Comparative Analysis of Legal Frameworks and Reform in Global Urban Planning Systems: Insights from ‘Planning Regulation-Constrained’ and ‘Development Order-Guided’ Models in the Stock Era

Abstract

This study examines global urban planning systems through a comparative analysis of two governance models: the Planning Regulation-Constrained (Germany, USA, Japan) and Development Order-Guided (UK, Singapore, Hong Kong SAR) approaches. Focusing on six jurisdictions—Germany, USA, UK, Hong Kong SAR, Japan, Singapore—it analyzes their legal frameworks, regulatory tools, and approval mechanisms to assess efficacy in the era of urban stock optimization. Findings reveal inherent tensions between the two models: rigid rules ensure certainty but hinder adaptation, while discretionary systems offer flexibility but risk fairness deficits. Hybridization emerges as imperative, blending as-of-right permissions with contextual discretion. For China’s dual system, reforms are proposed—multi-tiered laws, dynamic use packages, streamlined approvals, and collaborative governance—to balance public interest and market dynamism for sustainable urban regeneration.