submissions, so anything personal or commercially sensitive should be left out. The practice can prepare a submission for a scheme, a site or a representative body.
Please note. General information only, not legal or planning advice. Much of this is new legislation that has not yet been tested and could be subject to challenge, amendment or further regulation. For a definitive answer on a particular property or application, engage with the relevant planning authority.
The amended draft Statement of 4 September 2026 proposes, in NPPM 2: studio 32 m², one-bed 45 m², two-bed three-person 63 m², two-bed four-person 73 m², three-bed four-person 76 m² and three-bed five-person 90 m², measured internally. The draft would prevent development plans setting higher minimums. It is a consultation draft and the final text may differ.
The draft proposes at least 25% of units in NPPM 3, with plans unable to require more. For refurbishment schemes and urban infill sites of up to 0.25 ha the draft would let the planning authority accept less.
2.7 m at ground floor in NPPM 4. Above ground floor the draft points to the 2.4 m in Technical Guidance Document F.
The draft says it applies to any application determined after it issues. On that wording, a scheme lodged under the 2025 guidelines but decided after the Statement issues would likely be assessed under the Statement. The planning authority is the place to confirm how it is applying it to a particular file.
Generally not, under the draft NPPM 1, except for social housing, Part V housing and older persons' schemes where a Housing Need and Demand Assessment supports a mix.
The draft gives the planning authority discretion, for refurbishment on sites of any size and urban infill on sites of up to 0.25 ha, to relax dual aspect, the ground-floor height, storage and amenity space, subject to design quality. Whether that discretion is used on a given scheme is for the authority.
The draft keeps a presumption against shared accommodation and co-living in NPPM 7, unless the planning authority has identified a specific demand through a Housing Need and Demand Assessment.
In NPPM 8, a single study bedroom of 8 m² without an en-suite and 11.5 m² with one, with shared living space of 3.6 m² per person for ten and 3.3 m² per person for twelve.
This is uncertain. Until Part 4 commences, the 2000 Act (section 34(2)(ba)) applies a national requirement in place of a conflicting plan provision; section 86 of the 2024 Act, which replaces it, does not appear to contain an equivalent. On our reading, a scheme that meets an NPPM but conflicts with a surviving plan standard could be treated as a material contravention until plans are brought into line. This is new legislation, it has not been tested, and the planning authority's view on a particular application should be sought.
The Department's notice gives 5.30pm on 12 October 2026, by email to nrupconsultation@housing.gov.ie or by post to National Strategic Planning, Department of Housing, Local Government and Heritage, Custom House, Dublin 1, D01 W6X0.
The practice advises developers, funders and public bodies on how the amended apartment standards bear on schemes in preparation and on permissions not yet built.