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European Public Real Estate Association

EPRA

EPRA represents publicly traded European real estate companies with over €840 billion in assets, promoting investment in listed real estate.

Lobbying Activity

Meeting with Aura Salla (Member of the European Parliament)

17 Dec 2025 · General introduction and shared priorities

Real estate group EPRA seeks simpler EU taxonomy rules

5 Dec 2025
Topic — The European Commission is reviewing environmental delegated acts for the EU taxonomy.
Message — EPRA requests treating the taxonomy as a classification tool instead of building-level certification. They urge including acquisition and ownership as eligible activities for circular economy reporting. The group calls for unifying sustainable investment definitions across different EU regulations.123
Why — Property owners would avoid high costs associated with mandatory third-party asset verification.45
Impact — Professional auditing firms lose business as mandatory third-party building certifications are scrapped.6
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Meeting with Yannis Maniatis (Member of the European Parliament)

23 Oct 2025 · Housing Crisis in the EU

Meeting with Alicia Homs Ginel (Member of the European Parliament)

14 Oct 2025 · HOUS Draft Report position

Meeting with Borja Giménez Larraz (Member of the European Parliament, Rapporteur)

22 Sept 2025 · HOUS Draft Report

European property sector urges regulatory reforms for housing investment

13 Aug 2025
Topic — A consultation on a European strategy to improve housing construction productivity.
Message — EPRA requests streamlined permitting timelines and the removal of state aid caps. They advocate for harmonized real estate investment rules across the Single Market. They want tax rules adjusted to better support large-scale housing projects.123
Why — These changes would reduce project delays and lower overall financing costs.4
Impact — Environmental groups may see green standards compromised by more flexible requirements.5
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Response to Review of the State aid rules on the Services of General Economic Interest (“SGEI”)

30 Jul 2025

The European Public Real Estate Association (EPRA) is the voice of Europes listed real estate sector, representing over 290 publicly listed property companies (including Real Estate Investment Trusts REITs) with a combined EUR 880+ billion in assets. EPRAs members are long-term owners, managers, and developers of real estate across Europe, committed to sustainable and inclusive growth. Many listed property companies are directly engaged in housing from investing in affordable and mid-market rental homes to converting underused buildings into housing bringing global capital, expertise, and scale to help address Europes housing crisis. We welcome the opportunity to contribute to the European Commissions call for evidence on revising the State aid rules for Services of General Economic Interest (SGEI) in housing, and we fully support the broader European Affordable Housing Plan slated for 2026. The revision of Services of General Economic Interest (SGEI) State aid rules for affordable housing is a timely and critical step. Current State aid rules have not fully facilitated affordable housing investment at scale. In the attached paper, EPRA outlines its key recommendations for a revised SGEI framework aimed at unlocking greater investment in affordable housing.
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Meeting with Antonella Sberna (Member of the European Parliament)

16 Jul 2025 · Posizione di EPRA sulla crisi abitativa

Response to Commercial real estate statistics

11 Jul 2025

The European Real Estate Association (EPRA) is the voice of Europes listed real estate companies, their investors, and suppliers. With more than 290 members covering the entire spectrum of the listed real estate industry, EPRA represents over EUR 880 billion in real estate assets and 95% of the market capitalisation of the FTSE EPRA Nareit Europe Index. EPRAs mission is to promote, develop, and represent the European public real estate sector. We achieve this by providing better information to investors and stakeholders, actively engaging in public and political debates, promoting best practices, and fostering cohesion and strength within the industry. In this capacity, we welcome the opportunity to provide feedback on the proposed Regulation for non-financial commercial real estate statistics. Youll find our recommendations outlined in greater detail in the attached document.
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Response to Recommendation on savings and investment accounts

7 Jul 2025

The European Real Estate Association (EPRA) is the voice of Europes listed real estate companies, their investors, and suppliers. With more than 290 members covering the entire spectrum of the listed real estate industry, EPRA represents over EUR 880 billion in real estate assets and 95% of the market capitalisation of the FTSE EPRA Nareit Europe Index. In this role, we welcome the opportunity to present our recommendations for the Savings and Investments Accounts, as it presents a key opportunity to strengthen capital markets for long-term investments. It also allows for an assessment of competitive models within and beyond the EU. Indeed, while the precise structure of a comprehensive SIU is still being debated, insights from successful existing models can provide a valuable blueprint for its development. You will find our recommendations attached in greater detail.
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Meeting with Philippe Moseley (Cabinet of Commissioner Dan Jørgensen) and European Association for Investors in Non-Listed Real Estate Vehicles

