The Shift welcomes the European Commission’s publication of the first-ever European Affordable Housing Plan (EAHP). This landmark initiative signals that the EU recognises housing as more than a market commodity and is, as the Plan states, “a fundamental right and a cornerstone of human dignity.” The appointment of the EU’s first Commissioner for Energy and Housing, Dan Jorgensen, created a vital opportunity to address the housing crisis across Europe, and this Plan represents an important step toward fulfilling that mandate.
Housing costs overburden 80 million Europeans, and homelessness has increased significantly over the past decade. The financialization of housing, wherein residential real estate is treated primarily as a vehicle for wealth accumulation rather than as homes, has contributed significantly to this crisis, driving unaffordability and displacement across the continent.
While the EAHP recognizes the impact of financialization on housing and suggests actions to address speculation, clearer limitations on housing investment are needed in Europe, and the Plan represents an unmissable opportunity.
This analysis evaluates the EAHP against human rights standards, including The Shift Directives, which provide a comprehensive framework for governments and investors to transition toward housing systems that uphold the right to adequate housing. We examine the Plan, identify areas of alignment and propose recommendations to strengthen the Plan’s Actions.
The Right to Adequate Housing and the Human Rights Framework
The EAHP’s explicit recognition that housing is not just a commodity, but a fundamental right represents a significant rhetorical shift in EU policy. To move beyond rhetoric, the Plan should more explicitly reference the standards that attach to the human right to adequate housing under international law. These standards provide concrete benchmarks against which policies can be assessed. States and investors have responsibilities and legal obligations to respect, protect, and fulfil the right to housing; the Plan would benefit from explicitly anchoring its actions in these binding commitments.
Social and Affordable Housing Expansion
Revision of State aid rules to facilitate support for affordable housing beyond the most disadvantaged groups is welcome. Extending support to low- and middle-income households responds to the reality that the housing crisis now affects a broader segment of society. However, we emphasize that affordability must be defined in relation to household incomes, not market rates, to ensure housing is truly affordable for all population groups, including homeless people. Housing ecosystems must reflect social realities across the entire income spectrum, ensuring that social and affordable housing is available to all who need it.
Housing Stressed Areas and Short-Term Rentals
We strongly welcome the Plan’s introduction of a framework to identify “areas of housing stress” and enable targeted interventions. This evidence-based approach, using publicly available data to determine where housing pressures are most acute, provides local authorities with the tools to implement proportionate measures, including rent caps. The proposed legislative initiative on short-term rentals (STRs), to be delivered as part of an Affordable Housing Act, is a positive development. STRs have impacted housing availability and affordability across European cities. We welcome the commitment to provide legal certainty for public authorities to manage STRs, particularly in housing-stressed areas.
Affordable housing within planetary boundaries
The EAHP’s focus on increasing housing supply, while understandable, risks missing the structural causes of the crisis. Unregulated supply increases often benefit investors who construct what is profitable rather than what is needed, rarely addressing the housing needs of low-income communities. This supply-driven approach also carries significant climate implications: construction accounts for up to 70% of total emissions over a building’s lifecycle, and embodied carbon from now until 2050 will far outpace operational emissions. We urge the Commission to complement supply measures with robust demand-side interventions and regulations that ensure new housing genuinely meets social and environmental need.
The Plan’s emphasis on combining affordability with sustainability represents sound policy. The focus on renovation over demolition and energy efficiency aligns with both planet boundaries and human rights standards. We welcome the attention to mobilizing vacant properties and repurposing existing buildings, which optimizes the built environment without additional carbon emissions from new construction. The Plan also encourages the prioritization of renovation and repurposing of existing buildings, while avoiding unnecessary demolitions. However, enforceable funding requirements tied to sustainable housing criteria would ensure compliance with EU climate goals. Funded new builds should be limited to high energy efficiency (EE) standards, and retrofits should imply minimum EE increases.
Tenant Protections and Vulnerable Groups
The EAHP focus on addressing homelessness and supporting vulnerable tenants through a proposed Council recommendation on fighting housing exclusion and housing-led solutions represents positive steps. We also note positively the Plan’s references to ensuring renovations do not increase housing costs for tenants, a concern consistently raised by tenant organizations. Similarly, attention to housing for young people and students addresses an emerging area of financialization.
