Housing simplification package

225 submissions in the snapshot (185 from organisations), portal total 225. Feedback list on the portal.

185 of 185 organisation submissions analysed; the model reads them as: opposes 4 supports 47 wants changes 100 34 held back for review (low confidence).

• Micro company, PRT Company, PRT model reads as: supports source
  • Support the European Commission in simplifying regulations regarding housing development.

    I welcome the European Commissions effort to simplify the rules around housing development.

• AIPI Associazione Italiana Professionisti Interior Designers NGO, ITA model reads as: supports source
  • Allow qualified professionals recognised under Italian Law No. 4/2013 to sign and submit CILA and SCIA procedures for non-structural interior works.

    allow qualified professionals recognised under Italian Law No. 4/2013, acting within their legally recognised competences, to sign and submit CILA and SCIA procedures relating exclusively to non-structural interior works;

  • Require municipal digital planning platforms to include all legally recognised professional categories.

    require municipal digital planning platforms to include all legally recognised professional categories through dedicated fields for "other technical professionals";

  • Apply the principle of proportionality when defining professional eligibility requirements for public procurement.

    apply the principle of proportionality when defining professional eligibility requirements for public procurement, avoiding unnecessary restrictions based solely on membership of regulated professional bodies;

• Embuild Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Merge the SEA and EIA Directives and reinstate exemptions for smaller projects.

    Embuild calls for legally reinstating exemptions for smaller projects. Specific simplification suggestions: a. Merge the SEA and EIA Directives.

  • Introduce exemptions for housing construction and limit the non-deterioration principle under the Nature Restoration Law.

    Specific simplification suggestions: a. Introduce exemptions for housing construction. Review implementation to ensure flexibility for national spatial-planning specificities.

  • Add a housing exemption to the land-take Article for high-demand areas under the Soil Monitoring Law.

    b. Add a housing exemption to the land-take Article for high-demand areas.

• Micro company, NLD Company, NLD model reads as: wants changes source
  • Promote structured digital building permit submissions based on open, machine-interpretable standards like IFC.

    promoting structured digital building permit submissions based on open, machine-interpretable standards (e.g. IFC and related open interoperability standards), rather than document-based PDF submissions;

  • Apply the once-only principle to enable secure reuse of information throughout the permitting process across competent authorities.

    applying the once-only principle, enabling information submitted by applicants to be securely reused throughout the permitting process and across competent authorities instead of being repeatedly recreated or resubmitted;

  • Support a common European framework for digital building permitting based on interoperable data standards and reference architectures.

    support a common European framework for digital building permitting based on interoperable data standards, reference architectures and the exchange of implementation experience.

• SNPI Business association, FRA model reads as: wants changes source
  • Adopt an approach based on actual carbon emissions and cost efficiency rather than automatic rental bans tied to energy performance classes.

    favouring an approach based on actual carbon emissions and cost-efficiency of the works rather than an automatic ban on renting linked to a DPE class;

    machine translation by the Commission, original in FR
  • Better integrate summer comfort and heatwave resilience into housing performance assessment criteria.

    better integrate summer comfort and heatwave resilience into housing performance assessment criteria;

    machine translation by the Commission, original in FR
  • Strengthen financial support schemes to make renovations truly sustainable for owners.

    strengthen financial support schemes to make renovations truly sustainable for owners;

    machine translation by the Commission, original in FR
• Micro company, MKD Academic or research institution, MKD model reads as: wants changes source
  • Distinguish between regulatory obligations from EU law and national implementation during impact assessments to address gold-plating.

    Consequently, distinguishing between regulatory obligations originating from EU law and those resulting from national implementation ("gold-plating") should become a central element of the impact assessment.

  • Establish fully integrated digital permitting systems based on the once-only principle to streamline administrative processes.

    One of the most effective simplification measures would be the establishment of fully integrated digital permitting systems based on the "once-only" principle.

  • Ensure regulatory frameworks actively facilitate the deployment of modern construction methods and innovative technologies.

    Regulatory frameworks should actively facilitate rather than unintentionally hinder the deployment of these technologies.

• Micro company, GBR Company, GBR model reads as: wants changes source
  • Anchor the global distribution ledger directly into physical server silicon at logistics and border-clearance hubs to prevent supply chain subversion.

    Anchors the global distribution ledger directly into physical server silicon at logistics and border-clearance hubs.

  • Implement Veritas Core PCIe hardware interposers directly inside public sector procurement servers to isolate the database layer from the vulnerable host operating system.

    Implement Veritas Core PCIe hardware interposers directly inside public sector procurement servers, the database layer is mechanically isolated from the vulnerable host operating system.

  • Lock edge-sensor telemetry data straight into the bare-metal hardware to prevent digital greenwashing and metric spoofing for building performance reporting.

    Locks edge-sensor telemetry data straight into the bare-metal hardware.

• Micro company, ISR Company, ISR model reads as: wants changes source
  • Unblock harmonised standards and establish an EU type-approval route for repeatable modular and offsite construction systems.

    Unblock harmonised standards and create an EU type-approval route for repeatable modular/offsite systems ("approve once, build across Member States"), leveraging the harmonised Eurocodes.

  • Build a single interoperable buildings data layer to enable once-only reporting across different EU directives.

    Build ONE interoperable buildings data layer aligning the CPR Digital Product Passport, EPBD EPC/renovation passport and e-permitting on open standards (IFC/BIM, GIS) for "once-only" reporting.

  • Issue harmonised EU end-of-waste criteria and a proportionate conformity route for reused and innovative products.