11 Jun 2025 · Housing

European real estate sector seeks tailored sustainable finance labels

30 May 2025
Topic — The European Commission is reviewing rules for disclosing sustainable financial product information.
Message — EPRA requests a tiered classification system that better reflects real estate investment strategies. They call for specific criteria to recognize building renovations as critical transition activities. They also suggest aligning disclosure requirements with building energy performance standards.12
Why — Simplifying requirements would lower compliance costs and reduce legal risks for property funds.34
Impact — Investors may face less comparable data if industry-led proxies replace standardized energy certificates.5
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Response to European Affordable Housing Plan

28 May 2025

The European Public Real Estate Association (EPRA) is the voice of Europes listed real estate companies, their investors, and suppliers. With more than 290 members covering the entire spectrum of the listed real estate industry, EPRA represents over EUR 880 billion in real estate assets and 95% of the market capitalisation of the FTSE EPRA Nareit Europe Index. EPRAs mission is to promote, develop, and represent the European publicly listed real estate companies. We achieve this by providing better information to investors and stakeholders, actively engaging in public and political debates, promoting best practices, and fostering cohesion and strength within the industry. In this role, we welcome the opportunity to provide our feedback on the call for evidence regarding the upcoming European Affordable Housing Plan. This consultation comes at a pivotal time. Europes housing markets are under severe strain. Theres an acute shortage of available homes, much of the current housing stock requires upgrades to meet quality and energy efficiency standards, and housing costswhether renting, buying, or developinghave soared beyond what most households can afford. This crisis calls for urgent, coordinated action and a long-term strategy to deliver lasting solutions. The attached paper presents targeted industry solutions in this call for evidence to help fuel the EUs housing response. With the support of our members, we have developed a paper featuring 18 actionable recommendations, supported by real-world case studies that demonstrate how listed property companies are already making a differenceand how their impact can be further scaled.
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EPRA urges harmonised energy standards to drive green investment

7 May 2025
Topic — Revising the methodology for calculating cost-optimal energy performance levels for buildings.
Message — Promote consistent transposition of performance requirements and definitions across Member States. Reflect actual market diversity and use lower discount rates for valuations. Align national frameworks with recognised tools and voluntary disclosure frameworks.123
Why — Harmonised rules would lower compliance costs and increase investment certainty.45
Impact — Diverse asset classes lose out as policy incentives favor specific typologies.6
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EPRA seeks unified and simplified EU sustainability reporting rules

26 Mar 2025
Topic — The initiative simplifies EU sustainability reporting requirements to balance environmental goals with business competitiveness.
Message — EPRA requests aligning reporting thresholds with existing directives and allowing building standards like BREEAM as energy proxies. They also propose unifying sustainable investment definitions and simplifying criteria for pollution and circular economy.123
Why — Simplified requirements would reduce administrative burdens and support sector growth and competitiveness.45
Impact — Environmental groups lose oversight if pollution data and circularity requirements are removed.67
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EPRA urges overhaul of EU real estate securitisation rules

25 Mar 2025
Topic — The Commission is reviewing rules for securitisation transparency, due diligence, and institutional capital requirements.
Message — EPRA urges the EU to recalibrate capital requirements to better reflect actual risk. They want the STS framework revised to accommodate commercial real estate debt characteristics. The group advocates for a principle-based, proportionate, and less prescriptive regulatory framework.123
Why — Lowering barriers would allow firms to recycle capital and fund large-scale property projects.4
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Meeting with Julie Rechagneux (Member of the European Parliament)

25 Mar 2025 · Position du secteur des sociétés immobilières cotées sur la commission HOUS

Meeting with Lauro Panella (Cabinet of Commissioner Maria Luís Albuquerque)

