While UIPI supports the objectives of the European Affordable Housing Plan (EAHP) and recognises the importance of coordinated action to address Europe’s housing challenges, the current framing of the Affordable Housing Act, raises significant concerns. Particularly, in the way it is described, the plan risks being an overbroad catch-all initiative that conflicts with distinct policy areas, potentially exceeding EU competences by blurring out the lines between legislative requirements and non-legislative guidance.

In particular, UIPI urged that:

• EU action on housing must fully respect the principle of subsidiarity, ensuring that key competences such as urban planning, permitting and rental regulation remain primarily at national, regional and local levels.
• The Commission should ensure closer alignment between the Act’s stated objectives and its actual content, focusing on targeted and well-defined measures that provide legal certainty.
• Any EU initiative on “housing stress” should avoid imposing prescriptive benchmarks, as defining such indicators at EU level risks triggering policy interventions that exceed EU competences.
• If developed, housing stress indicators should remain a voluntary methodological toolkit rather than binding criteria influencing national housing policies or market restrictions.
• Efforts to regulate short-term rentals should not lead to a highly harmonised EU framework, as this would undermine local flexibility and fail to reflect diverse housing market conditions across Member States and cities.
• The EU should prioritise coordination, data sharing and exchange of best practices, rather than introducing top-down regulatory frameworks that risk creating tensions with local decision-making.
• Addressing housing affordability should focus on tackling structural issues related to housing supply and access, while preserving legal certainty and respecting national sovereignty and local democratic accountability.