    Issue harmonised EU end-of-waste criteria and a proportionate conformity route for reused and low-volume innovative products.

• Micro company, BEL NGO, BEL model reads as: wants changes source
  • The EU should encourage Member States to better coordinate planning, housing and energy regulations while ensuring proportionality.

    The EU should encourage Member States to better coordinate planning, housing and energy regulations, while allowing proportionate requirements for the renovation and conversion of existing buildings, without compromising safety, accessibility, health or energy performance.

  • Apply simpler permitting procedures to low-impact renovation works and affordable housing projects while encouraging adaptive reuse.

    Simpler procedures should apply to low-impact renovation works and to projects delivering affordable housing. Greater emphasis should also be placed on the reuse of vacant buildings, particularly offices.

  • Improve fiscal coherence by addressing VAT rules to support affordable housing and renovation projects.

    The Commission should examine how VAT rules could better support affordable housing by ensuring greater consistency for renovation projects and by reducing VAT-related disincentives affecting the conversion or demolition-reconstruction of vacant buildings, particularly offices, into affordable housing.

• Micro company, GRC NGO, GRC model reads as: wants changes source
  • Ensure the simplification initiative explicitly supports cooperative, community-led and non-profit social housing models.

    Simplification should explicitly facilitate cooperative, community-led and non-profit social housing models.

  • Distinguish between administrative barriers and structural drivers of housing unaffordability in the impact assessment.

    The impact assessment should distinguish clearly between barriers affecting housing production and the broader structural drivers of housing unaffordability, including land values, financialisation, speculative investment, and unequal socioeconomic access to housing.

  • Maintain regulatory protections, social safeguards, and mechanisms that secure affordability and inclusion for vulnerable groups.

    Mechanisms that secure affordability, inclusion, and protection for those most vulnerable to housing insecurity should be maintained.

• PIMEC Business association, ESP; register: Trade and business associations model reads as: wants changes source
  • Amend the Services Directive 2006/123 to set a strict 3-month deadline for housing construction and renovation licenses.

    Licenses for housing construction and renovation should not take more than 3 months, including all permits and formalities.

  • Apply positive administrative silence within 3 months for small housing projects and changes of use up to 10 housing units.

    Licenses for small housing projects of up to 5 million in budget, such as renovating an existing housing bloc, shall be subject to positive administrative silence in 3 months, so that works can resume thereafter.

  • Cap national, regional, and local licensing fees and taxes at 5 percent of the total housing project budget.

    National, regional and local authorities shall not levy licensing fees or taxes of more than 5% of the housing project budget.

• VinylPlus Business association, BEL model reads as: wants changes source
  • Align the Construction Products Regulation, Energy Performance of Buildings Directive, Energy Efficiency Directive, Waste Framework Directive, and REACH Regulation to eliminate duplication and conflicting requirements.

    Align the Construction Products Regulation (CPR), the Energy Performance of Buildings Directive (EPBD), the Energy Efficiency Directive (EED), and the Waste Framework Directive (WFD) and the REACH Regulation to eliminate duplication and conflicting requirements.

  • Accelerate the development of harmonized standards under the Construction Products Regulation and ensure the Declaration of Performance and Conformity serves as a common source of information.

    Accelerate the development of harmonized standards under CPR and ensure that the new Declaration of Performance and Conformity (DoPC) can serve as a common source of information for building-level assessments, public procurement and financing decisions.

  • Establish EU-wide end-of-waste criteria for construction-derived materials and clarify the interface between chemicals and waste legislation.

    Establish EU-wide end-of-waste criteria for construction-derived materials and clarify the interface between chemicals and waste legislation.

• Council of Gas Detection and Environmental Monitoring Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Do not weaken health, indoor environmental quality, or domestic life safety standards during regulatory simplification.

    We urge the European Commission, EU policymakers and the Member States not to weaken health/indoor environmental quality and domestic 'life safety' standards (fire, carbon monoxide, gas and electrical safety) as part of these regulatory simplification efforts.

  • Ensure that housing supply and affordability initiatives do not compromise essential safety standards.

    Housing supply and affordability should not compromise such critical standards.

• The National Real Estate Stock (Krajowy Zasób Nieruchomości) Public authority, POL model reads as: wants changes source
  • Coordinate the full investment process through binding deadlines, parallel approvals, digital monitoring, and a single coordinator.

    Binding deadlines, the possibility of conducting consultations and approvals in parallel, digital monitoring of cases and a single coordinator for larger investments are needed.

  • Introduce a fast-track procedure for social and affordable housing and exempt projects from parking requirements when served by public transport.

    We call for a departure from parking requirements where the investor demonstrates that residents can be served by existing public transport or by public transport planned to be available by the time the development is put into use.

  • Simplify financing and state aid rules to enable combining public land, grants, loans, and infrastructure funding.

    Municipalities, Social Housing Initiatives and other public entities need clear and replicable rules for combining public land, grants, preferential loans and infrastructure financing.

• Fire Safe Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Integrate fire and life safety into planning, permitting, and digital systems from the start.

    Build simplification on a safe-by-design approach, integrating fire and life safety into planning, permitting and digital systems from the outset;

  • Exclude fire and life safety checks from positive administrative silence mechanisms.

    Exclude essential fire and life safety verifications from automatic approval mechanisms;

  • Strengthen EU-level coordination and guidance on fire and life safety interpretations.

    Strengthen EU coordination on the interpretation of fire and life safety requirements;

• Plastics Europe Business association, BEL; register: Trade and business associations model reads as: supports source
  • Establish a coherent and technology-neutral framework that eliminates national over-regulation.