12 Mar 2025 · EPRA presented their company and activities

Response to Savings and Investments Union

26 Feb 2025

The European Real Estate Association (EPRA) is the voice of Europes listed real estate companies, their investors, and suppliers. With more than 290 members covering the entire spectrum of the listed real estate industry, EPRA represents over EUR 880 billion in real estate assets and 95% of the market capitalisation of the FTSE EPRA Nareit Europe Index. EPRAs mission is to promote, develop, and represent the European publicly listed real estate sector. We achieve this by providing better information to investors and stakeholders, actively engaging in public and political debates, promoting best practices, and fostering cohesion and strength within the industry. In this role, we welcome the opportunity to present our recommendations for the Savings and Investments Union (SIU) as it presents a key opportunity to strengthen capital markets for long-term investments. It also allows for an assessment of competitive models within and beyond the EU. Attached is our detailed and comprehensive contribution.
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Meeting with Dirk Gotink (Member of the European Parliament)

19 Feb 2025 · Housing

EPRA urges harmonization of European real estate investment regimes

23 Jan 2025
Topic — The European Commission is updating its strategy to strengthen the single market.
Message — EPRA wants the Commission to harmonize fragmented national real estate investment regimes. They suggest promoting mutual recognition to facilitate cross-border capital flows.12
Why — Harmonization would reduce administrative hurdles and help European firms compete with the US.34
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EPRA urges broader scope for energy renovation lending framework

4 Nov 2024
Topic — A consultation establishing a voluntary portfolio framework to increase lending for energy renovations.
Message — EPRA requests a framework covering all buildings instead of only the worst-performing assets. They suggest introducing financial incentives and aligning the rules with existing banking and sustainability regulations.123
Why — This ensures their high-quality property portfolios remain eligible for renovation financing and incentives.45
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Meeting with Eero Heinäluoma (Member of the European Parliament) and The European Digital Payments Industry Alliance

20 Sept 2024 · Current Affairs

Real estate body EPRA urges tax exemptions for housing

10 Sept 2024
Topic — The Commission is evaluating rules that address common forms of aggressive tax avoidance practices.
Message — EPRA wants to preserve the unique characteristics of national REIT regimes and avoid asymmetrical tax treatment. They request new exclusions for borrowing costs related to housing shortages and renovation needs.12
Why — This would increase the attractiveness of the sector and boost private capital flows.3
Impact — National governments would lose revenue currently collected from limits on corporate interest deductions.4
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Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

5 Sept 2024 · Introductory meeting, next mandate

Response to Business in Europe: Framework for Income Taxation (BEFIT)

19 Jan 2024

The European Public Real Estate Association (EPRA) is pleased to offer feedback on the BEFIT proposal, which is contained in the attached document. EPRA is the voice of Europes listed real estate companies and with more than 290 members (companies, investors, and their suppliers), EPRA represents over 840 billion EUR of real estate assets (European companies only) and 95% of the market capitalisation of the FTSE EPRA Nareit Europe Index.
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Real estate association urges equal tax treatment for REITs

18 Sept 2023
Topic — A proposal to standardise withholding tax relief procedures across the European Union.
Message — The association requests specific provisions ensuring Real Estate Investment Trusts benefit from the new tax procedures. They advocate for relief at source to be the mandatory default system. Finally, they suggest limiting fees charged by financial intermediaries.123
Why — These changes would ensure their members avoid double taxation and high administrative costs.45
Impact — Financial intermediaries might lose revenue if the EU limits their service fees.6
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EPRA urges flexible carbon pricing and shared building costs

28 Aug 2023
Topic — The European Commission is updating registry rules to incorporate maritime and aviation into the ETS.
Message — EPRA recommends a flexible system that accounts for national energy infrastructure and specific building types. They propose sharing carbon costs between owners and tenants based on a building’s energy performance.12
Why — Linking costs to refurbishment allows landlords to transfer carbon pricing burdens to tenants after upgrading properties.3
Impact — Low-income households may suffer more because carbon costs represent a larger share of their income.4
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EPRA urges mutual recognition of real estate investment trusts

26 Aug 2023
Topic — The EU is proposing measures to increase retail investor participation in capital markets.
Message — The association supports a unified EU system for withholding tax relief. They also propose soft-law measures for mutual recognition of real estate investment trusts.12
Why — Removing regulatory barriers would allow real estate companies to expand cross-border investment.34
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Real estate group demands clearer EU sustainability reporting definitions

