eu travel tech on the Affordable Housing Act: no housing fix, but new single market problems

Brussels, 9 September – Today, the European Commission published its long-awaited Affordable Housing Act.

For eu travel tech, this initiative is misguided and not grounded on facts and data. The Commission is carving short-term rentals out of the horizontal single market rules that apply to every other service sector, allowing national and local authorities a much lower threshold for scrutiny of proposed restrictions. This sets a dangerous precedent for carving out and disadvantaging sectors based on political pressure rather than objective justification.

While we fully recognise the urgency of the housing crisis and the need to address local pressures where they arise, any policy response must be grounded in facts, evidence, and a clear understanding of the real drivers of housing affordability. Available data consistently shows that short-term rentals represent approximately 1.2% of total dwelling stock, while nearly 20% of EU dwellings are unoccupied.[1] If the EU wants to solve the housing crisis, it must address its real drivers—not target short-term rentals.

Now that the proposal has been tabled, eu travel tech stands ready to engage constructively with lawmakers and stakeholders in the upcoming discussions. We believe two objectives shall be at the heart of the new Regulation, once adopted:

Ensuring any restriction on STR activities at local or national level is fit for purpose. Proportionality, as established by EU law, needs to remain the cornerstone of such regulations: In practice, this means that restrictions have to be targeted, grounded on real data and take into account all costs and benefits.[2]
STR restrictions must be rooted in evidence. The Regulation on data collection and sharing relating to short-term accommodation rental services (Reg. 2024/1028) will provide the robust, comparable data needed to assess STR activity accurately. When the data is available in a consistent manner and at a scale, authorities will be able to use the granular monthly activity data to design proportionate, locally tailored measures. This evidence-based approach must remain the precondition for compliance with EU law.

“We had expressed concerns about this legislative initiative on numerous occasions, and we still have them. The previous legislation on STRs has just started being implemented and is yet to provide any data on short-term rental activity. This means that the very data we need to assess the link between Housing and STRs simply does not exist. Weakening single market rules for the sake of scoring political points will not address housing issues in Europe.” said Emmanuel Mounier, Secretary General of eu travel tech.

He added that “In addition, housing stress must be assessed against clear and appropriate metrics. Any restriction on Short-Term Rentals must be supported by relevant STR data and evidence of a clear link to the identified housing stress. Housing stress alone cannot justify restrictions. The Regulation must make this requirement explicit and ensure its strict application.”

As outlined by the Commission in its Affordable Housing Action Plan last December, short-term rentals deliver multiple benefits to the European economy: greater choice, additional amenities for consumers, extra income for hosts, an incentive to invest in renovation, and a boost to tourism, incomes and jobs.[3] In the upcoming discussions, eu travel tech will work to ensure those benefits are preserved. Any measures aimed at addressing housing impacts linked to STR activity must remain local in nature, proportionate, non-discriminatory, and necessary, in line with EU law and established case law on this matter.

[1] European Commission, Understanding the housing crisis, SWD(2025) 1053/2, 16.12.2025, p. 87.
[2] The Court of Justice of the EU has provided numerous clarifying criteria on the proportionality test applicable to short-term rental restrictions, notably in the joined Cases C-724/18 and C-727/18 (Cali Apartments and HX) and, more recently, in the Advocate General’s Opinion in Smartflats (C-813/24, 2 February 2026. Blanket prohibitions or restrictions, like complete STR bans, are almost always unlawful.
[3] https://transition-pathways.europa.eu/tourism/articles/strengthening-local-economies-positive-impact-short-term-rentals-europes-rural