    To accelerate this transition, the EU must establish a coherent, technology-neutral framework that eliminates national over-regulation and provides long-term investment certainty.

  • Streamline standardisation, harmonise digital product requirements, and introduce EU-wide End-of-Waste criteria for recycled plastics.

    This can be achieved by streamlining standardisation, harmonising digital product requirements to eliminate duplicative reporting for manufacturers, and creating harmonized EU-wide End-of-Waste criteria for recycled plastics.

• Polish Association of Developers Business association, POL; register: Trade and business associations model reads as: wants changes source
  • Develop a standard methodology to measure the real duration of housing permit procedures across prerequisite decisions.

    Develop a common methodology for measuring the real not statutory duration of permit-granting for housing, covering all prerequisite decisions, and link registers of key decisions (Outline Planning Permission, EIA Decision, Building Permit) to cadastral parcels.

  • Encourage enforceable time limits across the full permit-granting sequence.

    Encourage Member States to set measurable and enforceable time limits for the entire permit-granting chain, not only for the final decision, building on the approach taken for renewable energy permitting.

  • Review the application of discretion by Member States regarding EIA screening thresholds under Annex II of the EIA Directive.

    Review how Member States use their discretion under Annex II of the EIA Directive (2011/92/EU).

• European Network on Independent Living NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Maintain accessibility requirements across new construction and renovation projects.

    maintain accessibility requirements in new construction and renovation;

  • Prevent simplified planning and permitting procedures from bypassing accessibility safeguards.

    ensure that simplified planning and permitting procedures do not allow accessibility requirements to be bypassed, promote Universal Design as part of the standard approach to housing development;

  • Involve disabled persons and representative organisations when formulating measures that affect housing accessibility.

    involve disabled people and their representative organisations in the development of measures affecting housing accessibility.

• Austrian Federal Economic Chamber Business association, AUT; register: Other organisations, public or mixed entities model reads as: wants changes source
  • The simplification package must adopt a comprehensive, whole-system perspective rather than focusing solely on isolated procedural steps.

    Therefore, the simplification package must look at the whole system and not be limited to individual procedural steps.

    machine translation by the Commission, original in DE
  • Procedures should be accelerated and digitalised under the once-only principle alongside binding procedural deadlines.

    Compliance with the ‘once only’ principle: Data should be provided only once.

    machine translation by the Commission, original in DE
  • Renovation requirements should remain proportionate and avoid imposing excessive follow-up burdens that deter economically viable projects.

    The WKÖ calls for proportionate renovation requirements that do not prevent economically sensible renovations by imposing additional follow-up obligations.

    machine translation by the Commission, original in DE
• Austrian Federal Economic Chamber Business association, AUT; register: Other organisations, public or mixed entities model reads as: wants changes source
  • Implement digitalised procedures, one-stop-shops, realistic deadlines, and the once-only principle.

    Compliance with the ‘once only’ principle: Data should be provided only once. There are also digital, media-free procedures, one-stop-shops for permits and better coordination of construction, environmental, water and nature protection procedures.

    machine translation by the Commission, original in DE
  • Facilitate renovation and repurposing of existing buildings through proportionate requirements.

    The WKÖ calls for proportionate renovation requirements that do not prevent economically sensible renovations by imposing additional follow-up obligations.

    machine translation by the Commission, original in DE
  • Ensure climate and energy requirements are implemented in a cost-effective and technology-open manner with flexibilities.

    It therefore calls for technology-open, result-oriented solutions that take into account costs, technical feasibility and life-cycle impacts. Flexibilities should be possible, in particular for existing buildings and subsidised housing.

    machine translation by the Commission, original in DE
• Micro company, BEL Business association, BEL model reads as: wants changes source
  • Under the CRR, the Article 465 low-risk weighting should be made permanent and duplicate reporting channels consolidated.

    Proposal: make the Article 465 transitional low-risk weighting permanent EU-wide, integrate asset encumbrance into existing reports and consolidate redundant reporting channels.

  • Evidence requirements for renovation under the EU Taxonomy should be standardised and private customers exempted from minimum safeguards.

    Proposal: simplify and standardise evidence for renovations, accepting energy certificates, national certificates and funding decisions; exempt private customers from minimum safeguards or presume compliance; and distinguish private homes from developer projects for new builds, using proxy indicators and lighter DNSH checks for small measures.

  • A moratorium should be placed on new documentation obligations and existing reporting aligned with realistic timelines.

    Proposal: introduce new documentation duties only in justified exceptions, phase out equivalent existing requirements and align deadlines with actual implementation.

• City of Vienna Public authority, AUT model reads as: wants changes source
  • Focus on simplifying or improving existing EU legislation rather than creating new regulations in the housing sector.

    Instead, this initiative should focus on simplifying or improving existing EU legislation that is currently having a direct or indirect negative impact on the housing market.

  • Ensure the principle of subsidiarity is respected and that simplification does not weaken tenant protections or social standards.

    In any case, simplification must not compromise tenant protection and social standards.

  • Streamline administrative procedures and permitting while maintaining high environmental standards and preventing retroactive regulatory impacts on ongoing approvals.

    To reduce project delays in large-scale urban development, it is essential to streamline administrative procedures and permitting processes while maintaining high environmental standards and ensuring legal certainty to prevent new regulatory requirements from affecting ongoing approval procedures.

• European Network on Independent Living NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Ensure that administrative simplification does not come at the expense of housing accessibility requirements.

    However, the response stresses that simplification must not come at the expense of accessibility.