6 Jul 2023
Topic — The EU is establishing mandatory standards for how companies disclose sustainability information.
Message — EPRA supports the new standards but requests more complete definitions and instructions. The group believes more clarity and time are needed for effective implementation.123
Why — This would allow real estate companies to avoid significant costs for mandatory auditing.4
Impact — Investors lose timely access to sustainability data if implementation timelines are extended.56
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European real estate group demands inclusion of rental property income

3 May 2023
Topic — This consultation defines environmentally sustainable economic activities within the EU’s green investment classification system.
Message — EPRA urges the Commission to include buildings developed or renovated for long-term rental income. They also request allowing alternatives to energy certificates and simplifying environmental safeguard requirements.12
Why — Listed property companies would be able to report their rental income as sustainable turnover.3
Impact — Environmental protections might be compromised if safeguards against significant harm are simplified as requested.4
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Response to Minimum level of taxation for large multinational groups

6 Apr 2022

EPRA gladly takes the opportunity to comment on the Proposal for a Council Directive on ensuring a global minimum level of taxation for multinational groups in the European Union, as we followed closely the negotiations at the OECD level. EPRA supports the efforts of the European institutions to implement the agreement of the OECD GloBE Pillar II on an EU level and would like to highlight few key concerns to contribute to a well reflected and fully functioning implementation. To begin with, we would like to underline the potential issue of double taxation in case of participations held by regularly taxed entities in so called Real Estate Investment Trusts (REITs). In some countries, for example in the UK, a stake in a REIT is commonly kept just below 10%, as to fulfill the respective local REIT-requirements. In the current proposal, such a stake would be regarded as a “portfolio shareholding” (Article 15,1,b,i), hence gains and losses arising from changes in the fair value of, or resulting from the disposal of, such ownership interests would not be exempted from the “qualifying” income, which potentially would lead to double taxation, with an expectedly concomitant decrease of attractiveness of those REITs for investors. More detailed position of EPRA can be found in the attached document:
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Response to Fighting the use of shell entities and arrangements for tax purposes

6 Apr 2022

The European Public Real Estate Association (EPRA) is the voice of Europe's listed real estate companies that derive income from the ownership, trading and development of income producing real estate assets. Listed real estate allows anyone, from retail investors to large institutional investors, to invest in the underlying assets of publicly quoted companies, the same way as investing in other industries through purchasing shares. With more than 280 members (companies, investors and their suppliers), EPRA represents over 680 billion EUR of real estate assets (European companies only) and 94% of the market capitalisation of the FTSE EPRA Nareit Europe Index. EPRA plays a leading role in increasing the transparency of the listed real estate environment by improving the quality and consistency of the financial reporting, performance reporting and corporate governance framework within Europe. EPRA produces its Best Practice Recommendations (BPR) which are a recognised benchmark for reporting listed real estate under international accounting standards. General position EPRA welcomes the opportunity to provide feedback to the European Commission proposal laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU (the “Directive” or “proposal”). Whilst we fully support the Commission’s fight against tax avoidance, it is EPRA’s view that the proposal will risk resulting in incoherent legislation, as a number of significant measures in this domain have only recently been implemented and their impact has not yet been evaluated. The proposal is based on assumptions that predate and ignore several initiatives to counter base erosion and profit shifting. In the context of the EU, the shell entities initiative does not take into account in particular: • the Anti-Tax Avoidance Directives (I&II) • the Directive on Administrative Cooperation (DAC) • the fourth Anti-Money Laundering Directive • EU-list of non-cooperative jurisdictions for tax purposes • the end of several national tax practices and the introduction of safeguards as a result of the OECD BEPS action plans, in particular the introduction of minimum standards (e.g. the principal purpose test of BEPS Action 6). While the main goal of the Directive is to tackle tax avoidance and evasion via shell entities, which we share, the proposal integrates disproportionate elements also targeting entirely legitimate business structures. The current proposal triggers several concerns that will be addressed in more detail below. Detailed explanation of position can be found in the attached paper:
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

