European Association for Investors in Non-Listed Real Estate Vehicles
INREV
INREV's aim is to improve the accessibility of non-listed real estate funds for institutional investors by promoting greater transparency, accessibility, professionalism and standards of best practice.
ID: 47748145557-46
Lobbying Activity
Response to EU taxonomy - Review of the environmental delegated act
3 Dec 2025
INREV, the European Association for Investors in Non-Listed Real Estate Vehicles, welcomes the opportunity to support the Commissions review of the EU Taxonomy Climate and Environmental Delegated Acts. Our membership consists of long-term real estate fund managers and institutional investors who play a central role in financing the transition of Europes building stock. We support the objective to improve clarity, reduce unnecessary complexity, and ensure a more proportionate and coherent framework. Experience from the first years of application shows that unclear definitions, overly granular thresholds, and misalignment with legislation such as the recast EPBD have created significant implementation challenges. A more streamlined approach is needed to ensure that the Taxonomy remains usable, credible and effective. In this context, we highlight several priorities. The framework must reflect the real estate investment model, in which sustainability performance is driven not by construction activity but through the long-term acquisition, management and upgrading of existing buildings. Deep renovations, retrofits and redevelopment form a core part of this model and often deliver the most meaningful climate-mitigation outcomes. Simplification of DNSH criteria, better alignment with EPBD obligations, and clearer pathways for operational-energy reporting and proxy use would further support consistent and practical implementation. Moreover, interoperability across EU reporting frameworks is essential to reduce duplication and improve comparability for investors. We attach our position document that provides detailed technical feedback, including specific recommendations on criteria design, DNSH simplification, transitional activity classification, data availability and proportionality. We remain ready to engage actively with the Commission in the next stages of this review and to contribute sector-specific expertise to ensure an effective, evidence-based Taxonomy for real estate.
Read full responseResponse to Review of the State aid rules on the Services of General Economic Interest (“SGEI”)
25 Jul 2025
The European Association for Investors in Non-Listed Real Estate Vehicles (INREV) welcomes the European Commissions initiative to revise the State aid rules for services of general economic interest (SGEI), with a particular focus on affordable housing. The deterioration of housing affordability across the EU, particularly in major urban centres, constitutes not only a growing social crisis but also a structural constraint on economic mobility and cohesion. While the Commission's forthcoming European Affordable Housing Plan (2026) signals a welcome recognition of the urgency, revision of the State aid framework is a vital and necessary precondition for the success of any such strategy. The current rulesrooted in the 2012 SGEI Decision and Frameworkwere not designed with todays housing market challenges in mind. They lack the clarity, flexibility and scope to support the delivery of affordable housing at the scale and speed required. INREVs contribution to this public consultation offers valuable insights into how the rules could be revised to better reflect market realities, promote subsidiarity, and catalyse investment in housing solutions for a broader cross-section of society. This response seeks to articulate key principles and policy recommendations, drawing on the Commission's problem definition and proposed objectives, and grounded in INREVs evidence and arguments. We hope with our comments to make a constructive contribution to this important policy debate. Kind regards, Jeff Rupp
Read full responseResponse to Commercial real estate statistics
7 Jul 2025
INREV (the European Association for Investors in Non-Listed Real Estate Vehicles) welcomes the European Commissions proposal to establish a framework for non-financial statistics on commercial real estate, recognising its potential to close critical data gaps that hinder macro-prudential oversight. We support the initiatives objective to improve data quality, consistency, and comparability across the sector. We stress the need for sectoral differentiation to reflect the heterogeneity of commercial real estate. Applying consistent subcategoriesaligned with existing frameworks would enhance the analytical usefulness of the data and facilitate integration with financial regulation. We agree that existing administrative data should be the primary source for statistics. Where this is not feasible, we support the use of private data sources only when clearly necessary and proportionate, in line with Article 17b of Regulation (EC) No 223/2009. Safeguarding confidentiality is essential. While we welcome references to Regulation (EC) No 223/2009, we recommend embedding confidentiality commitments directly within the regulations main text to strengthen legal clarity and build trust among data providers. Finally, we urge ongoing engagement with industry stakeholders to ensure that definitions and methodologies are in line with market realities. A harmonised approach to key concepts such as 'rent' or 'usable floor area' will be crucial for producing meaningful and comparable outputs. INREV stands ready to support the Commission in shaping a fit-for-purpose framework that serves both public policy objectives and the needs of the commercial real estate industry. For further details, please see the attached document. For any questions, please contact us at public.affairs@inrev.org.