  • Do not treat accessibility safeguards as mere administrative burdens that can be removed in the name of efficiency.

    Accessibility requirements should not be regarded as administrative burdens that can simply be removed in the name of efficiency.

  • Prevent opportunities for accessibility requirements to be bypassed, weakened, or deprioritised through simplification.

    The response therefore argues that simplification must not create opportunities for accessibility requirements to be bypassed, weakened or deprioritised.

• City of Stockholm Public authority, SWE model reads as: wants changes source
  • Ensure new requirements do not apply retroactively to projects currently in planning or permitting.

    Across all files new requirements should not apply retroactively to projects already in planning or permitting, and the package should be build on the proposed regulation to accelerate environmental assessments to reduce duplicated assessments.

  • Allow flexible renovation trajectories under the EPBD that preserve existing structures and avoid applying new-build standards.

    Allow flexible renovation trajectories that preserve existing structures, avoid applying new-build standards to renovation and conversions and prioritise never-renovated buildings.

  • Clarify early how urban green space targets in the Nature Restoration Regulation interact with urban densification.

    Clarify early how urban green space targets relate to densification; in Stockholm nearly all infill sites contain some green feature.

• Bank Gospodarstwa Krajowego Other, POL; register: Other organisations, public or mixed entities model reads as: wants changes source
  • Include NPBIs as direct operators and distributors of EU funds dedicated to affordable housing.

    include NPBIs, particularly pillar-assessed ones, as direct operators/distributors of EU funds allocated to affordable housing,

  • Establish dedicated risk management rules for housing projects with favourable risk profiles under CRR III and Solvency II.

    establish dedicated risk managament rules for housing projects with favorable risk profile/sector track record under CRR III and Solvency II (details in EAPB position paper),

  • Simplify InvestEU appraisal and reporting processes.

    substantially simplify InvestEU appraisal and reporting,

• Association of German Public Insurers Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Ensure regulatory simplification does not compromise requirements essential for safety, prevention, and climate resilience.

    Simplification should follow a clear guiding principle: less bureaucracy and lower procedural costs without compromising the protective effect required for safety, prevention and climate resilience.

  • Incorporate natural hazard data into planning, site selection, and approval procedures at an early stage.

    Natural hazard information should be incorporated into planning, site selection and approval procedures at an early stage.

  • Make EU and national funding instruments available for prevention measures that strengthen resilience.

    Where necessary prevention measures require significant additional upfront investment, existing European and national funding and financing instruments should be specifically made available for measures that strengthen resilience.

• ANEC, the European consumer voice in standardisation Consumer organisation, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Ensure that simplification does not compromise consumer protection, safety, accessibility, housing quality, or environmental performance.

    However, simplification should not come at the expense of consumer protection, safety, accessibility, housing quality or environmental performance.

  • Assess housing affordability through long-term living costs, including energy bills and maintenance, rather than just purchase or rental costs.

    ANEC emphasises that housing affordability should be assessed not only through purchase and rental costs, but also through the long-term costs of living in a dwelling, including energy bills, maintenance and renovation costs.

  • Maintain essential safeguards relating to safety, accessibility, and building quality when reducing regulatory complexity.

    Regulatory simplification should focus on reducing complexity, fragmentation and duplication while maintaining essential safeguards relating to safety, accessibility and building quality.

• Europabüros der bayerischen und baden-württembergischen Kommunen im Namen der bayerischen und baden-württembergischen kommunalen Spitzen- und Landesverbände (Vertretung von mehr als 3000 Städten und Gemeinden, 106 Landkreisen, 7 bayerischen Bezirken) Public authority, DEU model reads as: supports source
  • The EU must strictly observe the principle of subsidiarity in housing policies.

    The EU must strictly respect the principle of subsidiarity.

    machine translation by the Commission, original in DE
  • EU housing policy should focus on relief measures and reducing hurdles stemming from EU legislation.

    From a local point of view, the EU’s housing policy should therefore be limited to relief measures and reduce existing hurdles arising from EU law.

    machine translation by the Commission, original in DE
• World Green Building Council NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Protect the Energy Performance of Buildings Directive and do not reopen it.

    Protect the EPBD and do not reopen it

  • Maintain focus on consistent national implementation of the EPBD across Member States.

    Continue to focus on consistent national EPBD implementation

  • Promote harmonisation of circularity rules through the upcoming Circular Economy Act.

    Drive harmonisation of circularity rules via the Circular Economy Act

• Micro company, BEL Business association, BEL model reads as: supports source
  • Clarify VAT rules, reduce administrative burdens, and facilitate reduced VAT rates for housing.

    The Commission should clarify it, reduce administrative burdens and facilitate existing flexibility, including reduced VAT rates for housing.

  • Assess cumulative regulatory burdens and eliminate overlapping procedures and duplicate reporting.

    The Package should assess their combined effect and eliminate overlapping procedures, duplicate reporting and inconsistent requirements.

  • Promote binding timelines, coordinated authorities, and digital procedures to accelerate permitting.

    Drawing on RED III, the EU should promote binding timelines, coordinated authorities, digital procedures and parallel assessments.

• Cassa Depositi e Prestiti Other, ITA; register: Other organisations, public or mixed entities model reads as: supports source
  • Establish a harmonised European framework, eligibility criteria, and reporting standards for affordable housing.

    establishing a harmonised European framework for affordable housing, eligibility criteria and reporting standards;

  • Promote integrated permitting procedures with coordinated assessments and a single administrative contact point.

    promoting integrated permitting procedures for affordable housing projects, with coordinated assessments by competent authorities and a single administrative point of contact that serves as a single interface between project promoters and the public administration;

  • Introduce regulatory and prudential incentives to mobilise institutional capital for affordable and social housing.

    introducing regulatory and prudential incentives to mobilise long-term institutional capital for affordable and social housing investments.