EPRA*, representing the listed real estate sector in Europe, thanks the Commission for the opportunity to provide feedback on the draft Delegated Act on Article 8 of the EU Taxonomy Regulation (TR). EPRA’s feedback is focused on the listed real estate sector due to the Association’s sector specific knowledge and experience. Key highlights:  We welcome the Commission’s proposal to specify the content, methodology, and presentation of the information to be disclosed by both non-financial and financial undertakings. We consider the proposed draft a solid and much needed foundation towards enabling companies in scope of the Taxonomy Regulation to disclose relevant information in a comparable way. We stress that the clearer the rules on disclosure, the greater the comparability achieved for all companies, investors, financial intermediaries etc. Therefore, we encourage the Commission to provide more details and clarification on how to apply the proposed rules in a uniform way while recognising sectorial specificities (e.g. listed real estate).  The listed real estate (LRE) sector appreciates the postponement of the application on the financial KPIs to 1st January 2023 as it will allow the sector to get acquainted with the new TR rules on disclosure and gain a greater clarity on many aspects which remain unspecified. We suggest to specify in the draft Article 9(3) that the first reporting period for financial KPIs is the fiscal year 2022 to be disclosed in 2023.  In addition, we propose to equally postpone the second part of the qualitative information referred to in Section 1.2.1 of Annex I. which relates to any substantial deviations to the Capex Plan and related information, as it would not be relevant for the initial reporting years.  We recommend to further clarify: 1. The definitions of CAPEX and OPEX for investment property to ensure comparability. 2. That for those activities for which technical criteria can be verified only upon completion of the project (e.g. thermal integrity for development of new buildings), non-financial undertakings are to count their turnover, CAPEX and OPEX based, on engagement, to respect the technical criteria at the end of the project. 3. That all costs related to renovations (e.g. acquisition costs) should be added in the CAPEX for investment property if the renovations meet technical screening criteria. 4. That the KPIs of transitional activities are to be counted in the final share (in %) of the Taxonomy aligned KPIs in addition to being reported separately in the proposed templates.  We propose to specify that Methodology in point b) refers to the non-financial undertakings disclosing the KPIs for each eligible economic activity and the total KPIs for all economic activities at the level of the relevant undertaking and group.  We stress that the proposed template does not currently accommodate a full disclosure of the CAPEX plan. We suggest to extend the template to up-to 5 year time horizon to enable long-term investors to have a greater overview of the efforts pursued by non-financial undertakings.  Lastly, we refer to EPRA feedback on the ESAs consultation concerning Taxonomy-related sustainability disclosure (http://bitly.ws/dIwc). We highlight a significant lack of alignment between the methodology to calculate Taxonomy-aligned investments in non-financial undertakings. We recommend a weighted average ratio composed of all three KPIs, or alternatively a weighted average ratio composed of turnover and CAPEX, as long as the relevant share of OPEX can be added to the CAPEX plan and disclosed as part of CAPEX in the respective years. Please note that we provide additional comments in the ANNEX to the EPRA feedback on the Commission Delegated Regulation on Article 8 of the EU Taxonomy submitted on 2 June 2021. We remain available to discuss this further at your convenience. Please contact Jana Bour, EPRA EU Policy Manager, at j.bour@epra.com.
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Response to Business taxation for the 21st century