Read full responseMeeting with Philippe Moseley (Cabinet of Commissioner Dan Jørgensen) and European Public Real Estate Association
11 Jun 2025 · Housing
Response to European Affordable Housing Plan
2 Jun 2025
The European Association for Investors in Non-Listed Real Estate Vehicles (INREV) welcomes the European Commissions initiative to develop a European Affordable Housing Plan and fully supports its ambition to address housing as a core pillar of social cohesion, economic competitiveness, and environmental transition. INREV represents over 500 members across Europe and globally, including institutional investors such as pension funds, insurance companies, and sovereign wealth funds that collectively provide income security for more than 172 million people. Our membership also includes fund managers, investment banks, advisors, and other key stakeholders engaged in the non-listed real estate sector. Collectively, they manage over 500 non-listed real estate investment vehiclesincluding funds, joint ventures, club deals, and separate accountsdemonstrating the scale and diversity of capital and expertise that can be mobilised toward achieving the objectives of the Affordable Housing Plan. Institutional investors are particularly well positioned to contribute to the delivery of long-term, sustainable housing solutions. They manage patient capital that is increasingly being directed toward housing investments capable of generating both stable financial returns and positive social outcomes. However, Europes housing crisis is not cyclical but systemicdriven by chronic underinvestment, demographic changes, urbanisation, and fragmented policy frameworks. Addressing this challenge requires a shift from fragmented, reactive measures to a coherent, strategic approach: a long-term, pan-European policy architecture that aligns public objectives with private investment capabilities, creates stability across economic cycles, and enables delivery at scale through integrated governance mechanisms. INREV response draws on our latest research which explores how institutional capitallong-term, stable, and increasingly sustainability-drivencan be more effectively mobilised in partnership with public policy to bridge the affordability gap. The goal is to increase access to quality, affordable housing for middle-income and underserved households across Europe, supporting broader economic, social, and environmental priorities. We attach our full response to the European Affordable Housing Plan Call for evidence together with the underlying research to support evidence-based policy development and constructive dialogue with stakeholders.
Read full responseResponse to Savings and Investments Union: Directive fostering EU market integration and efficient supervision
29 May 2025
The European Association for Investors in Non-Listed Real Estate Vehicles (INREV) welcomes the opportunity to respond to the Commission's Call for Evidence on Savings and Investment Union - EU rules to foster market integration and efficient supervision. We hope our attached comments will make a constructive contribution to this important topic. If you have any questions or would like to discuss our response, please contact me at jeff.rupp@inrev.org. Sincerely, Jeff Rupp INREV Director of Public Affairs
Read full responseResponse to Revision of EU rules on sustainable finance disclosure
25 May 2025
Dear DG FISMA Unit C4 Asset management team, The European Association for Investors in Non-Listed Real Estate Vehicles (INREV) welcomes the opportunity to respond to the Call for Evidence on the revision of SFDR. We hope our attached comments will make a constructive contribution to this important topic. If you have any questions or would like to discuss our response, please contact me at jeff.rupp@inrev.org. Sincerely, Jeff Rupp INREV Director of Public Affairs
Read full responseResponse to Evaluation of the Anti-Avoidance Tax Directive (ATAD)
11 Sept 2024
We hope our comments make a constructive contribution to the reconsideration of ATAD I and are available for further clarification or explanation if desired. Kind regards, Jeff Rupp Director of Public Affairs INREV
Read full responseResponse to Commercial real estate statistics
22 Dec 2023
INREV, the European Association for Investors in Non-Listed Real Estate Vehicles, strongly supports the European Commission Call for Evidence on Commercial Real Estate Statistics. We agree that the regulation would fill a significant gap in the availability of statistical information on commercial real estate which is needed for macro-prudential purposes. The collection of high-quality, consistent real estate data is critical to success and will ultimately lead to more informed analysis and recommendations. Please see our detailed comments in the attached.
Read full responseResponse to Debt equity bias reduction allowance (DEBRA)
27 Jul 2022
INREV - the European Association for Investors in Non-Listed Real Estate Vehicles appreciates the European Commission's efforts to further neutralise the bias against equity financing and welcomes the carve out granted to financial undertakings.
We appreciate the opportunity to respond to this important proposal. Please see our detailed views in the attached document.
Read full responseResponse to Fighting the use of shell entities and arrangements for tax purposes
5 Apr 2022
INREV hopes the views in the attached response reflect a few clear points.
The first is that the primary purpose of real estate non-listed funds is to enable collective investment in real estate assets for multiple institutional investors such as pension funds and insurance companies.
Second, it is an important principle of tax policy that cross-border tax rules should put these investors in the same tax position that they would be in if they had invested in the underlying real estate assets directly. In other words, there should be tax neutrality between a direct investment in real estate and an investment in real estate through a non-listed real estate vehicle, a principle that has been recognised by the OECD in its 2010 CIV report and BEPS recommendations, by the EU in ATAD 1, and by EU Member States.