• Spanish National Markets and Competition Commission Public authority, ESP model reads as: supports source
  • Improve regulatory coordination among actors in the land transformation process and rationalise applicable rules.

    Improving the regulatory coordination among the various actors involved in the land transformation process, and rationalising the applicable rules, an idea aligned with the philosophy behind the European Housing Alliance and other European initiatives.

  • Promote greater supra-municipal territorial planning to prevent fragmentation and administrative inefficiencies.

    Promoting greater supra-municipal territorial planning, an area where the EU could be a leading inspiration to avoid fragmentation and possible inefficiencies in certain procedures.

  • Improve sectoral and environmental reports by ensuring proportionality, removing duplication, and applying positive administrative silence.

    Improving the functioning of sectoral and environmental reports, some of which are subject to European regulations. This could be achieved by ensuring their proportionality, avoiding unnecessary duplication, and replacing negative administrative silence with positive administrative silence wherever feasible.

• Fédération Française du Bâtiment Business association, FRA; register: Trade unions and professional associations model reads as: wants changes source
  • Reduce multiple regulatory constraints on the housing sector.

    the BTF has already called for the multiple constraints on the housing sector to be reduced.

    machine translation by the Commission, original in FR
  • Adopt targeted simplification measures across various EU directives and regulations without reopening complete revisions.

    In the attached annex, the BTF proposes a series of simplification measures targeted at different EU directives and regulations, without however calling for a complete revision of these texts.

    machine translation by the Commission, original in FR
  • Ensure consistency across EU regulations to avoid varying requirements and unnecessary administrative burdens.

    In addition, the FFB calls for a degree of consistency between several regulations in order to avoid varying requirements from one text to another, which leads to an additional administrative burden for companies that have to comply with them.

    machine translation by the Commission, original in FR
• Deutscher Landkreistag Other, DEU model reads as: wants changes source
  • Revise the requirements of the Habitats Directive to facilitate new housing creation and renovation.

    a revision of the requirements of the Habitats Directive is particularly necessary in order to enable the creation of new housing or the renovation of existing housing (see Annex).

    machine translation by the Commission, original in DE
  • Review the impacts of the Nature Restoration Regulation, the Energy Efficiency Directive, and the Energy Performance of Buildings Directive on housing delivery delays.

    In addition, there would be an urgent need to review the impact of the so-called Restoration Regulation, but also of the Energy Efficiency Directive (EED) and the Energy Performance of Buildings (EPBD).

    machine translation by the Commission, original in DE
• Österreichischer Sparkassenverband Business association, AUT; register: Trade and business associations model reads as: wants changes source
  • Provide tax advantages or waive land registration fees to support affordable housing acquisition.

    Tax advantages in connection with the acquisition of land (cancellation or reduction of land transfer tax) or the complete waiving of registration fees in connection with the land register can help here.

    machine translation by the Commission, original in DE
  • Assess whether social housing assets can receive favourable prudential collateral treatment under ECB rules and Solvency II.

    it should be assessed whether assets related to social housing could receive a more favourable treatment as collateral.

    machine translation by the Commission, original in DE
  • Facilitate housing financing and reduce bureaucracy in relevant legal acts.

    Funding needs to be made easier and excessive legal acts need to be made less bureaucratic.

    machine translation by the Commission, original in DE
• Micro company, FRA Business association, FRA model reads as: wants changes source
  • Assess the impact of any housing simplification rules on forest management prior to adoption.

    no rule designed for housing should be adopted without first assessing its impact on forest management and forestry works.

    machine translation by the Commission, original in FR
  • Ensure full coherence between the housing package and the stress test of the Birds and Habitats Directives.

    We call on the Commission to ensure full coherence between the Package and the stress test of the Nature Directives.

    machine translation by the Commission, original in FR
• European Builders Confederation EBC Business association, BEL; register: Trade unions and professional associations model reads as: supports source
  • Enforce proportionality based on firm size and contract value without weakening standards.

    Proportionality by firm size and contract value, framed as an enforceable test.

  • Implement a single coordinated permit procedure with parallel assessments and binding deadlines.

    Applying the once-only principle, one integrated procedure per project, with assessments obtained in parallel rather than in sequence.

  • Resolve the standardisation backlog under the Construction Products Regulation as a primary deliverable.

    the standardisation backlog as the priority deliverable of the package

• SEFA- Sustainable Energy Finance Association Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Apply a once-only principle to housing project data so information can be reused across authorities and funding processes.

    First, the Commission should consider a once-only principle for the preparation and end-use of housing project information.

  • Align regulatory rules, funding streams, State aid, and financing to reduce administrative hand-offs.

    Second, greater alignment is needed between regulatory requirements, EU and national funding, State aid, technical assistance and financing.

  • Introduce a delivery test when creating or reviewing EU housing legislation to check practical implementation conditions.

    Finally, SEFA recommends introducing a delivery test when developing or reviewing EU housing-related requirements.

• Micro company, SVN Other, SVN model reads as: wants changes source
  • Apply the once-only principle in spatial planning and permitting to avoid reassessing issues without good cause.

    Apply the once-only principle: issues already substantively assessed should not be reassessed without good reason.

  • Simplify the transition to procurement negotiation procedures when all received bids exceed the available budget.