However, the Plan’s approach to tenant protections remains insufficient. It proposes to “identify models and share good practices combining the protection of property rights of owners with tenant security”, a framing that prioritizes balancing interests rather than increasing tenant protections. The Plan’s reliance on addressing low housing supply with blended finance requires strong social and environmental conditionalities to ensure long-term affordability and avoid speculation, including long-term holding periods of social and affordable housing qualification and open-ended rental contracts.
Deregulation Concerns
The Plan’s focus on “cutting red tape” and simplifying regulations raises significant concerns. While administrative efficiency is desirable, inadequate regulation has contributed substantially to the current crisis. The Plan’s framing of rules as impediments to housing supply risks undermining protections that serve vital social, environmental, and safety functions. We caution against deregulation that could weaken tenant protections, environmental standards, or quality requirements.
Taxation: a missed opportunity
The Plan frames taxation primarily as a cost burden, stating that “taxes are a major component of housing costs, including during purchase.” This framing suggests that reducing taxes would improve affordability, rather than recognizing taxation’s essential role in discouraging speculative behavior and generating revenue for social housing. While the plan encourages Member States to design effective taxation policies, it does not address the preferential tax treatment enjoyed by REITs and other institutional investors, nor does it suggest vacancy taxation.
Addressing Financialization and Speculation: Investment Framework and Human Rights Conditionalities
The Plan’s commitment to analyze speculation and housing price dynamics and promote market transparency is welcome, but requires further binding norms. To genuinely address speculative behavior, the Commission must move beyond analysis and peer-learning toward mandatory requirements.
We welcome the increased financial commitments outlined in Pillar II—including EUR 43 billion in housing-related investment under the current MFF and the commitment by national promotional banks to invest EUR 375 billion by 2029. However, the described mobilization of private investment requires further human rights and environmental conditionalities.
Under international human rights law, States have obligations to regulate the real estate market and financial actors to ensure the right to adequate housing. All housing investment, public and private, should be accompanied by mandatory social and environmental conditionalities ensuring affordability linked to household income; security of tenure; protection against displacement; and sustainability requirements aligned with climate targets.
In terms of transparency, fund recipients receiving EU or EIB funding must be required to disclose annually information relating to the homes that have been supported by that funding:
- Number and type of units built with that funding: size, number of bedrooms, and affordability and tenure mix (social rent / affordable rent / private ownership)
- Energy Efficiency rating mix (EPC standards)
- Occupancy and vacancy rates
- Median and mean rents
- Median and mean sale values for homeownership
Enforceable requirements tied to social and affordable housing funding allocation are needed. Specifically, where projects receive EU or EIB funding, social conditionalities should apply:
- For social housing, public housing, collective/community, or affordable housing projects, tenure should be guaranteed in perpetuity, or for a minimum of 70 years
- Where homes are rented, works must minimize displacement of residents; if temporary displacement is unavoidable, residents must be offered a right of first refusal to return upon completion, with comparable rehousing provided during works
- Rental contracts after completion must be long-term; at minimum, two years longer than the standard contract duration in the relevant country.
- Projects must also ensure tenant cost neutrality, meaning rent increases should be limited to the projected savings on energy bills resulting from efficiency improvements, as assessed by an independent body
- Where homes are owner-occupied, they cannot be resold or converted into rental properties for ten years after the last receipt of EU or EIB funding.
We note that the Plan proposes a voluntary, market-led investment framework. Given States’ human rights obligations and investors’ responsibilities under the UN Guiding Principles on Business and Human Rights, human rights investment frameworks should be mandatory. The Shift offers to collaborate with the Commission, the European Investment Bank and other relevant EU agencies in developing both the Pan-European Investment Platform and the investment framework to ensure they incorporate human rights standards that deliver genuine affordability and security in the long term.
Conclusion
The European Affordable Housing Plan represents a meaningful acknowledgement that Europe’s housing crisis demands coordinated action. Its recognition of housing as a fundamental right, attention to housing stressed areas, and commitment to regulating short-term rentals align with key elements of a human rights-based approach.
However, to deliver lasting change, the Plan must be strengthened in several critical areas. Its approach to taxation represents a missed opportunity to address structural drivers of unaffordability, and the focus on “cutting red tape” risks undermining vital protections. Furthermore, the reliance on voluntary investment frameworks without social and environmental conditionalities creates a risk that resources are used without guaranteeing long-term affordability or protecting the most vulnerable.
The Shift stands ready to work constructively with the European Commission, the EIB and relevant agencies. We offer our expertise in developing the human rights conditionalities necessary to make the Plan’s ambitious goals a reality for the millions of Europeans struggling to find a decent, affordable home.
