New-build properties in England have no standardised mechanism to verify or record flood resilience measures. A new study finds that insurers cannot currently distinguish between flood-resilient new builds and those that were not built to that standard.
Ardent Consulting Engineers, commissioned by Flood Re, examined five recent housing developments and interviewed practitioners across planning, development, flood risk, and insurance. The study found that the planning system generally delivers flood resilience where specified, but conditions attached to approvals are often vague. Property flood resilience (PFR) is rarely mandated by building regulations and carries no post-planning mechanism to confirm implementation.
The research proposes a framework for Flood Performance Certificates (FPCs) in new-build housing. FPCs would function similarly to Energy Performance Certificates. Each would provide a formal, property-level record of flood resilience that could be transferred at sale or referenced at underwriting.
The core problem identified by Ardent is documentary. Once a development is complete, no systemic process confirms whether approved flood mitigation measures were actually installed. Without a verified record, insurers have no basis to price resilience into premiums or reward investment in flood protection.
The Environment Agency estimates 6.3 million homes in England now face flood risk, up from 5.5 million in 2018. Aviva's analysis found that 11% of homes built between 2022 and 2024 are already at flood risk, projected to reach 15% by 2050. Those properties fall outside Flood Re, which excludes homes built after January 2009.
The Association of British Insurers (ABI) has repeatedly called for tighter links between planning policy and flood-risk assessment. Its position is that new housing in flood-prone areas must be matched by mandatory resilience measures.
FPCs would address the gap through a post-construction verification stage carried out by independent accredited professionals. Developers would submit as-built information for review by those professionals. A verification report would then inform the FPC.
Authorities would be limited to confirming submission of evidence within existing frameworks, with no new regulatory body required. Ardent said the process would not introduce new design requirements or alter planning policy. The framework would also align with emerging proposals for digital property logbooks and provide a durable mechanism to store and transfer verified resilience data.
Flood Re is planning a discounted premium structure by 2028 that would allow insurers to recognise and credit FPC-verified properties. FPC pilots are expected to start by the end of 2026, with new builds identified as a subsequent deployment. The scheme is scheduled to exit the market in 2039, when flood cover returns to risk-based pricing.
A 2025 review led by Emma Howard Boyd, former Environment Agency chair, warned annual flood damage could reach £2.4 billion without reform. That figure reinforces why insurers need property-level evidence well before Flood Re's exit.
Jonathan Kassian, head of flood resilience at Flood Re, said the framework would "provide a clear, standardised and transferable record for householders, insurers, lenders and other stakeholders."
Brian Cafferkey, director at Ardent, said FPCs would create a trusted record of as-built resilience data. He said the approach would improve transparency and strengthen confidence for homeowners, insurers and lenders.
National policy requires flood-resilient development, but local planning authorities apply the guidance inconsistently. No durable property-level record exists once construction is complete. FPCs would create that record at the point of occupation, sale or underwriting.