Third, a non-listed real estate fund generally holds its real estate investments through one or more (controlled) special purpose companies (SPCs) for a number of legitimate commercial and legal reasons. These reasons include the protection of the real estate fund from the liabilities of and potential claims against the fund’s immovable property assets as well as facilitating debt financing, including debt by third-party lenders.
These SPCs ensure ring-fencing of the liabilities of, and potential legal claims against, each asset or relatively small group of assets. To maintain the principle of tax neutrality, it is important that the interposition of SPCs does not cause an additional tax burden that would not arise if the investments were held directly by subjecting the investment income to double taxation. We note further that the income derived from real estate assets owned by a real estate fund is typically subject to full taxation in the country where the real estate is physically located, while the fund structure is designed to facilitate the collective investment and provide for tax neutral income distribution to its investors which is then subject to tax treatment under their domestic tax laws. Finally, the institutional investors and fund managers in our industry are strong proponents of ethical tax policy and behaviour. In addition to their own internal ethical tax policies, through INREV, our industry has adopted a Code of Tax Conduct (https://www.inrev.org/guidelines/module/EN/code-of-tax-conduct?find=504#inrev-guidelines) that is consistent with the guidelines and principles of the UN Investors' Recommendations on Corporate Tax Disclosure, the OECD's Guidelines for multinational enterprises, the OECD's Building Better Tax Control Framework and the sustainability reporting standard on tax, GRI 207: Tax 2019.
The legislative proposal reflects the Commission’s clear concern about the risk that investors can use shell structures or other arrangements to avoid or unethically minimise tax. We share this concern but see the approach proposed to lack the refinement necessary to make it successful. If overbroad tax rules that label certain sectors or structures as shell entities used for tax purposes are adopted, they run the risk of unintentionally sweeping up a number of entities that have been adopted for legitimate business purposes, even if they have many or even all the gateways listed in Article 6. For example, a real estate fund established for long-term investment typically has little need for extensive staff or premises given the nature of the activity being undertaken and the staff and premises can often more efficiently be shared between a number of related group entities. We strongly believe that these entities and their characteristics should be analysed considering the commercial context and purpose for which they were put in place. They should not be automatically suspected of being used for tax purposes based solely on a “hallmarks” of organisational characteristics. We hope to make a constructive contribution to this important tax policy issue.
Read full responseResponse to Long Term Investment Funds – Review of EU rules
24 Mar 2022
Long-term investment funds – review of EU rules
INREV is the European Association for Investors in Non-Listed Real Estate Vehicles. We provide guidance, research and information related to the development and harmonisation of professional standards, reporting guidelines and corporate governance within the non-listed property funds industry across Europe.
INREV currently has approximately 480 members. Our member base includes institutional investors from around the globe including pension funds, insurance companies and sovereign wealth funds, as well as investment banks, fund managers, fund of funds managers and advisors representing all facets of investing into non-listed real estate vehicles in the UK and the rest of Europe. Our fund manager members manage more than 500 non-listed real estate investment funds, as well as joint ventures, club deals and separate accounts for institutional investors.
Statement of principles
INREV welcomes the opportunity to provide feedback on the European Commission’s (Commission) Proposal for a Regulation amending Regulation (EU) 2015/760 as regards the scope of eligible assets and investments, the portfolio composition and diversification requirements, the borrowing of cash and other fund rules and as regards requirements pertaining to the authorisation, investment policies and operating conditions of European long-term investment funds.
INREV supports the Commission’s targeted approach in reviewing the existing ELTIF framework. We believe that the current rules should be neither diluted nor unnecessarily augmented without careful consideration of the potential impact on managing non-listed real estate funds.
We appreciate the Commission’s proposal to adopt specific rules to make the ELTIF more attractive to institutional investors. Non-listed real estate is a long-term investment and institutional investors are able to invest via tailored made AIFs. Nevertheless, the proposed rules tailored to institutional investors may provide some additional benefits that will attract capital in these structures and INREV therefore supports the Commission’s proposal.
Read full responseResponse to Alternative Investment Fund Managers – review of EU rules
24 Mar 2022
Statement of principles
INREV welcomes the opportunity to provide feedback on the European Commission’s (Commission) Proposal for a Directive of the European Parliament and of the Council amending Directives 2011/61/EU (‘AIFMD’) and 2009/65/EC (‘UCITS directive’) as regards delegation arrangements, liquidity risk management, supervisory reporting, provision of depositary and custody services and loan origination by alternative investment funds.
The non-listed real estate investment industry has adapted to the requirements of AIFMD, which is generally working well. INREV therefore supports the Commission’s targeted approach in reviewing the existing AIFMD framework. We believe that the current rules should be neither diluted nor unnecessarily augmented without careful consideration of the potential impact on managing non-listed real estate funds.