    Where all tenders exceed the available budget, transition to negotiation procedures already allowed by law should be clear, predictable and simple, supported by standard guidance and model documentation.

  • Clarify State aid and SGEI frameworks, guarantees, and stable financing instruments for public and non-profit housing.

    Provide clearer SGEI/State-aid models, guarantee schemes and stable long-term financing, including blended and revolving instruments, for public and non-profit housing projects.

• Micro company, DEU Business association, DEU model reads as: wants changes source
  • Accept existing Environmental Product Declarations to reduce administrative burdens under the Construction Products Regulation.

    Existing Environmental Product Declarations (EN 15804) should be accepted to simplify compliance.

  • Exempt construction products from reuse obligations specified in the Packaging Regulation.

    Construction products should be exempt from reuse obligations in the Packaging Regulation (specifically regarding § 29), which currently increase costs and disrupt material supply.

  • Prioritize funding toward buildings with the highest energy demand following the worst-first principle.

    Funding should prioritize buildings with the highest energy demand.

• European Disability Forum NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Maintain existing accessibility and sustainability standards when undertaking simplification efforts.

    Simplifying should not mean lowering standards on sustainability and accessibility.

  • Harmonise EU-wide rules regarding accessibility and affordability to tackle fragmented governance.

    Addressing the fragmentation of rules under different levels of governance should be addressed by harmonising EU-wide rules on accessibility and affordability to make our housing future-proof.

  • Properly enforce existing Energy Performance of Buildings Directive provisions rather than weakening them.

    The Energy Performance of Buildings Directive in particular should rather be implemented properly instead of watered down as it contains many useful provisions on accessibility for persons with disabilities.

• Ecologistas en Acción NGO, ESP; register: Non-governmental organisations, platforms and networks and similar model reads as: opposes source
  • Reject environmental deregulation that weakens existing environmental and territorial protection directives.

    The proposals we have seen in connection with this package do not address these problems, but rather make proposals to reform legislation such as the environmental impact directive, the birds and habitats directive or the environmental assessment directive, which have contributed to preserving diversity and having more resilient territories.

    machine translation by the Commission, original in ES
  • Condition housing supply expansion on measures guaranteeing access for low and middle incomes to prevent real estate speculation.

    Ecologistas en Acción believe that facilitating the construction of more housing without measures guaranteeing access to low and medium incomes would only exacerbate the problem, as it would put more housing on sale for speculation.

    machine translation by the Commission, original in ES
• FEICA - Association of the European Adhesive & Sealant Industry Business association, BEL; register: Trade and business associations model reads as: supports source
  • Adopt coherent, proportionate and performance-based regulatory frameworks that preserve material and technology neutrality while maintaining high protection standards.

    FEICA therefore calls for coherent, proportionate and performance-based regulatory frameworks that preserve material and technology neutrality while maintaining high standards of safety, health, environmental protection and resilience.

  • Ensure timely implementation of the Construction Products Regulation and the Energy Performance of Buildings Directive.

    This includes the timely implementation of the Construction Products Regulation and the Energy Performance of Buildings Directive, the avoidance of overlapping information requirements and a lifecycle approach to housing affordability that considers durability, maintenance and energy performance alongside initial construction costs.

• FIEC Business association, BEL; register: Trade unions and professional associations model reads as: supports source
  • Simplify permitting procedures to minimise duplication between environmental assessments and improve administrative coordination.

    FIEC calls for simpler permitting procedures, with less duplication between environmental assessments and better coordination among the authorities involved.

  • Improve access to finance and remove obstacles hindering construction and renovation.

    It also identifies changes needed to improve access to finance and remove obstacles to construction and renovation.

  • Assess the cumulative impact of regulation on housing affordability and distinguish EU requirements from additional national rules.

    The contribution stresses the need to assess the cumulative effect of regulation on housing affordability and to distinguish EU requirements from additional national rules.

• Villaägarnas riksförbund Consumer organisation, SWE model reads as: supports source
  • Design the EU regulatory framework to safeguard national autonomy and local responsibility for housing supply, land use, and spatial planning.

    The EU regulatory framework should therefore be designed to safeguard national autonomy and local responsibility for housing supply, land use and spatial planning.

    machine translation by the Commission, original in SV
  • Ensure decisions can be taken within reasonable timeframes and with predictable outcomes by reducing unnecessary administrative burdens.

    When reviewing regulatory frameworks, the EU and Member States should pay particular attention to reducing unnecessary administrative burdens and avoiding duplication of trials that delay construction and renovation without bringing corresponding societal benefits.

    machine translation by the Commission, original in SV
  • Systematically evaluate new and revised EU legislation regarding its impact on housing supply, costs, renovations, and investments.

    New and revised EU legislation should be systematically evaluated in terms of its impact on housing supply, housing costs, renovations and investments.

    machine translation by the Commission, original in SV
• Association of Netherlands Municipalities Public authority, NLD model reads as: wants changes source
  • Raise public procurement thresholds to account for increasing construction costs.

    raise public procurement thresholds to reflect rising construction costs

  • Recognise affordable housing at least partially as a Service of General Economic Interest and clarify that sustainability and circularity criteria can carry greater weight.

    recognise affordable housing, at least in part, as a Service of General Economic Interest (SGEI); clarify that sustainability and circularity criteria may carry greater weight, even where this indirectly strengthens regional supply chains.

