On 30 September, UIPI provided input to the European Commission’s Call for Evidence on Housing Supply and Affordability (Regulatory Simplification), contributing to the preparation of the forthcoming Housing Simplification Package. UIPI strongly supports the Commission’s objective of identifying unnecessary regulatory burdens, reducing delays and costs, and facilitating the provision and renovation of housing across Europe. As individual homeowners, co-owners and private landlords invest in, maintain, renovate and provide a substantial share of Europe’s existing housing stock, ensuring that regulation is workable for property owners is essential to achieving Europe’s housing, affordability and sustainability objectives.
The Housing Simplification Package represents an important opportunity to examine not only individual regulatory requirements, but also their cumulative impact on those who build, own, renovate and provide housing. Simplification should not come at the expense of Europe’s environmental, climate, safety or social objectives, but should ensure that these objectives are pursued through rules that are proportionate, coherent, predictable, economically feasible and workable in practice.
In particular, UIPI urged that:
- The Commission should assess the cumulative impact of EU legislation on housing, looking horizontally across regulatory frameworks and avoiding duplicated assessments, reporting requirements and information requests. Particular attention should be paid to individual and small-scale property owners, who have significantly less administrative capacity than institutional actors.
- Permitting procedures should become faster, more predictable and less duplicative, including through defined timelines, early scoping, standardised documentation and coordinated or single-window procedures, while respecting national and local competences.
- Housing supply, urban densification and nature-protection objectives should be better reconciled, with proportionate requirements, clear thresholds and predictable derogation and compensation mechanisms that allow renovation, urban infill and additional housing supply while safeguarding environmental objectives.
- Land and soil policies should enable housing supply, notably by facilitating and financing brownfield regeneration, rather than restricting greenfield development without ensuring that economically viable alternatives are available
- The renovation framework, including implementation of the Energy Performance of Buildings Directive (EPBD), should be simpler and economically feasible, with proportionate requirements, sufficient implementation periods, simpler administrative processes, legal and technical clarity, and stable financing. The objective should be to accelerate renovation rather than discourage investment through excessive complexity, cost or uncertainty.
- The EU should help reduce construction costs through standardisation, innovation and a better-functioning Single Market, facilitating modern construction methods, prefabrication and reused or recycled construction products, while improving interoperability and avoiding repeated submission of the same regulatory information.
- The sustainable-finance framework should better support smaller renovation projects, with simpler DNSH criteria, proportionate verification and reporting requirements, recognition of existing national documentation, and greater alignment between the EPBD, EU Taxonomy and related sustainable-finance rules.
- The Commission should examine how prudential banking rules affect access to housing finance, including the impact of CRR III and the output floor on mortgage lending capacity and borrowing costs for households.
- Finally, the Commission should introduce a systematic “housing check” in EU policymaking, assessing the impact of new and revised EU legislation on housing supply, renovation costs and investment, while involving the full diversity of housing-sector stakeholders in that assessment.
Ultimately, UIPI stressed that Europe’s housing challenge requires both more homes and better use of the homes Europe already has. Regulatory simplification should therefore facilitate new construction while making it easier and more economically viable to renovate, adapt, densify, reuse and preserve Europe’s existing building stock.