31 Mar 2021

EPRA, representing the listed real estate sector in Europe, thanks the European Commission for the opportunity to provide feedback on the ‘Communication on business taxation for 21st century’. Property companies serve businesses and society by actively developing, managing, maintaining and improving the built environment, where we all live, work, shop and relax. Listed real estate companies provide stable and strong long-term performance to investors and especially to pension funds through reliable dividends, contributing to the retirement of millions of people. The liquid nature of listed property companies facilitates also the ‘democratisation’ of real estate – by providing the opportunity for individual investors to participate alongside larger investors, in otherwise inaccessible investment opportunities. For the upcoming ‘Communication on business taxation for 21st century’ we propose the three objectives highlighted in the published Roadmap: 1) Removing barriers in investment and growth. We agree that within the European Union there is currently a patchwork of complex measures forming a business tax environment not sufficiently conducive to investment and growth. We argue that in the current context brought by the Covid-19 pandemic and other significant global developments, such as climate change and population aging, reviewing a European vision for business taxation which would focus on enabling long-term investment and sustainable growth, seems to be paramount. Particularly for listed real estate, we point out that there are currently fourteen European countries which recognised a public benefit to incentivise real estate investment through public markets and have introduced Real Estate Investment Trusts (REIT) legislation to maximise returns through an effective tax pass-through. Although those 14 countries represent 84% of the European GDP , these are still 14 unique REIT regimes with no framework in place to facilitate their mutual recognition. 2) We agree that tax policies also have a role to play in supporting business in their transition to a green Europe. A successful REIT regime could be an excellent enabling framework to drive investments in the retrofit of existing buildings. If only a REIT’s status in one Member State would be recognised in other Member States, it would significantly facilitate their ability to further scale up investments within the European internal market. If there were a European directive enabling a mutual recognition of REITs, subject to the right set of conditions, it would certainly help drive the investments toward more sustainable real estate. 3) We endorse making international tax framework better aligned with the realities of the digitalised economy and translating the OECD GloBE recommendations to the European level. As we stressed to the OECD , we are convinced that the tax policy objectives of domestic REIT regimes neither are inconsistent with the tax policy objective of the GloBE rules, nor create a competitive distortion that would undermine the tax policy objectives of the GloBE proposal. To the contrary, subjecting REITs to the GloBE rules would undermine the policy objectives that domestic REIT regimes are seeking to achieve. The uniqueness of real estate investment trusts (REITs) will therefore require a more tailored solution when addressing an international, and then European tax frameworks. We remain available to discuss this further at your convenience. Please contact Tobias Steinmann, EPRA Director Public Affairs at t.steinmann@epra.com or Jana Bour, EPRA EU Policy Manager at j.bour@epra.com.
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Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

EPRA, representing the listed real estate sector in Europe, thanks the Commission for the opportunity to provide feedback on the EU taxonomy criteria. We stress that our members, including the major listed property companies and REITs*, stand strongly behind the EU Taxonomy. There has been tremendous work done by the High-Level Expert Group, the Technical Expert Group and the Commission. It goes without saying that we need a tool – at European level – to help us speak the same language and to help the business and investment communities to re-orient the capital to where it matters. In the draft Delegated Regulation, there are many positive measures which we highlight: - The Commission’s draft focuses on real estate with seven distinct ‘economic activities’; - The preserved ambition to go beyond the current standards for new buildings; - Certain measures to improve the EU’s renovation rate from the current 0.4%-1.2%: o with well-designed screening criteria for ‘renovation’ (i.e. major renovation/-30% PED) o emphasis on the ‘individual measures and professional services’ economic activities); - Recognition of the operational property investment economic activity (‘acquisition and ownership’). There are also measures requiring further attention to become successful on the market. For example: - The Technical screening criteria supports prominently construction and acquisition of new buildings, while fully disregarding the most meaningful real estate activity to substantially support climate change mitigation, i.e. acquisition of existing buildings with the aim of renovating them. - We stress that it is the actual performance of the buildings which is sought after by the investors (rather than the designed one). There is significant evidence showing a gap between the designed and actual performance of the buildings and that EPCs are not reliable in capturing the real performance of a building. - There is a lack of measures to facilitate immediate functionality of the taxonomy within and outside the EU** (e.g. enabling use of alternative schemes as proxies for EPCs – as per TEG’s report); - Criteria for acquisition of new buildings built before 2020 are for certain member states disproportionally stricter than those for the newly built buildings after 2020. To facilitate a fair and balanced roll-out of the Taxonomy, we recommend to revert to the TEG’s recommendation of the top 15 % of the national building stock. - We noticed a particularly narrow approach on the acquisition and ownership. Property investment companies have the scale to make a true difference. They own the buildings, renovate the buildings they own (redevelopment projects), acquire existing ones to renovate and build new buildings for their own portfolio (not for sale). Therefore, we point out that there is a substantial part of their business which supports climate change mitigation but has not been recognised in the Taxonomy. - Considering the reporting obligations on the listed companies and on the financial market participants in respect of the financial products, we find the cumulative effect of the DNSH requirements excessive to the level which might render the Taxonomy unusable. We recommend to simplify the DNSH requirements. We urge the Commission to postpone the Taxonomy Delegated Regulation’s adoption, revisit all the technical details and take more time to justify where it deviates from the HLEG’s and TEG’s recommendations. Please note that we elaborate on each of the mentioned points in the ANNEX to the EPRA feedback on the Taxonomy Delegated Regulation submitted on 17 December 2020. We remain available to discuss this further at your convenience. Please contact Jana Bour, EPRA EU Policy Manager at j.bour@epra.com. * The vast majority of constituent companies included in the FTSE EPRA Nareit Europe Real Estate Index ** We refer to EU Member States such as Belgium or Germany which don’t rely on EPCs ratings
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Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