  • Accelerate and simplify end-of-waste criteria for common construction materials while providing explicit flexibility for circular renovation projects.

    to accelerate and simplify end-of-waste criteria for commonly used construction materials such as timber, concrete and steel; introduce explicit flexibility for circular renovation and building conversion projects

• LEG Immobilien SE Company, DEU; register: Companies & groups model reads as: wants changes source
  • Revise EPBD deadlines and requirements to better reflect delivery capacity, financing conditions, and national starting points.

    revise EPBD deadlines and requirements to reflect delivery capacity, financing and national starting points;

  • Allow binding portfolio- and district-level assessments to direct investments toward measures with the highest emissions benefit per euro.

    permit binding portfolio- and district-level assessment, so investment can be directed to the measures with the greatest emissions benefit per euro;

  • Prevent disproportionate costs for tenants while securing reliable funding for vulnerable households.

    avoid disproportionate costs for tenants and provide reliable funding for vulnerable households;

• European Council of Engineers Chambers (ECEC) NGO, BEL; register: Other organisations, public or mixed entities model reads as: supports source
  • Establish a fast-track procedure based on prior technical verification by recognised professional engineering bodies.

    ECEC proposes a fast-track procedure for projects previously verified by a recognised professional engineering organisation or another qualified entity.

  • Allow professionals to submit information once through a single digital file accessible to all relevant authorities.

    Professionals should provide information only once through a single digital file accessible to all authorities.

  • Adapt regulatory frameworks and technical responsibilities to accommodate industrialised and off-site construction methods.

    ECEC proposes that responsibilities correspond to the technical functions actually performed; that the competent-professional principle be applied; that interfaces between design, manufacturing, transport, assembly and operation be clarified; that collaboration between engineers, architects, manufacturers and contractors be promoted; and that quality controls carried out in the factory be recognised, avoiding unnecessary repetition on site.

• Deutsche Unternehmensinitiative Energieeffizienz e.V. (DENEFF) Business association, DEU; register: Non-governmental organisations, platforms and networks and similar model reads as: opposes source
  • Focus the simplification package on practical bottlenecks that delay projects rather than reopening existing EU energy legislation.

    The Housing Simplification Package should focus on practical bottlenecks that actually delay housing creation and renovation projects.

    machine translation by the Commission, original in DE
  • Do not reopen existing EU energy legislation, specifically the EPBD and EED, within the simplification package.

    It should therefore under no circumstances be opened as part of the Housing Simplification Package.

    machine translation by the Commission, original in DE
  • Target practical hurdles to enable the repurposing of underused non-residential buildings and restocking.

    Practical hurdles for such projects should be targeted and synergies between housing creation and renovation should be exploited.

    machine translation by the Commission, original in DE
• Les Entrepreneurs Business association, FRA; register: Trade unions and professional associations model reads as: wants changes source
  • Ensure regulatory consistency across texts to prevent differing requirements and higher administrative burdens.

    They also call for better consistency between regulations, in order to avoid requirements that vary from one text to another and increase the administrative burden for businesses.

    machine translation by the Commission, original in FR
  • Harmonise obligations, aid, and funding criteria around common benchmarks.

    Harmonise definitions and criteria. Obligations, aid and funding must be based on common benchmarks.

    machine translation by the Commission, original in FR
  • Accelerate authorisation procedures with clear deadlines and simpler rules.

    Speed up procedures. Authorisations need to be faster, simpler and subject to clear deadlines.

    machine translation by the Commission, original in FR
• Deutsches Studierendenwerk e.V. Business association, DEU model reads as: wants changes source
  • Extend State aid facilitations to student unions performing statutory social tasks.

    In order to fulfil the statutory tasks, student unions must also participate in the aid facilitations.

    machine translation by the Commission, original in DE
  • Allow exemptions from stricter EPBD charging infrastructure requirements for public-interest institutions.

    We suggest that exemptions from these stricter rules should be made possible for institutions which are in the public interest, such as the German student unions, which perform social, legal tasks.

    machine translation by the Commission, original in DE
  • Raise public procurement thresholds appropriately to avoid requiring public tenders for small and medium construction projects.

    Therefore, the thresholds, which have remained unchanged for 10 years despite rising wages and prices for materials, works and services, should be raised appropriately so as not to require public tendering for every small or medium-sized construction project.

    machine translation by the Commission, original in DE
• Council of European Municipalities and Regions Other, BEL; register: Associations and networks of public authorities model reads as: wants changes source
  • Provide greater flexibility and simplified State aid procedures for public-interest and municipal housing investments.

    Procedures should be significantly simplified, particularly regarding entrustment requirements, overcompensation controls and earmarking obligations, reducing reliance on costly external legal expertise.

  • Adopt a simpler procurement framework with higher thresholds and greater flexibility for contract modifications and direct awards.

    CEMR therefore calls for a simpler and more flexible procurement framework, including higher thresholds that better reflect current market conditions, greater use of direct awards after unsuccessful procedures, and increased flexibility for contract modifications.

  • Explicitly recognise housing as an overriding public interest and provide clearer assessment thresholds under nature protection rules.

    Clearer thresholds, proportionate assessments for low-risk projects, more flexible compensation mechanisms and explicit recognition of housing as an overriding public interest in areas facing shortages would improve planning certainty while maintaining environmental objectives.

• Micro company, ITA Company, ITA model reads as: wants changes source
  • Complement regulatory simplification with structural credit support instruments such as base rate loan schemes.

    To this end, it is proposed to supplement the text by providing for the introduction and regulation of ‘base rate loans’ (or reference capped rates).

    machine translation by the Commission, original in IT
• Deutscher Sparkassen- und Giroverband (DSGV) Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Exclude energy-efficiency renovation from acquisition, development and construction exposures under prudential rules.

