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From Berlin to Vienna and Barcelona: how could European housing policies influence the UK?

Europe's impetus to build affordable, social homes could show a better way for England.

By Samir Jeraj

On 26 September 2021, Berlin used the power of the ballot box to launch a revolution. Voters in the city backed a consultative referendum to turn more than 240,000 rented homes into public housing, expropriating them from powerful landlords who owned more than 3,000 homes.

“In Berlin, over 80 per cent of people are tenants – so the rental market is huge,” explains Colleen Higgins, an organiser with the campaign group Deutsche Wohnen & Co Enteignen (DWE). As rents began to rise and housing standards fell, activists looked towards the housing stock that had been bought by companies in the 1990s and the 2000s when the local government needed money. In 2021, they demanded this housing be brought back into public ownership to meet the needs of Berliners rather than those of landlords.

England is currently facing a housing crisis and could do well to look at the experiences of other countries. In Scotland, the devolved government has taken steps that would make Westminster nervous, such as abolishing the right to buy and allowing councils to control rents, while Vienna has maintained a large public housing stock for decades, and Berlin has taken radical steps towards expropriating private housing for social use by mobilising more than a million voters in a referendum.

“We didn’t start from scratch, we started with a lot of tenants already organising,” says Andrei Belibou, another activist with DWE. He explains that the campaign was structured along two parallel lines; one comprised a set of working groups which covered key parts of the campaign, from communications to collecting signatures for the referendum. This sat alongside groups for each of the city’s 12 neighbourhoods (called kiez in German), such as Neukölln in the south or Mitte (literally “middle”). “So, we can involve people by addressing their specific needs, because people in this kiez team will know their neighbourhood and they will know what’s going on there, what people need,” Belibou says. There are also efforts to organise renters whose first language is not German, an important factor in an international city and a reflection that some of the most disadvantaged renters are migrants.

The campaigners also used traditional fly-posting and door-knocking tactics together with digital technology that enabled more people to get involved. The result was definitive: 59 per cent of Berliners who are eligible to vote voted for the proposals on a turnout of 73 per cent.

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In Scotland, the SNP government has steered through a set of centre-left reforms designed to tackle the country’s housing crisis while putting them on a very different path from England under the Conservatives.

“We have this long-term housing strategy [for Scotland] Housing to 2040, which is genuinely comprehensive,” says Professor Ken Gibb, director of the UK Collaborative Centre for Housing Evidence. “It has a genuine vision and principles, it’s quite radical in what its aims and objectives are, perhaps too radical in the sense that the bar to achieve them is much, much higher,” he adds. The aims include ending homelessness, achieving net zero by 2045, and ensuring long-term stability in house prices. This last point is a radical one, as it would mean transforming housing’s role in the economy, focusing on it as a human right rather than as an asset.

However, with great and long-term ambition comes challenges – primarily, these include how to design the right policies, pass them, build a cross-party consensus so that they survive a potential change in government, and actually deliver results. This is all while working in a policy and spending environment that is not within the Scottish government’s control: for example, the capital budgets allocated to Scotland from the UK government will largely determine how many of the promised 10,000 new social and affordable homes can be built.

“There are big external shocks: cost of living, rising development costs, rising construction costs, which are turning social housing providers away from developing, as well as the private market [away] from developing,” Gibb says. The Scottish government has also disproportionately cut funding for building new homes, further reinforcing the impact from the rising costs of construction.

Scottish parliamentarians are also debating proposals on rent controls and strengthening the response to homelessness, but Gibb feels these policies have not been specific enough and risk placing further duties on councils that they do not have the resources to deliver. “It’s not enough to have a vision, you have to have a mechanism by which government and parliament can be held to account over a period of time,” he says. To some extent Scotland under the SNP and Wales under Labour have followed a similar journey, but at different paces, regulating the private rented sector and curbing the right to buy. Scotland went further and abolished the Right to Buy scheme, which Gibb says incentivised councils to start building new housing by ensuring new social housing would not be lost to private ownership.

“The real problem is not that we’re not building enough homes, it’s that we have turned housing into a financial asset,” says the economist Dr Josh Ryan-Collins of University College London. He points to how this has come about from housing policy dating back to the 1980s, and arguably to the 1970s, prioritising home ownership. “The whole system, the fiscal policy, financial regulation, and planning and housing policy favours this one tenure and discriminates against the other tenures,” he says.

Ryan-Collins points to Barcelona and the policies of Ada Colau, who was mayor from 2015 to 2023, as an inspiring example of what he would like to see in the UK. These included giving the city’s government first refusal on the sale of private rented homes, which enabled the authorities to buy up and convert homes into social housing on a large scale. Colau’s administration also supported cooperative housing and introduced successful rent controls, something Scotland is currently grappling with.

Vienna is another example of a city that in the 1920s, during a period of extreme economic hardship, successfully built new housing at scale, funded by taxes on luxuries. Today, Vienna is one of Europe’s most affordable cities for housing, retaining a large stock of publicly owned housing that means rents are around a third of those in London. The quality of housing is also high, designed to be beautiful as well as practical for an individual or family, meaning that Vienna has remained a desirable yet also achievable place to live.

Ryan-Collins also wants to see significant changes in macro-economic policy to reduce the flow of speculative investment, where landlords buy UK housing stock in order to profit from rising house prices. He also wants to see change to the development model the country uses. “It’s dominated by private developers and landlords who want to maximise the land value,” he says. That meant there was no incentive for developers to increase the supply of housing to an amount that would lead to a fall in house prices.

There are also substantial logistical and environmental challenges to building new housing. Ryan-Collins believes the best and quickest way to increase the supply of housing in the UK is to target policies, and specifically taxes, on owner-occupiers who are living in larger homes than they need, or not living in them at all. Such policies would encourage these individuals to downsize and would focus all new building on social housing.

“The only type of housing that should be built now is full, genuinely affordable social rental housing,” says Ryan-Collins, adding that the UK should follow Barcelona and implement a government buy-up scheme for private rented housing.

Yet Berlin’s tale comes with a cautionary warning that progress is rarely easy.

While DWE won its 2021 referendum, the expropriation has yet to happen. The city government sent the proposal to a commission to check its legality, something campaigners felt was a stalling tactic as they had already done their research on this. By the time it was deemed legal, a new city government led by a centre-right mayor was in power, putting the brakes on the radical move. Campaigners are now working on a second, legally binding, referendum where they will have drafted the new law themselves.

The challenge in England is the seeming lack of political will at a national level to up-end the current system. Years of devolution and levelling up have yet to bestow the powers to councils and combined authorities to fund new social housing, just as they have as yet to empower voters in Berlin to take the initiative and make legislative change.

The UK has already seen sustained long-term policy with a broad political consensus – but this has been in supporting home ownership and rising property values. These policies have enriched some, but impoverished many and are no longer economically tenable. The question is whether the UK can forge a new vision and consensus on a housing system that can meet the needs of its citizens – and then make it happen over the coming decades.

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