The European Commission presented the draft of the Affordable Housing Act together with an accompanying recommendation on 9 September. The aim of this initiative is to increase legal certainty in strained housing markets and to strengthen the supply of housing in the European Union. The German Federal Chamber of Architects (BAK) takes note of the proposed measures and comments on their potential impact on the construction and planning industry.
The BAK expressly welcomes the Commission's focus on the use of existing properties, their repurposing, and the densification of urban areas. This approach is regarded as a substantial contribution to efficient resource use and the development of liveable towns and communities. Nevertheless, the Chamber stresses the necessity that an intended simplification of processes must not lead to a reduction in planning quality, building culture, or an impairment of fair competition.
Ms Andrea Gebhard, President of the German Federal Chamber of Architects, underlines the fundamental importance of affordable housing for creating socially diverse and liveable communities. She emphasises that good planning, efficient procedures, and an intelligent approach to existing building stock form the basis for this, not a reduction in quality standards. Ensuring independent planning is indispensable in this context. The Commission also addresses tax disincentives, which is positively received by the BAK.
A positive aspect of the Commission's proposal is the intended increase in flexibility regarding planning law requirements, provided that quality and sustainability standards are maintained. This corresponds with the basic idea of building type E, which provides for functional flexibility while retaining unchanged protection goals. The BAK highlights that independent planning by architects makes a decisive contribution to securing local context, quality, and building culture when applying standardised construction methods.
In view of the intended reforms, the German Federal Chamber of Architects formulates specific demands to ensure quality and fairness in the planning process. These include, among other things, the design of tendering procedures that are both quality-oriented and suitable for small and medium-sized enterprises. It is demanded that architectural competitions and access for small and medium-sized enterprises (SMEs) be strengthened, whereby overall tenders should not weaken independent planning services and lot allocation. Furthermore, the acceleration of approval procedures is urged, while maintaining legal protection. Digital processes and clear deadlines are advocated, while fictitious approvals and the limitation of legal remedies must not reduce legal protection as well as safety and environmental checks. Regarding serial and modular construction, a technology-open application is demanded, ensuring independent planning, local context, quality, and building culture through architects.
The German Federal Chamber of Architects intends to continue to actively participate in the legislative process. The goal is to ensure that simplifications lead to a faster provision of housing, without jeopardising planning quality and fair competition. This corresponds to the premise that high-quality and sustainable solutions for the housing market are of crucial importance in the long term.