30 Oct 2020 · Climate transition and renovation wave

Meeting with Maria Elena Scoppio (Cabinet of Commissioner Paolo Gentiloni)

14 Sept 2020 · REIT Regime and its opportunities

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

7 Sept 2020

EPRA, representing the listed real estate sector in Europe, thanks the European Commission for the opportunity to provide feedback on the possibility of a Delegated Regulation on Taxonomy-related disclosures by undertakings reporting non-financial information. We sincerely believe that both the EU Taxonomy Regulation and its upcoming delegated rules setting up a Technical Taxonomy will aid substantially in identifying and then re-directing the capital flows into more sustainable activities. In this context, there is a strong agreement between both the investment and business communities that providing right information to the investors will determine the size of its success [e.g. EIOPA’s Financial Stability Report – July 2020]. Regarding the Taxonomy related disclosures, we believe that the three specific indicators (turnover, Capex and/or Opex), which are embedded in the EU Taxonomy Regulation, are sufficiently clear and provide for an excellent guide for companies to begin with a related disclosure (attached are a few examples). What is needed next, in our opinion, is to ensure that the EU Technical Taxonomy, in a form of a delegated regulation, will also be sufficiently clear so that undertakings are able to determine their degree of alignment with the technical taxonomy. We stress that there are great differences between various sectors and trying to come up with a ‘one fits to all’ solution might not bring the anticipated results. We therefore urge the European Commission to remain focused on the Technical Taxonomy and keep the discussion on the economic activities going. We also ask the Commission to consider that there are great sector differences and specificities and therefore it is important to let those sectors look for solutions which would help companies provide for material and comparable information within each sector, e.g. real estate. Lastly, we stress that there is an ongoing review of the Non-Financial Reporting Directive (NFRD) and we would like to invite the European Commission to consider a greater alignment between the Taxonomy and NFRD. We refer to the EPRA position paper on NFRD (2020) for your consideration. It is accessible at the following weblink: https://www.epra.com/application/files/5515/9948/1701/EPRA_position_on_NFRD_2020_Review__August_2020.pdf. We would welcome a constructive dialogue with you on this subject and remain available to discuss this further at your convenience at publicaffairs@epra.com.
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Response to Climate change mitigation and adaptation taxonomy

23 Apr 2020

EPRA, representing the listed real estate sector in Europe, thanks the Commission for the opportunity to provide feedback on the EU taxonomy criteria. We consider the work of the Technical Experts Group (TEG) important in guiding investors to support businesses on their transition path towards sustainability. There are few out of many positive measures which we would like to highlight: • Alignment with the Non-Financial Reporting Directive (NFRD) is an encouraging step towards greater transparency; • Buildings have been recognised as effectively the largest energy consuming sector; • TEG’s focus on real estate with four distinct ‘economic activities’; • The ambition to go beyond the current standards for new buildings; • Measures to facilitate immediate functionality of the taxonomy outside the EU (e.g. for building renovation); • Measures to improve the EU’s renovation rate from the current 0.4%-1.2% (e.g. the ‘individual measures and professional services’ economic activity); • Measures to help improve the operational phase of the building’s life cycle (e.g. ‘acquisition and ownership’ as an economic activity). Considering the scale of the project, it is only expected that we would need further clarification on certain details. With that vision, EPRA welcomes the TEG EU Taxonomy Webinar Series which are to provide clarity by answering to questions that stakeholders may have. We would like to point that the EU Taxonomy Webinar on Buildings [https://www.youtube.com/watch?v=Bule8fKdM94&feature=youtu.be], held on April 2nd, was particularly helpful in clarifying the possibility to count revenue of eligible assets for climate change mitigation under the ‘acquisition and ownership’ economic activity. In fact, TEG’s Report explains at page 16 that for climate change mitigation, an economic activity can count turnover for the economic activity which meets technical screening criteria. On the other hand, for climate change adaptation, turnover can only be counted where the activity is enabling adaptation by others. Therefore and in line with the additional clarifications provided by the TEG experts, it is our understanding that real estate activities (L68.2) should be enabled to capture the proportion of turnover related to the rental income of the assets meeting technical screening criteria set by the EU Taxonomy. There are few areas where we have further questions referring to the classification of the economic activities in the Taxonomy and its consistency with the NACE Rev. 2 Statistical classification of economic activities in the EU. We attach an excel document converted to PDF in which we built few practical case studies (from page 12) in order to simulate the application of the current Taxonomy by the listed real estate sector. Based on the simulated case studies, we have few follow-up questions which are integrated in the document itself (at page 11 and then from 12 until 15). On that note, we would like to point out that Eurostat has been consulting on the classification’s revision during the summer 2019 and therefore we wonder whether there will be changes to the NACE classification before the EU Taxonomy will be applicable. We remain available to discuss this further at your convenience.
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Response to Revision of Non-Financial Reporting Directive

