• Home / Insight / Environmental Audit Committee Report on Flood Resilience

    Environmental Audit Committee Report on Flood Resilience

    17/10/2025

    The Environmental Audit Committee (EAC) has published its Fourth Report on Flood Resilience in England, setting out a series of urgent recommendations to strengthen the nation’s response to increasing flood risks driven by extreme weather, urbanisation, and climate change.

    While the report spans a broad range of issues – from agricultural land use to governance reform – this alert focuses on three areas of particular relevance to the insurance sector and its customers:

    • Housing development and planning reform
    • Sustainable Drainage Systems (SuDS)
    • The role of insurance in future flood resilience

    The publication also comes ahead of the imminent release of Professor Bonfield’s follow-up report ‘Floodproof: An Action Plan to Build Resilience’, which will assess progress since his original 2016 action plan and propose a new roadmap for government and industry.

    1. Housing Development and Planning: “Building Risk into the Landscape”

    The Committee’s report echoes the concerns raised in our earlier paper to parliament about the government’s ambition to build 1.5 million new homes and the associated flood risk.

    The EAC concludes that the planning system “is not keeping pace with the modern realities of flooding”, with development continuing in areas of known flood risk. It warns that “development should not be permitted in areas known to be at high risk of flooding” and calls for flood risk to be treated as a strategic constraint within the National Planning Policy Framework.

    The Committee recommends that:

    • By end-2025, the government should consult on statutory requirements for assessing the cumulative impact of development on flood risk, to be implemented by 2027.
    • Water companies should become statutory consultees on major planning applications.
    • Stronger compliance and enforcement mechanisms should be introduced for Flood Risk Assessments, including post-construction inspections to ensure mitigation measures are delivered in practice.
    • These recommendations directly align with insurer concerns that current planning policy is embedding risk rather than resilience – a concern we have previously highlighted in relation to ‘grey belt’ and marginal development sites where drainage and utility capacity are already under strain.

     

    2. Sustainable Urban Drainage Systems (SuDS): A Long Overdue Step Forward

    The Committee has sent a clear message to government:

    “The Government should now commence Schedule 3 of the Flood and Water Management Act 2010 without further delay, making SuDS mandatory in all new developments.”

    Despite repeated commitments, Schedule 3 remains unimplemented, leaving SuDS optional and inconsistently applied. Witnesses to the inquiry described this as a “critical missed opportunity” to embed resilience at the design stage.

    This reinforces our clients’ long-standing position that SuDS are essential for managing surface water flooding, which affects an estimated 4.6 million homes in England. Without mandatory implementation, new housing developments risk worsening flood vulnerability and driving future insurance claims.

    The EAC also calls for better integration between planning policy, flood management, and sewerage infrastructure, and urges government to ensure that by 2027, surface water flood risk is “consistently quantified and fully integrated into national flood risk assessments.”

     

    3. The Role of Insurance: Securing a Fair and Sustainable Future

    The Committee dedicates a full section of its report to the role of insurance, describing it as a “cornerstone of household and market stability.”

    Key findings include:

    • Flood Re’s success and limitations: While the scheme has reduced average premiums from £4,500 to £1,100 and increased coverage, it excludes homes built after 2009 and commercial properties. Evidence suggests many post-2009 homes have still been built in flood-prone areas, undermining the assumption that newer housing is low risk.
    • Insurance gaps: Around one in eight UK households – particularly renters, leaseholders, and low-income families – remain uninsured or underinsured against flood risk.
    • Future of the market: Flood Re is due to end in 2039, yet flood risk will remain high. Without reform, properties in flood-prone areas risk becoming uninsurable and unmortgageable, threatening both community resilience and market stability.
    • Flood Performance Certificates (FPCs): The Committee supports piloting FPCs, modelled on EPCs, to provide transparent property-level flood resilience ratings. This could support insurer pricing, inform consumers, and incentivise property-level resilience measures.

    The Committee recommends:

    • Government to begin work on a ‘Flood Re 2.0’ model, recognising resilience measures and supporting low-income households.
    • Consultation by end-2025 on strengthening the role of insurance in national flood resilience.
    • Support for piloting Flood Performance Certificates, initially on a voluntary basis, subsidised for low-income households.

    These recommendations point toward a more integrated approach linking insurance, mortgage lending, and resilience investment – and suggest that insurers will play an increasingly strategic role in shaping future flood adaptation policy.

    4. Next Steps and Outlook

    The EAC’s report marks a significant milestone in the national conversation on flood resilience. Its recommendations – particularly the urgent call to commence Schedule 3 and the emphasis on planning reform – reflect issues long raised by the insurance industry.

    With the Bonfield ‘Floodproof’ report due shortly, further guidance is expected on how public and private stakeholders can collaborate to close the resilience gap, including practical steps for property-level protection and community-scale adaptation.

    We will continue to monitor these developments closely and look to further engage with policymakers to ensure that future housing, infrastructure, and insurance frameworks are aligned with long-term flood resilience objectives.

     

    For further information please contact:

    Natalie Larnder - Partner and Head of Market Affairs

    NLarnder@keoghs.co.uk

     

    Matthew Rogers - Partner and Head of Property Risks & Coverage

    mrogers@keoghs.co.uk

     

    Natalie Larnder
    Author

    Natalie Larnder
    Partner and Head of Market Affairs

    Contact

    Related Insights

    New Build Flooding

    Planning reform and flood risk – a growing area of focus in Westminster

    Flooding Risks

    Flooding risks and housing growth

    Parliamentary debate on flooding and planning: implications for new developments and insurers

    Stay informed with Keoghs

    Sign-up

    Our Expertise

    Vr

    Claims Technology Solutions

    Disrupting claims management with innovation & technology

     

    The service you deliver is integral to the success of your business. With the right technology, we can help you to heighten your customer experience, improve underwriting performance, and streamline processes.