    Energy-efficiency renovation should therefore be excluded from ADC exposures.

  • Extend preferential prudential treatment to predominantly publicly owned housing companies subject to lasting public control.

    Moreover, the treatment available to public housing or not-for-profit entities regulated by law should be extended to predominantly publicly owned housing companies subject to lasting public control.

  • Assess whether the systemic risk buffer remains necessary and proportionate alongside existing prudential instruments.

    Second, the Commission should assess whether the systemic risk buffer under Article 133 of Directive 2013/36/EU remains necessary and proportionate alongside existing prudential and supervisory instruments.

• Health and Environment Alliance (HEAL) NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: opposes source
  • Ensure the initiative does not take the form of an omnibus law or endanger environmental and climate legislation.

    However, if the Commission nevertheless opened such additional, time and resources consuming process, HEAL considers it essential that this initiative does not take the shape of yet another omnibus, and does not endanger climate or environmental protective legislation.

  • Invest in preventing and reducing pollution at the source rather than creating another omnibus.

    Policy instrument: more investment into preventing and reducing pollution at source needed, not another omnibus

• ASVAL Other, ESP; register: Trade unions and professional associations model reads as: supports source
  • Include affordable and long-term residential rental housing in the assessment without establishing a uniform EU-wide definition.

    (i) affordable and long-term residential rental housing to be included as a specific focus of the assessment, without establishing a uniform EU-wide definition of affordable housing, as this should remain within the competence of Member States and regional authorities;

  • Quantify the impacts of EU rules separately from their implementation at national, regional, and local levels.

    (ii) the impacts of EU rules (EPBD, Energy Efficiency Directive, Construction Products Regulation, environmental assessment, public procurement and State aid) to be quantified separately from those arising from their implementation at national, regional and local level, including measurement of the actual time required until housing units are delivered;

  • Promote one-stop shops, maximum processing timelines, digital procedures, and positive administrative silence.

    (iii) the promotion of one-stop shops, maximum processing times, digital procedures and positive administrative silence where appropriate, as well as making energy renovation accessible to small property owners;

• Bundesarchitektenkammer Other, DEU; register: Trade unions and professional associations model reads as: wants changes source
  • EU law should only be amended where a barrier at European level is proven, while retaining mandatory protection and quality objectives.

    EU law should therefore only be amended where there is a proven European barrier.

    machine translation by the Commission, original in DE
  • Clear rules for intellectual planning services and design competitions are needed in public procurement law, avoiding overall awards as the norm.

    In public procurement law, clear rules are needed for intellectual planning services, appropriate thresholds, technical and sub-lots, quality competitions and design competitions.

    machine translation by the Commission, original in DE
  • Adopted climate, energy and environmental objectives should not be renegotiated on a blanket basis, and duplication of structures and evidence should be consistently reduced.

    Double structures, different definitions and parallel evidence should be consistently reduced.

    machine translation by the Commission, original in DE
• European Roma Grassroots Organisations (ERGO) Network NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Simplification measures must include one-stop community procedures and accessible information while avoiding treating EU social, environmental, or rights protections as burdens.

    Simplification should include one-stop procedures which are available at community level, accessible information including in minority languages, reduced fees or free procedures, outreach and community mediation, and removing fixed-address or documentation requirements for accessing rights.

  • Efforts to simplify procedures for informal settlements must not accelerate demolitions or evictions.

    These efforts, however, must never accelerate demolitions or evictions.

  • The package must facilitate affordable public, social, cooperative and non-profit housing without financing segregation or displacement.

    The Package should facilitate expansion and renovation of affordable public, social, cooperative and non-profit housing through simpler procurement, permitting and finance.

• Zentraler Immobilien Ausschuss e.V. (German Property Federation, ZIA) Business association, DEU model reads as: wants changes source
  • Environmental and waste legislation should be reviewed to avoid duplicate assessments and keep environmental data valid for seven years.

    Multiple assessments at different planning and permitting stages should be avoided, and duly collected environmental and species protection data should remain valid for seven years.

    machine translation by the Commission, original in DE
  • Prudential requirements affecting housing finance should be reformed in a separate accelerated procedure.

    Given the annual housing investment gap of more than EUR 150 billion,[1] the upcoming banking package should address the output floor, ADC risk weighting and transitional arrangements for real estate financing in a separate accelerated procedure.

    machine translation by the Commission, original in DE
  • Binding deadlines should apply to EU assessment procedures, allowing parallel assessments and deemed approval.

    Binding deadlines should apply to procedures shaped by EU assessment requirements.

    machine translation by the Commission, original in DE
• Verband der öffentlichen Wirtschaft und Gemeinwirtschaft Business association, AUT model reads as: wants changes source
  • Projects of major importance for housing or climate policy without a decision within a legally defined period should automatically be deemed approved.

    Projects of particular importance for housing or climate policy for which no decision has been taken within a legally defined period should automatically be deemed approved.

    machine translation by the Commission, original in DE
  • European IT systems must not create parallel structures with functioning national solutions.

    However, there must be no parallel structures between functioning national solutions and European IT systems.

    machine translation by the Commission, original in DE
  • Qualified fire safety experts should be allowed to validate applicable fire safety regulations prior to project submission to shorten permitting times.

    Even before the submission of a building project, qualified fire safety experts could check and validate the applicable fire safety regulations, which, based on experience, would lead to a reduction of six to nine months.

    machine translation by the Commission, original in DE

91 more analysed submissions on the consultation page.