25 Feb 2020

The European Public Real Estate Association (EPRA) is the voice of Europe's listed real estate companies that derive income from the ownership, trading and development of income producing real estate assets. With more than 270 members (companies, investors and their suppliers), EPRA represents over 450 billion EUR of real estate assets (European companies only) and 94% of the market capitalisation of the FTSE EPRA Nareit Europe Index. Helping our members to lead the market, EPRA acknowledged the importance of reporting practices and provided an additional layer of financial transparency by developing their set of best practice recommendations (BPR) as early as in 2001. The main aim has been to further advance transparency of the sector which is required by EU law for all listed companies. As further step in this direction, EPRA developed in 2011 its set of Sustainability Best Practices Recommendations (sBPR) to provide investors with material, comparable and consistent ESG data. The EPRA sBPR Guidelines represent the sole industry standard for public ESG disclosure in the European listed real estate sector with more than 70 listed companies fully adopting it. As any other standard, the set of recommendations is periodically revised in consultation with the investment community to ensure that information disclosed by listed property companies are relevant and financially material for the primary users (i.e. investors). The current edition of the EPRA sBPR Guidelines (3rd edition) was launched in September 2017 and draw on the Global Reporting Initiative’s (GRI) Reporting Standards (2016 edition) and Construction & Real Estate Sector Disclosures (CRESD), and in line with the EU NFR Directive. Investors are pleased with sBPR and continue to engage with EPRA seeking greater comparability of the ESG data. To further increase comparability of ESG data, EPRA developed database of all ESG information disclosed by listed property companies under the sBPR. EPRA sBPR database is to meet the investors’ need of accessing ESG data more easily and in a more comparable way. The unique feature of the EPRA sBPR database is that it is freely and publicly accessible by any stakeholder (*). EPRA welcomed the EU NFRD and considered it the beginning of the policymakers’ efforts to enhance the transparency of companies’ ESG performance. EPRA’s observations in this regard are that listed property companies go voluntarily beyond what is currently required by legislation. For example, many EPRA members would not meet the minimum 500 employees’ threshold for NFRD to apply; nevertheless they do disclose this information on a voluntary basis to remain competitive and to demonstrate that they are managing ESG factors and improving their performance over time. EPRA has observed that a correlation between the size of listed property company and the quality of sustainability disclosures is decreasing (**). It clearly shows that the trend is heading towards smaller sized listed property companies with better reporting on non-financial information. We recognise that EPRA’s approach in equipping smaller companies to continue to improve their sustainability disclosure by granting them access to a specifically tailored industry standard (EPRA sBPR) proved successful. As for the development of a European non-financial reporting standard, we believe that this work might bring many benefits as long as it brings/or enables further industry per industry focus so that there is a level of standardisation but also equipment for European small and medium sized companies. (*) https://www.epra.com/register (**) 33% of companies fully reporting in compliance with EPRA sBPR has a market capitalisation < 1 billion euro; 47% of companies fully reporting in compliance with EPRA sBPR has a market capitalisation between 1 and 5 billion euro; 20% of companies fully reporting in compliance with EPRA sBPR has a market capitalisation > 5 billion euro. Data refers to FY 2018.
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