INREV position paper on State Aid to Affordable Housing

INREV’s position paper on the European Commission’s State aid rules for affordable housing services of general economic interest (SGEIs) builds on the ongoing work under the European Affordable Housing Plan.

INREV supports the Commission’s intention to ensure that state aid rules enable rather than hinder the delivery of affordable housing. However, the paper stresses that definitions must clearly distinguish between social housing—reserved for vulnerable or low-income households—and affordable housing, which addresses the broader gap for middle-income residents across Europe’s urban areas.

INREV calls for a proportionate and evidence-based approach, where State aid is granted only in cases of clearly demonstrated market failure. Housing shortages should be assessed objectively to distinguish genuine market failures from policy-induced barriers such as inefficient planning, restrictive zoning, or excessive regulation. Public support should therefore complement—not substitute—market activity, ensuring that aid is targeted where the market cannot deliver affordable housing on its own. 

Recognising that housing delivery depends on the alignment of local and EU-level policy, INREV urges the Commission to promote best practice through coordination mechanisms and knowledge sharing among Member States. This includes clarifying how different forms of support—such as rental guarantees, direct grants, or land contributions—can be applied while maintaining competitive neutrality.

The position also reinforces the industry’s readiness to co-invest alongside public authorities to scale up affordable housing delivery. Institutional investors such as pension funds and insurers bring the long-term capital, governance standards, and risk management practices needed for sustainable outcomes.

INREV continues to engage closely with the Commission, together with partners such as Build Europe and IVBN, to ensure that upcoming guidance reflects both the policy objectives of the Affordable Housing Plan and the practical realities of market implementation. The overarching goal remains a fair and effective framework where public support catalyses, rather than replaces, private investment in delivering affordable homes across Europe.