THE EUROPEAN ANTI-POVERTY STRATEGY AND COUNCIL RECOMMENDATION ON FIGHTING HOUSING EXCLUSION:
HOUSING EUROPE ASSESSMENT AND CALL TO ACTION FOR MEMBERS
On the 6th of May 2026 the European Commission presented the social package to help end poverty in the EU and to strengthen the rights of people with disabilities. Within it, two important pieces of legislation are extremely relevant for the housing sector, namely the Anti-Poverty Strategy and the Council recommendation on fighting housing exclusion which is still in the proposal stage. Housing Europe broadly welcomes the attention given by the European Union to poverty reduction, housing exclusion and homelessness. Both the strategy and the Recommendation contain several positive elements, notably its references to prevention, integrated support and complementary services, and the recognition that access to social housing, and housing-led approaches as essential elements to fight housing exclusion, combating homelessness and poverty.
Nevertheless, few elements in the two pieces of legislation would benefit from improvement. In the following paragraphs some points of consideration will be offered on the Anti-poverty strategy. However, the focus of this statement will specifically address the Recommendation which is at proposal stage and adjustments are possible.
The Anti-Poverty Strategy: concerns on private and philanthropic organizations financing social housing.
A central concern relates to the Anti-Poverty Strategy’s emphasis on mobilizing businesses and philanthropic organizations to strongly complement public resources to combat poverty. In this context, in October 2026 a Coalition Against Poverty, bringing together socially responsible business and philanthropic organizations will be launched.
While such actors can play a complementary role, an Anti- Poverty strategy aimed at improving access to housing should not massively rely on financing sources tied to the willingness of a few market players. In particular, housing access for homeless and for people in deep precarity requires additional support services and generates social value rather than financial return. As a consequence, strong public investment is necessary, and innovative financing can be understood as complementary but should not be regarded as substitute.
The Council recommendation of fighting housing exclusion: several concerns are identified
- Misconceptions Regarding Social Housing Allocation Systems
Several provisions of the Recommendation on fighting housing exclusion appear to reflect a limited understanding of how social housing allocation systems operate in many Member States.
- Transparency of Social Housing Waiting Lists
Point 6 (j) calls on “measures to prevent and address stigmatization and discriminatory practices in access to housing such as transparent criteria for social housing waiting lists, anti-bias training for housing professionals and support services for tenants facing discrimination”. While combating discrimination is important, the wording of this provision risks implying that social housing allocation systems currently operate through opaque or arbitrary procedures.
As a general rule, social housing allocation is already governed by highly regulated and transparent procedures. Allocation decisions are generally based on established criteria, relying on points-based mechanisms examined by dedicated allocation committees operating under clear legal frameworks.
The Recommendation would benefit from acknowledging the fact that social housing challenge is not connected to the absence of transparent criteria but rather the structural shortage of public investments and support to the public, cooperative, and social housing sector
- Narrow consideration of target groups
Point 9(c) calls for “increasing the availability of adequate housing solutions for people experiencing housing exclusion, in particular parents with children, and ensure that they are taken into account and prioritized in the allocation mechanisms for social housing”. This provision again appears to neglect how social housing allocation systems already function in several Member States.
In many Member States, family composition, housing inadequacy, overcrowding, and social vulnerability are already considered within allocation procedures. Families with children are frequently among the categories that receive priority, not as a direct consequence of parenthood itself, but because this usually leads to situations of overcrowding or housing inadequacy.
As a result, the Recommendation risks presenting a policy solution which is already embedded within national systems. The recommendation should rather focus on getting a critical mass of public, cooperative and social housing as a core solution to prevent homelessness and housing exclusion.
- Misleading interpretation of Investment Barriers in Social Housing
Investment, State Aid and Blended Finance
Points 8(c) encourages “implementing innovative financing models, such as revolving funds, blended financing and public guarantees mobilizing both public and private capital for affordable and social housing”. On this point, it is important to underline the irreplaceable role of public subsidies in the financing of social and affordable housing. Social housing is a low-return investment sector, consequently the only way to maintain lower rents is to have public resources. For this reason, innovative finance is welcomed but must remain complementary.
In addition, point 8(g) proposed “taking up financial instruments and blended funding under the current cohesion policy, while using the flexibilities offered under its mid-term review to re-allocate EU funding towards affordable housing”.
Also here, the Recommendation appears to assume that State aid rules constitute a major obstacle to investment in housing, while there is a widespread consensus among housing professionals that this is the low level of investment which is a factor of the current crisis. Furthermore, in many contexts, the primary constraints affecting housing are structural factors such as, for example, land prices, increasing construction costs or permitting time.
Presenting State aid flexibility as a key solution may misidentify the main causes of underinvestment in housing. While regulatory simplification can contribute positively, it cannot compensate for the fundamental supply-side constraints.
It is also important to note that one major issue in the field of fighting housing exclusion is the discrepancy between on the one hand the generally multi-annual funding for the infrastructure part of the provision of social and affordable housing and on the other hand, the more short-term funding for social support and services. This discrepancy is an obstacle to an approach combining housing solutions with adequate social support.
- Untargeted approach to youth vulnerability
Youth should not be treated as a homogeneous category facing identical levels of housing vulnerability. Significant differences exist between young people in education, those entering the labour market, young workers with stable incomes, homeless youth and young migrants. However, this logic is not consistently applied throughout the text, where youth appears to be addressed as a broad category.
A more effective approach would focus specifically on vulnerable youth, namely those facing risks of housing exclusion, homelessness and poverty. Such targeting would ensure that resources are directed towards those with the greatest needs while avoiding overly broad categorization.
Conclusion
Housing Europe supports the overall objective of strengthening action against poverty and housing exclusion across the European Union. Nevertheless, a more evidence-based understanding of the sector would strengthen the credibility of the Recommendation and improve the capacity of Member States to concretely implement them.
It is essential to remember that the Council Recommendation is a non-binding instrument. While it provides useful guidance to Member States, it does not create legal obligations. This characteristic makes it important that the potential implementation is done in close dialogue with national, regional, and local providers of social, cooperative and public housing.
For these reasons, and in view of the EPSCO meeting on 29 October 2026, where the Recommendation will be discussed, our members are encouraged to engage with their national housing authorities with the aim of highlighting these points of concern while bringing their first-hand expertise before the meeting takes place.
Such engagement will be necessary to ensure Council Recommendation that are responsive to the realities faced by public, cooperative and social housing in Europe.