Detailed explanation of position
In response to the legislative proposal, INREV would like to make the following comments on delegation and loan originating funds which we hope will make a constructive contribution to consideration of and potential modifications to the proposal:
Delegation: INREV supports the fact that delegation has been explicitly recognised as a key contributor to the success of the EU fund and manager labels. Delegation “allows for the efficient management of investment portfolios and for sourcing the necessary expertise in a particular geographic market or asset class”.
While there has been a desire among regulators for increased transparency regarding delegation arrangements, we note that there has been increased transparency following the introduction of the new annual notification mechanism from NCAs to ESMA focusing on certain delegations to entities located in third countries. In our view, this should not lead to a situation where ESMA would systematically review delegation arrangements with delegates domiciled in third countries, in a way similar to a proposal related to Article 31a that was considered and rejected in the context of the 2017 ESA review.
Loan originating funds: Experience shows that loan originating funds are an important diversification from sole reliance on bank lending and offer alternative financing options for entities. In INREV’s view, the proposed new requirements imposed on loan originating AIFs should be limited and coherent from a business perspective. In particular, product-level regulations are not in the spirit of AIFMD and should be avoided.
Further, although we understand the purpose of the proposed risk retention requirement, which is to address potential moral hazards and promote sound credit underwriting and due diligence practices, we do not support the 5% risk retention and believe there are other less intrusive means to achieve those objectives. We would support a more general prohibition on the originating of loans with the sole purpose of transferring those loans to third parties related to the AIFM, its AIFs and associated SPEs and its clients.
Regarding the proposed 60% threshold, although many loan funds are closed-ended, a considerable percentage of loan funds are open-ended, including loan funds sponsored by government entities as part of their pension system or to finance the economy. There is robust institutional investor appetite for open-end real estate loan origination funds. These evergreen funds are less costly for investors as they do not need to be repeatedly launched and closed and, at the same time, institutional investors are aware of and able to invest in funds adequately address their liquidity management concerns.
This 60% threshold is likely to unnecessarily burden open-ended real estate loan origination funds and we therefore do not support this restriction. If a 60% or other threshold is adopted, we would urge that funds that are already established and operating should be grandfathered form having to comply with this limitation.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
17 Dec 2020
INREV, the European Association for Investors in Non-Listed Real Estate Vehicles, welcomes the opportunity to contribute to the European Commission’s consultation on a draft delegated act under the Taxonomy Regulation.
INREV values the work done by the High-Level Expert Group, the Technical Expert Group and the European Commission on Taxonomy; however, INREV believes that it is important to have harmonisation among different regulations at a certain level.
We welcome the fact that there are common principles of the Taxonomy Regulation and the Disclosure Regulation 2019/2088 (SFDR), such as “do not significantly harm” (DNSH) principle. However, we indicate major differences between the principles introduced in the SFDR and the ones provided in the Taxonomy. For example, in the SFDR the scope of DNSH principle goes beyond environmental objectives and it is factor based, while the EU Taxonomy focuses on environmental objectives and it is activity based. Another example is that they define sustainability criteria without providing reference to each other. More clarity is therefore needed on the degree of alignment between the principles introduced by these two regulations. It is critical to avoid any challenges that might result from inconsistencies between regulatory requirements.
We would like to highlight a couple of key points that should be considered when developing technical screening criteria for real estate industry, as follows:
1) The proposed technical screening criteria for real estate activities are prominently supportive of construction and/or acquisition of new buildings. While they cover renovation of existing buildings, acquisition of existing buildings with the aim of renovating them should also be included in the Annex (Section 7).
2) In relation to energy performance criteria stated in the Annex (Section 7), we promote both ‘asset rating’ as well as ‘operational rating’ where both potential and actual performance could be reflected.
3) The technical screening criteria suggest that EPCs are the only alternative for energy performance certification. They should also allow the use of other alternative energy schemes, such as voluntary rating schemes which are widely accepted by market participants and are internationally recognised. We would like to highlight that there is lack of harmonisation and comparability of existing certification schemes and energy ratings across EU member states. Without reaching some degree of harmonisation among certifications and ratings, it is difficult to measure and compare the contribution to climate change mitigation or adaptation.
4) As a general note, we suggest considering the Carbon Risk Real Estate Monitor (CRREM) decarbonisation pathways and risk assessment tool to develop technical screening criteria for the real estate industry. (CRREM: EU funded research and innovation programme for real estate industry - https://www.crrem.eu/ ).
5) INREV supports the objective of the DNSH principle and finds the conditions stated in the Annex (Section 7) mostly relevant for the real estate industry. However, the scope of the technical screening criteria does not provide clarity on how this will be reported and the levels of acceptability of the criteria. For example, “Excessive water consumption due to inefficient water appliances” is stated as one of the main potentials for significant harm to the other environmental objectives. But the framework still needs further clarity on what metric should be used to define how much water consumption is considered to be excessive.
Read full response